UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INNOLUX CORPORATION
`Petitioner,
`
`v.
`
`SEMICONDUCTOR ENERGY LABORATORY CO., LTD.
`Patent Owner.
`
`Case IPR2013-00038
`U.S. Patent 7,956,978
`
`PETITIONER’S OPPOSITION TO MOTION TO AMEND
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INNOLUX CORPORATION
`Petitioner,
`
`v.
`
`SEMICONDUCTOR ENERGY LABORATORY CO., LTD.
`Patent Owner.
`
`Case IPR2013-00038
`U.S. Patent 7,956,978
`
`PETITIONER’S OPPOSITION TO MOTION TO AMEND
`
`
`
`
`
`Petitioner Innolux Corporation ("Innolux") hereby provides its opposition to
`
`Patent Owner Semiconductor Energy Laboratory Co., Ltd.'s ("SEL" or "Patent
`
`Owner") Motion to Amend ("Motion"). Because SEL's proposed amendments are
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`not supported by the specification and also fail to respond to a ground of
`
`unpatentability involved in the trial, SEL's motion should be denied.
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`I. Legal Standards
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`
`
`The Patent Owner, as the moving party, bears the burden to show entitlement
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`to the requested relief. See 37 C.F.R § 42.20(c). For a patent owner's motion to
`
`amend, 37 C.F.R §42.20(c) places the burden on SEL to show a patentable
`
`distinction of each proposed substitute claim over the prior art of record and prior
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`art known to the patent owner. See Idle Free Systems, Inc. v. Bergstrom, Inc.,
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`IPR2012-00027, Paper 26 ("Some representation should be made about the specific
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`technical disclosure of the closest prior art known to the patent owner, and not just a
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`conclusory remark that no prior art known to the patent owner renders obvious the
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`proposed substitute claims."). Moreover, a motion to amend may be denied where
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`the amendment does not respond to a ground of unpatentability involved in the trial.
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`See Id.
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`
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`A motion to amend may also be denied if it introduces new matter. See 35
`
`U.S.C. § 316(d)(3); 37 C.F.R. § 42.121(a)(2)(ii). The burden is on the patent owner
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`to show written description support in the original disclosure of the patent. The
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`written description test is whether the original disclosure of the application relied
`1
`
`
`
`
`
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`upon reasonably conveys to a person of ordinary skill in the art that the inventor had
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`possession of the claim subject matter as of the filing date. See IPR2-12-00005,
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`Paper 27 (citing Ariad Pharms., Inc. v. Eli Lilly & Co., 598 F. 3d 1336, 1351 (Fed.
`
`Cir. 2010) (en banc)). If the claim language does not appear in ipsis verbis in the
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`original disclosure, a mere citation to the original disclosure without any
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`explanation as to why a person of ordinary skill in the art would have recognized
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`that the inventor possessed the claimed subject matter as a whole may be
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`inadequate. See IPR2-12-00005, Paper 27.
`
`
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`The written description test is whether the original disclosure of the
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`application relied upon reasonably conveys to a person of ordinary skill in the art
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`that the inventor had possession of the claim subject matter as of the filing date. See
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`IPR2-12-00005, Paper 27 (citing Ariad Pharms., Inc. v. Eli Lilly & Co., 598 F. 3d
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`1336, 1351 (Fed. Cir. 2010) (en banc)).
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`II. The Proposed Amendment is Not Supported in the Original Disclosure
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`
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`In its Motion, SEL asserts that "layer" means "a continuous, unitary
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`structure." Id. at 7. In the context of the proposed claims, SEL further asserts that
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`"unitary" means that "the first conductive layer and the second conductive layer
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`each is a unitary layer."1 See Mot. 4-5. But, the construction of a "layer" being a
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`1 SEL also mis-states the appropriate construction standard of the broadest
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`reasonable construction. Instead, SEL states that its proposed construction of
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`2
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`
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`continuous, unitary structure is inconsistent with the ordinary meaning of layer and
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`the specification's description of layer in the '978 patent where a "layer" is described
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`as a structure having multiple, discontinuous parts.2 If the definition of a
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`conductive layer is a limited to continuous, unitary structures, then many of the
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`conductive layers described in the '978 patent would be excluded:
`
` "As shown in in FIG. 4, the dummy wirings 304 for the second layer are
`disposed uniformly at the respective gaps defined between the dummy
`wirings 301, the wirings 302 and the wirings 303 for the first layer which
`are formed of the starting film (silicon film)…" See Ex. 1001, Col. 9, ll.
