SEL EXHIBIT NO. 2025
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`INNOLUX CORP. V. PATENT OF SEMICONDUCTOR ENERGY
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`LABORATORY CO., LTD.
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`IPR2013—OOO66
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`INNOLUX CORP. V. PATENT OF SEMICONDUCTOR ENERGY
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`LABORATORY CO., LTD.
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`IPR2013—OOO66
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`INNOLUX CORPORATION
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`Petitioner
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`V.
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`PATENT OF SEMICONDUCTOR ENERGY LABORATORY CO., LTD.
`Patent Owner
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`CASE IPR2013—00066
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`PATENT 7,876,413
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`SUPPLEMENTAL DECLARATION OF DR. MICHAEL J. ESCUTI
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`1, Michael J. Escuti, do hereby declare and state that all statements made herein are
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`based on my own personal knowledge and that all statements made on information
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`and belief are believed to be true. I further do hereby declare and state that these
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`statements are made with the knowledge that willful false statements are
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`punishable by fine or imprisonment or both under 18 U.S.C. § 1001.
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`Dated: ngefyflg
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`. E 2 W.
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`Michael J. Escuti
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`I.
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`1.
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`INTRODUCTION
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`I have been retained by Semiconductor Energy Laboratory Co., Ltd. in this
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`proceeding as an expert in the relevant art.
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`2.
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`On July 24, 2013, I provided a declaration (“Initial Declaration”) (EX. 2012)
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`regarding US. Patent No. 7,876,413 (the “’413 patent”) (Ex. 1001).
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`In my Initial
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`Declaration, paragraphs 5, 9, 11, and 12,
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`I demonstrate that I have detailed
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`knowledge of
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`thin-film-transistor
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`(“TFT”)/liquid crystal display
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`(“LCD”)
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`technology, design, and fabrication, which is the technology relevant to the ’413
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`patent. Additionally, paragraph 49 demonstrates my detailed knowledge of
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`sealants used in LCDs, which is a key element of the ”413 claims.
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`3.
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`During my deposition, I testified that I had detailed knowledge of LCD
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`devices. Exhibit 2026, Escuti ’204 Dep., at 90:3—9.
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`1 demonstrated my detailed
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`knowledge of sealants.
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`Id. at 144:17-22.
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`I also testified that I had detailed
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`knowledge of TFT/LCD technology, design, and fabrication.
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`Exhibit 2027,
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`Escuti ’413 Dep., at 1424-17, 1625—11, 24:15-24, 39:1-11.
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`4.
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`Below I provide additional evidence to demonstrate my qualifications as an
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`expert in this proceeding.
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`A.
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`Supplemental Background And Qualifications
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`5.
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`The background and qualifications set forth in my Initial Declaration are
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`incorporated by reference herein.
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`6.
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`In my Initial Declaration I cite to an invited book chapter that I co-authored
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`and the courses I have taught at North Carolina State University. As further
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`support for my qualifications, I include Exhibit 2028, a copy of the Invited Book
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`Chapter: G.P. Crawford and M.J. Escuti, Liquid Crystal Display Technology, in
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`Encyclopedia of Imaging Science and Technology, ed. J.P. Hornak, (John Wiley &
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`Sons,
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`Inc., 2002), Exhibit 2029, a copy of Syllabus: 492/592—003 — Soft
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`Electronics: Organic Devices & Liquid Crystal Displays, Exhibit 2030, a copy of
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`Lab Module 4 of 4: OTFT: Fabrication and Characterization of an Organic Thin
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`Film Transistor, Exhibit 2031, a copy of a conference paper on another lab-based
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`course I teach, M.C. Ozturk and M.J. Escuti, A New Introductory Course 0n
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`Signals, Circuits and Systems, American Society for Engineering Education
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`Annual Conference, vol. 2532, art. no. 2473, 2006, Exhibit 2032, a copy of the
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`Syllabus for ECE 303- Electromagnetic Fields, and Exhibit 2033, a copy of the
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`Syllabus for E 304- Intro to Nano Science & Technology.
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`7.
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`Exhibits 2028—2033 demonstrate that I teach and study subjects such as
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`polycrystalline and amorphous silicon TFTS, their structures, materials, peripheral
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`driver circuits, and their use. Exhibit 2028 demonstrates that I have studied the
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`same type of TFTs disclosed in the specification of the ’413 patent since before
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`2002, including the TFTs and peripheral driving circuits formed directly on a glass
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`substrate.
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`See, e. g., Exhibit 2028, at 957—59. Exhibit 2028 cites for support
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`
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`numerous references addressing active—matrix LCD technology from prior to 1997,
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`which I reviewed in connection with this publication. See, e.g., Exhibit 2028, at
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`968—69 (citing S. Kobayashi, H. Hori, and Y. Tanaka, Active Matrix Liquid
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`Crystals Displays, Chapter 10,
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`in P. Collings and J. Patel, eds., Handbook of
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`Liquid Crystal Research, Oxford University Press, New York (1997), T. Brody, J.
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`Asars, and G. Dixon, A 6 X 6 inch 20 lines-per—inch liquid-crystal display
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`panel, IEEE Transactions on Electron Devices, vol. 20, pp. 995-1001 (1973), P. G.