`28-32 (emphasis added).
`
` "the dummy wirings 301, the wirings 302 and 303 for the first layer is
`not limited to a silicon film.." See Ex. 1001, Col. 8, ll. 24-26 (emphasis
`added).
`
` "It should be noted that the pitch of the dummy wirings 304 for the
`second layer is set to the pitch of the scanning lines 106…" See Ex. 1001,
`Col. 9, ll. 60-61 (emphasis added).
`
` "As shown in Figure 6, in the sealing material formation region, first
`support members 301, 302, and 303 made of the same material as the
`scanning lines 106…" See Ex. 1001, Col. 4, ll. 17-19 (emphasis added).
`
` "FIG. 4 is a top view showing the substrate interval correction means, in
`which first linear support members 301, 302, and 303 and second support
`members 304 are disposed alternatively at regular intervals.." See Ex.
`1001, Col. 4, ll. 63-66 (emphasis added).
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`
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`"layer" is a "reasonable construction." See Mot. at 5.
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`2 The Board held that all claims terms (with the exception of "pitch" and "black
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`matrix") are to be given their ordinary and customary meaning. See Decision at 9.
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`
`
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`3
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`
`
` "linear dummy wirings 301 for the first layer are formed by patterning
`the silicon film.." See Ex. 1001, Col. 7, ll. 61-64; see also Ex. 1012,
`Hatalis Dep. at 139:19-141:4.
`
`
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`In each of the instances above, the "layer" is associated with a plurality of
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`discontinuous, dummy wiring structures, which is inconsistent with the definition
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`proposed by SEL. For example, one of ordinary skill in the art reading the
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`specification would understand that the first layer comprises more than one dummy
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`wiring, i.e., wirings 301, 302 and 303. SEL mis-states the specification when it says
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`that it "describes conductive layers as 'support members' and/or 'dummy wirings,'
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`each of which is unitary, i.e., one continuous member." See Mot. at 5. As shown
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`above, however, the '978 specification actually refers to the support members and
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`dummy wirings as a first or second layer. As such, the layer is neither continuous
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`nor unitary.
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`
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`SEL next asserts that the specification describes that "'first support members
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`[301, 302 and 303 shown in Fig. 6]' correspond to the 'first and second conductive
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`layers.'" See Mot. at 6. From this interpretation, SEL concludes that the first and
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`second layers are unitary layers. Id. But, the specification actually describes that
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`"[a]s shown in Fig. 6,…the dummy wirings 304 for the second layer are disposed on
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`interlayer insulating film 220 at regular intervals in a region where the dummy
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`wirings 301, and the wirings 302, 303 for the first layer are not formed…" See Ex.
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`1001, col. 10, ll. 9-20. Thus, contrary to SEL's unsupported interpretation, the '978
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`specification states that support members 301, 302 and 303 are the first layer and
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`
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`4
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`
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`not the first and second conductive layers.
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`
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`Similarly, SEL quotes from the specification describing the embodiment
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`shown in Fig. 9 and asserts that the dummy wirings correspond to the first and
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`second conductive layers. See Mot. at 7. Yet, in the portion of the specification
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`SEL cites, the '978 specification plainly states that the starting film "forms the first
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`layer" and the film is patterned to form dummy wirings 501. Again, taken in proper
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`context, dummy wirings 501 form the first conductive layer. Notably, there are
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`multiple structures formed in the first layer, each of which is not continuous with
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`the other dummy wirings.
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`
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`SEL again mischaracterizes the embodiments in the specification. With
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`regarding to the embodiment shown in Fig. 8, SEL asserts that first wiring layer 401
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`is shown to be continuous. See Mot. at 7. SEL then concludes that this supports its
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`position that all of the dummy wirings are unitary because they are not
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`disconnected, i.e., continuous. Id. The specification, however, describes the
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`embodiment in Fig. 8 are being "rectangular wave shaped dummy wirings 401 for
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`the first layer." See Ex. 1001, col. 12, ll. 19-44 (emphasis added). Thus, this
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`embodiment discloses multiple structures forming a first conductive layer. While in
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`this example the dummy structures for the first layer are connected, those "wirings"
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`constitute multiple structures and thus do not support SEL's proposed amendment.3
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`3 For the same reasons, SEL's other citations do not support its proposed
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`amendment. See Mot. at 8. Each of the cited examples disclose multiple,
`5
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`
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`Finally, SEL asserts that the recitation of "unitary" conductive layers is
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`significant because only unitary conductive layers can block the entry of moisture
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`into the interior display area. See Mot. at 8. SEL's assertion, however, is
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`contradicted by the many examples in the '978 specification and the fact that the
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`'978 patent does not describe that the first and second conductive layer must be
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`unitary in order to perform the function of preventing the entry of moisture into the
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`interior of the display area.
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`
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`One of ordinary skill in the art would understand the meaning of "layer" to
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`encompass a single unitary structure as well as a plurality of such structures,
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`particularly in light of the '978 specification. See Ex. 1012, Hatalis Dep. at 138:12-
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`143:25. This is because "layer" can be used to refer to an initially deposited film of
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`material as well as a collection of structures that are patterned from that film (e.g.,
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`wiring lines). Id. One of ordinary skill in the art understands that these patterned
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`structures are still part of the same "layer." See Ex. 1013, Hatalis Decl. at ¶ 50. For
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`example, if a layer of aluminum is deposited and then patterned into discrete
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`structures (e.g. wiring lines), one of ordinary skill would still collectively refer to
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`these discrete structures as the "aluminum layer." Id. In other words, the aluminum
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`"layer" does not cease to exist simply because it is patterned into discrete structures.
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`Thus, one of ordinary skill in the art would understand the term "layer" to have a
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`broader meaning than "a continuous, unitary structure" as proposed by SEL.
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`disconnected wirings forming a first or second conductive layer.
`6
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`Because there is no support for SEL's proposed amendments, SEL's motion
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`should be denied on this basis.
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`III. SEL's Proposed Amendment Does Not Obviate a Ground of
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`Unpatentability
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`
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`A. The Proposed Amendment Does Not Distinguish, or Overcome,
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`The Prior Art
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`
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`1. Sono discloses the claimed first and second unitary
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`conductive layers
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`
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`SEL's proposed amendment fails to address the Decision's grounds of
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`unpatentability in view of Sono. In particular, SEL does not demonstrate how the
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`proposed "unitary" amendment overcomes the grounds for unpatentability set forth
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`in the Petition and the Decision. Instead, SEL merely reiterates its pre-existing
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`arguments against Sono, which have been twice rejected by the Board. In its
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`Preliminary Response and Request for Rehearing, SEL argued that Sono fails to
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`disclose the internal structures of the dummy circuits 74 and 75, including any
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`unitary conductive layers. See Prel. Resp. at 2-30; Req. for Rehearing at 8-9. In its
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`Motion, SEL again argues that Sono fails to disclose any internal structure for the
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`dummy circuits 74 and 75, "unitary" or otherwise. See Mot. at 9-10.
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`
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`As described in Petitioner's Petition and Reply, Sono discloses the internal
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`structure of the dummy circuits or scanning circuits, including the claimed first and
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`second conductive layers. See Pet. 19-21 and 28-30; Reply at 4-7. The proposed
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`amendment does not alter this because Sono's teachings are not limited to non-
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`"unitary" structures. Sono teaches making the peripheral circuits (i.e., scanning,
`7
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`
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`driving and dummy circuits 72-75) the same to achieve a uniform substrate-to-
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`substrate gap claimed in the '978 patent. See Ex. 1013, Hatalis Decl., ¶¶ 35-41.
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`
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`The Sono patent teaches how to create a uniform cell gap and avoid
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`unevenness in both the seal area and around the display area by forming dummy
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`structures (“dummy pixels” or “dummy circuits”). See Ex. 1013, Hatalis Decl., ¶
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`35. Sono teaches the formation of these structures within a “dummy area” which
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`has a “step substantially the same as the step in the display area.” Id. Furthermore,
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`Sono teaches the formation of said dummy area without adding any complexities to
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`the manufacturing process. Id.; see also Ex. 1003, col. 3, ll. 14-17.
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`
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`Sono teaches that the dummy area can be formed by dummy pixels. See Ex.