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`Le Comber, W. E. Spear, and A. Ghaith, Amorphous—siliconfield—eflect device and
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`possible application, Electronics Letters, vol. 15, pp. 179-181 (1979), D. E.
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`Mentley and J. A. Castellano, Liquid Crystal Display Manufacturing, Stanford
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`Resources,
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`Inc., San Jose, 1994 and J. A. Castellano, Handbook of Display
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`Technology, Academic Press Inc., San Diego, 1992).
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`8.
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`Exhibits 2028—2033 further demonstrate my experience in teaching about
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`TFT/LCD technology, design, and fabrication. Exhibit 2029 is the syllabus for a
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`course I teach and developed from scratch at NCSU starting in 2006, with an
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`emphasis on inorganic TFT technology used for active-matrix addressing in LCDs
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`(and Organic Light—Emitting Diode displays), as well as a focus on organic TFT
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`technology. The last page of the Syllabus lists the topics I cover in this course,
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`which include active-matrix addressing, TFT operation, and fabrication.
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`I use
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`selections from two textbooks for teaching the material on TFTs used for active-
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`
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`matrix LCDs: (1) Ernst Lueder, Liquid crystal displays: addressing schemes &
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`electro-optical eflects, New York:Wiley, 2001 and (2) Willem den Boer, Active
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`Matrix Liquid Crystal Displays: Fundamentals & Applications, Elsevier2Newnes,
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`2005.
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`In Exhibit 2030, a laboratory manual from this course, Figure 1 shows a
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`comparison of polycrystalline and amorphous silicon to organic TFTs. Note that
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`this Figure and discussion include data from 1997. Exhibit 2031, for example,
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`refers to signals and circuits,
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`including the issue of resistance.
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`I also teach
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`Electromagnetics course ECE 303, which includes concepts of capacitance,
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`resistance, transmission lines, and electronic materials. Exhibit 2032, Syllabus for
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`ECE 303- Electromagnetic Fields. Another relevant new course that I am teaching
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`is E 304, Introduction to Nano Science and Technology, wherein I teach about
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`nanoelectronic devices,
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`including modern field-effect—transistors
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`(FETs) and
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`advanced semiconductor materials. Exhibit 2033, Syllabus for E 304— Intro to
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`Nano Science & Technology.
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`9.
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`In 2001, I collaborated with my PhD advisor to create a ~10—hr Short Course
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`that became a multi—module Interactive Information Display Tutorial, wherein I
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`developed several electronic teaching modules,
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`including but not
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`limited to,
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`Module 36 "Active Matrix Addressing" and Module 40 "Indium Tin Oxide (ITO)
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`In203/SnO2", copies of which are in Exhibit 2037. The US. Display Consortium
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`funded the project for my advisor at Brown University, and published the
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`Interactive Information Display Tutorial as a CD-ROM. As part of this effort, I
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`presented an expanded version of this Short Course to 3M main research personnel
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`in early 2002, as mentioned in my deposition (Exhibit 2027, Escuti ’413 Dep., at
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`13:10-14).
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`I continue to use portions of this Short Course in my class on LCDs
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`and Organic Electronics. Note that the content of the Tutorial covers amorphous
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`and polycrystalline silicon TFTs and ITO in LCDs, with an emphasis on structures,
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`tradeoffs, and electrical operational principles. The Short Course/Tutorial further
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`demonstrates my study and teaching of active-matrix and TFT technology. The
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`Short Course/Tutorial, along with the parallel writing of the invited book chapter
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`Exhibit 2028, was the occasion for which I first deeply studied the relevant prior
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`art including before 1997.
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`10.
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`I have further relevant experience in active—matrix LCD design, fabrication,
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`and prototyping in a past project within the company that
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`I co-founded
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`(ImagineOptix), and in which I currently serve as Chief Science Officer. I was the
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`lead engineer/manager on a 2-yr project to develop a polysilicon TFT active-matrix
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`microdisplay suitable for implementing a switchable polarization grating as a
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`diffractive light valve within a transmissive LCD projector. This device was
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`prototyped, but not published because all aspects are proprietary information of
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`ImagineOptix. Exhibit 2027, Escuti ’413 Dep;, at 33:4—13, 54:22-55 :20.
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`11.
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`In the other published paper discussed during the deposition (Ex. 2038, Ex.
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`1008 for No. IPR2013-00068, “Late-News Paper: Polarization Independent Liquid
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`Crystal Microdisplays,” Komanduri et al), we report on a prototype reflective
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`active-matrix LCD (i.e., a microdisplay) employing a customized 256x256 active-
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`matrix on a silicon backplane, with top-surface aluminum pixel electrodes,
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`aluminum data lines, polysilicon scan lines, on—chip peripheral logic circuitry, all
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`fabricated over a silicon wafer. In addition, the LCD used a glass counter substrate
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`with an indium—tin—oxide (ITO) electrode, sealant with embedded spacers, and
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`metallized contact terminals on both substrates. While the transistor structures
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`within each pixel and within the peripheral driver circuits were necessarily
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`different than would be found in, e.g., a transmissive polysilicon TFT backplane,
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`the active—matrix principles are nearly identical.