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`1013, Hatalis Decl., ¶ 36. “More specifically, in said dummy area, there may be
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`formed dummy pixels of a same configuration, having same wirings, switching
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`elements, pixel electrodes etc. as in the display area.” Id.; see also Ex. 1003, col. 3,
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`ll. 18-27. As described in Sono’s patent, and as depicted schematically in Fig. 4, the
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`dummy pixels within the dummy area are formed the same as the pixels in the
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`display area. The advantages of Sono’s teachings are the formation of “same step”
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`which is “easy in manufacture, because the manufacturing process of the pixels can
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`be merely expanded and the additional steps are not required.” Id.
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`
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`Sono also teaches that “..said step may be formed by the circuit elements or
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`wiring provided in the peripheral area.” See Ex. 1013, Hatalis Decl., ¶ 37; see also
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`Ex. 1003, col. 3, ll. 28-31. For example, embodiment 5 of the Sono patent discloses
`
`
`
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`8
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`
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`a display with four circuit elements in the peripheral area, i.e. scanning circuits 82-
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`85 arranged along the four sides of the display area. Id. “In the present
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`embodiment, patterns 82-85 of a same step height are positioned on the four sides of
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`the display area 81, and are all utilized as peripheral scanning circuits. Also this
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`embodiment, like embodiment 4, can achieve a uniform liquid crystal cell gap and a
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`reduced chip size, because the liquid crystal sealing area 86 is formed on the
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`peripheral scanning circuits 82-85 of same step height.” See Ex. 1003, col. 6, ll. 53-
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`59. Figure 10 of Sono depicts the four scanning circuits 82-85 that are used to form
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`the same step. Id.
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`
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`The Sono patent also teaches that “dummy areas” may be formed with
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`“dummy circuits” in order to achieve a same step. See Ex. 1013, Hatalis Decl., ¶
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`38. Figure 7 of Sono depicts four circuit elements within the liquid crystal seal area
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`76, two of which are dummy circuits: “…a horizontal scanning circuit 72; a vertical
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`scanning circuit 73 having a same step as that of said horizontal scanning circuit 72;
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`a horizontal dummy circuit 74 having a same step as that of said horizontal scanning
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`circuit 72; a vertical dummy circuit 75 having a same step as that of said horizontal
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`scanning circuit 72…” Id.; see also Ex. 1003, col. 5, ll. 6-11.
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`
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`One skilled in the art would recognize that the dummy circuits 74 and 75 are
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`the same as the scanning circuits 72 and 73. See Ex. 1013, Hatalis Decl., ¶ 38. In
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`Figure 7, it can be seen that the area occupied by the dummy circuits 74, 75 is the
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`same as the area occupied by the scanning circuits 72, 73. Therefore all circuit
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`
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`9
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`
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`components (i.e., transistors and wirings) of the scanning circuits are also present in
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`the dummy circuits. Id. If any components (e.g., wirings) were missing from the
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`dummy circuits, then the area occupied by the dummy circuits would have been less
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`than that of the scanning circuits and uneven gaps across the substrate would result.
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`Id. Not only are the dummy circuits depicted as having the same area as the
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`scanning circuits, but Sono also discloses that “…excellent producibility is ensured
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`because the dummy circuits 74, 75 can be prepared in a same process as for the
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`peripheral scanning circuits 72, 73.” Id.; see also Ex. 1003, col. 6, ll. 34-37. Since
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`all circuits have the same size and are prepared in a same process, the dummy
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`circuits contain all the components (i.e., transistors and wirings) and thus are the
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`same as the scanning circuits. Id. This will ensure the “same step” and “excellent
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`producibility” advantages that Sono discloses. Id.
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`
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`As explained above, Sono discloses that when the dummy areas are formed
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`with dummy pixels, the dummy pixels are the same as the pixels in the display area,
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`which results in the formation of “same step” which is “easy in manufacture”
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`because it adds “no further complexities to the manufacturing process” and
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`“additional steps are not required.” See Ex. 1013, Hatalis Decl., ¶¶ 35-38; see also
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`Ex. 1003, col. 3, ll. 14-27. Likewise, one skilled in the art would recognize that
`
`when the dummy areas are formed with dummy circuits, based on Sono’s teachings,
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`the dummy circuits are the same as the scanning circuits in order to ensure the
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`“same step,” which is “easy in manufacture” because it adds “no further
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`
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`10
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`
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`complexities to the manufacturing process” and “additional steps are not required.”
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`Id. at ¶ 40.
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`
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`Furthermore, comparing Figures 7 and 10 of Sono a person skilled in the art
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`would recognize that circuit elements within the seal region can be used either as
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`scanning circuits or as dummy circuits. See Ex. 1013, Hatalis Decl., ¶ 41. When all
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`circuit elements are used as scanning circuits, such as those depicted in Figure 10 of
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`Sono, the ones on opposing sides of the display area 81 are the same in order to
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`ensure both the same functionality as well as the same step. Id. A person skilled in
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`the art would likewise recognize that the dummy circuits 74, 75 will be formed the
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`same as the scanning circuits 72, 73 that are in opposing sides of the pixel area 71.
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`Id. As stated above, the Sono patent teaches that the dummy circuits are the same
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`as the scanning circuits by showing all circuits to have the same size in Figure 7 and
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`disclosing that the same process is used for their fabrication. Id.
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`
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`A person of ordinary skill in the art thus would understand that the peripheral
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`dummy circuit area includes long conductive layer runs along dummy shift register
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`circuits, based on Sono's teaching that the dummy circuits mirror the peripheral shift
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`register circuits 72 and 73. See Ex. 1005, ¶¶ 25, 38, 39; see also Ex. 1012, Hatalis
`
`Dep. at 16:18-18:17. SEL's expert agreed that it was known to use shift registers as
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`drive circuits. See Ex. 1014, Stewart Dep. at 209:19-210:4. And, that such shift
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`registers have long conductive layer runs including power lines, ground lines and
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`clock lines. See Ex. 1012, Hatalis Dep. at 60:18-65:24 and 130:4-21; Ex. 1014,
`
`
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`11
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`
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`Stewart Dep. at 98:5-100:20. Mr. Stewart illustrated the long conductive runs
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`contained in shift registers and agreed that these wirings span the length of the
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`display. See Ex. 2011 at p.44, ¶ 100 (showing long conductive runs contained
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`within the exemplary shift registers); Ex. 1014 at 98:5-100:20. These long
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`conductive layer runs serve as the claimed first conductive layer (e.g., power line or
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`Clock 1 line) and the second conductive layer (e.g., ground line or Clock 2 line).
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`See Ex. 1012, Hatalis Dep. at 60:18-65:24 and 130:4-21. Finally, SEL's expert, Mr.
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`Stewart admitted that power lines, ground lines and clock lines, such as those
`
`disclosed in Sono, are unitary structures. See Ex. 1014 at 143:11-144:9.
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`
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`Because Sono's teaching relates generally to using symmetric structures to
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`achieve height symmetry under the seal regardless of the particular structures
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`being used, Sono's teachings to one of ordinary skill does not depend on
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`whether or not a layer is considered to be "unitary." As a result, SEL's proposed
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`amendment fails to address the Decision's grounds for unpatentability with
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`respect to Sono and should therefore be denied.
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`
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`In its Motion, SEL additionally argues that Sono allegedly lacks additional
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`claim elements relating to the layer from which the unitary conductive layers are
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`formed, their relative length in specified directions, and their electrical isolation.
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`Because these features are not germaine to whether their proposed amendment
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`addresses a ground of unpatentability, SEL's reliance on them in its Motion is
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`misplaced.
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`12
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`
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`2. Watanabe discloses the claimed first and second unitary
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`conductive layers
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`Watanabe renders obvious the proposed limitation of substitute claims 51 and
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`52, i.e., "wherein a length of the first unitary conductive layer along the first
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`direction and a length of the second unitary conductive layer along the first
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`direction are longer than a pitch of adjacent ones of the plurality of second
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`conductive lines." The amended claims remain obvious in view of Watanabe
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`because SEL's amendment does not address the Board's findings as to Watanabe's
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`gap adjusting layers. The Board's Decision did not depend on a finding that
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`Watanabe's conductive layers (i.e. gap adjusting structures) were non-unitary, so a
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`requirement that they be unitary is not relevant. To the contrary, the Board cited to
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`Watanabe's disclosure of long, continuous conductive layers, which would be
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`"unitary" under SEL's definition.