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`Furthermore,
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`the backplane
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`included a planarization and protection layer of silicon oxide, as well as a
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`polysilicon and multiple aluminum layers, of which all are deposited and patterned
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`in a manner similar to the ’413 patent.
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`12. An active-matrix LCD is by definition a device that employs at least one
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`transistor within each pixel for controlling its voltage. The silicon backplane in my
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`reference in Exhibit 2038 includes a transistor at each pixel - it is one type of
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`analog Liquid Crystal On Silicon (“LCOS”) backplane, developed mainly since the
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`early 19903. These were and are used in “projectors, rear-projection televisions,
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`view—finders, near-to-eye displays, and spatial—light—modulators.
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`In this paper, we
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`report on the result when we customized the LCOS and used it to prototype a new
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`kind of LCD.
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`13.
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`In a current effort at ImagineOptix, we are engaged in a long-term project to
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`develop a novel transmissive TFT active-matrix backplane, based on a non—silicon
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`inorganic semiconductor. Exhibit 2027, Escuti ’413 Dep., at 33:4—13; Exhibit
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`2026, Escuti ’204 Dep., at 58:7-13. This involves several other industrial partners
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`and pending proposals to federal fianding agencies, and is unpublished.
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`I cannot
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`provide any further details or status because the information is proprietary.
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`14.
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`I am also familiar with the state of the art in 1997.
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`15.
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`In 1997, I received my BS degree in Electrical and Computer Engineering
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`from Drexel University and began my graduate studies in electrical engineering at
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`Brown University. Both when I was an undergraduate and graduate student, I took
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`courses on LCD, very large scale integration (“VLSI”), and semiconductor
`fabrication and design. More specifically, as an undergraduate, I took multiple
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`courses on VLSI design and fabrication, which included TFT topics, and took a
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`course on electromagnetics that included basic LCD principles.
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`In 1999, as a
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`graduate student, I also completed an advanced course on LCDs, which had a
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`particular emphasis on active—matrix addressing and TFT structures used in LCDs.
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`The textbooks I used for this course were: Pochi Yeh and Claire Gu, Optics 0f
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`
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`Liquid Crystal Displays, Wiley & Sons (1999)
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`including Ch. 6 on “Matrix
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`Addressing” and Liquid Crystals: Applications and Uses (Vol. I), edited by B.
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`Bahadur, World Scientific (1995) including Ch. 15 on “Active Matrix LC Display”
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`by RC. Luo.
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`16. During my graduate (MS and PhD) studies at Brown University (1997-
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`2002), I reviewed many patents and publications related to TFT/LCD technology
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`frOm 1997 and before. For example:
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`T.P. Brody, Birth of the Active Matrix, Information Display 13, 28-32 (1997).
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`K. Ohmuro, S. Kataoka, T. Sasaki and Y. Koike, Development ofSuper-High-
`Image—Quality Vertical-Alignment—Mode LCD, Proc. SID 28, 845—848 (1997).
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`A. Chiang, Polysilicon thin film transistor technologyfor AM—LCDs, Proc SPIE
`1815, p. 128,1992.
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`F .C. Luo, Active matrix liquid crystal displays an overview, Proc SPIE 1815
`Display Technologies 50 1992.
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`Yoneda, K. ; Segawa, Y.; Yamada, T.; Kihara, K. , A Smart Arrangement of TFTs
`in Low—Temperature Poly-Si Circuitryfor Achieving Higher Efi’ective Yield in
`Production, CONFERENCE RECORD OF INTERNATIONAL DISPLAY
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`RESEARCH CONFERENCE; L— 1 -L—4 (1997).
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`17.
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`These printed publications were published on or before 1997.
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`18. As discussed in my Initial Declaration, I have been an engineer in the field
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`of TFT/LCD technology since graduate school, and I have prepared and taught
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`several courses on this topic since 2001 and continuing to date. Through this work
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`and preparation, I gained familiarity with the state of the art in 1997.
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`19.
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`I have also attended or reviewed several Seminar Lectures on active-matrix
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`LCDs offered by the Society for Information Display from the years of 1996 to
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`1999. These Seminar Lectures included ones described in the following papers:
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`Exhibit 2034, Walter F. Goede, Seminar M-l: Status of Electronic Displays,
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`Society For Information Display, 1996; Exhibit 2035, Colin Prince, Seminar M-3:
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`Active—Matrix LCDs, Society For Information Display, 1997; Exhibit 2036,
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`Terence J. Nelson, Seminar M-l: Electronic Information Display Perspective,
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`Society For Information Display, 1998. This was an essential part of the writing of
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`my 2002 journal paper, and the subsequent preparation of my courses on LCDS.
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`Furthermore,
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`in a prior case before the International Trade Commission, I also
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`examined these 1996—1999 Seminar Lectures on active—matrix LCDs, expressly to
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`review the state of the art around 1997.
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`20.
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`I also reviewed prior art
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`in determining how the phrase “through an
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`opening” is used in the prior art. Some of the references that I reviewed are cited
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`in paragraph 58 of my Initial Declaration.
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