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`
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`Watanabe discloses forming long metal gap adjusting layers 25 or 27 along
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`and between the conducting lines 17 and 18. See Decision at 22; Ex. 1012 at 167:9-
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`16. Watanabe teaches that "the substrate gap adjusting layers 25 and 27 may be
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`formed in long patterns along with the lead portions 13, 17, and 18 (without
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`contacting them.)" See Ex. 1004, col. 13, ll.45-49; Fig. 1. The Board found that:
`
`"[S]uch long gap patterns reasonably suggest lengths greater than the pitch
`between at least lines 17 in Figure 5, because Watanabe describes the patterns
`as "long patterns along the lead portions""
`
`See Decision at 22. In other words, as shown in Figure 1, Watanabe's gap adjusting
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`layers 25 and 27 can be long rectangles instead of the small squares shown in Figure
`13
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`
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`5. See Ex. 1012 at 167:17-168:10 and 171:3-21. SEL's Motion fails to address this
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`aspect of Watanabe; instead, it focuses on whether the individual gap adjusting
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`substrate layers can be collectively considered a layer. For example, whether three
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`horizontally aligned gap adjusting layers 25 in Figure 5 could be combined into one
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`long rectangular gap adjusting layer. Thus, the addition of "unitary" to "conductive
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`layer" has no bearing on the Board's grounds for obviousness because the Board
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`relied on Watanabe's teaching of forming long metal gap adjusting layers.
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`Accordingly, SEL's proposed claim amendments should be denied.
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`
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`
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`B. The Addition of the Word "Unitary" To The Claims Was
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`Already Considered And Rejected By the Board
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`SEL's proposed amendment requires that the first and second conductive
`
`layers each be a "unitary layer." See Mot. to Amend at 4-5. In doing so, SEL
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`represents that the scope of the amended claims 51 and 52 as understood by one of
`
`ordinary skill in the art is "substantially identical" to that of the original claims 7
`
`and 17 and requests that the Board reach a finding to that effect pursuant to 35
`
`U.S.C. § 252. Indeed, SEL's Response states that "layer" means "a continuous,
`
`unitary structure." See Response at 12. Thus, SEL concedes that its amendment
`
`does not change the scope of the term "layer" and as such it cannot present a new
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`argument to overcome a ground of unpatentability. SEL's proposed amendment
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`merely reflects its pre-existing claim interpretation that has already been presented
`
`to, and rejected by, the Board. See Decision on Rehearing at 8-9; Decision at 22-23.
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`By adding a limitation to the claims that was already considered by the
`14
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`
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`Board, and failing to show how it overcomes the prior art, the proposed amendment
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`does not address the Board's grounds for finding this claim limitation obvious, and
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`its motion therefore should be denied.
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`IV. Conclusion
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`For the foregoing reasons, SEL's Motion should be denied.
`
`Dated: September 23, 2013
`
`
`
`Respectfully submitted,
`
`
`/Scott A. McKeown/
`Scott A. McKeown (Reg. No. 42,866)
`Lead Counsel for Petitioner
`Oblon, Spivak, McClelland, Maier &
`Neustadt, LLP
`1940 Duke Street
`Alexandria, VA 22314
`Tel: (703) 412-6297
`Fax: (703) 413-2220
`SMcKeown@oblon.com
`
`Gregory S. Cordrey (Reg. No. 190,144)
`Back-up Counsel for Petitioner
`Jeffer Mangels Butler & Mitchell LLP
`3 Park Plaza, Suite 1100
`Irvine, CA 92614
`Tel: (949) 623-7236
`Fax: (888) 712-3345
`gxc@jmbm.com
`
`Stanley M. Gibson
`Admitted pro hac vice
`Jeffer Mangels Butler & Mitchell LLP
`3 Park Plaza, Suite 1100
`Irvine, CA 92614
`Tel: (310) 201-3548
`Fax: (310) 712-8548
`smg@jmbm.com
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`15
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`CERTIFICATE OF SERVICE
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`I hereby certify that PETITIONER’S OPPOSITION TO MOTION TO
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`AMEND in connection with Inter Partes Review Case IPR2013-00038 was
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`served on this 23rd day of September 2013 by electronic mail to Robinson
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`Intellectual Property Law Office, P.C., Counsel for Patent Owner, at
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`[erobinson@riplo.com], having a postal address at:
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`Robinson Intellectual Property Law Office, P.C
`3975 Fair Ridge Drive
`Suite 20 North
`Fairfax, VA 22030
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`/Scott A. McKeown/
`Scott A. McKeown (Reg. No. 42,866)
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`16
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