IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Petition for Inter Partes Review
`
`Attorney Docket No.:
`Customer No.:
`Real Party in Interest:
`
`42299.43
`27683
`Xilinx, Inc.
`
`§ §
`
`§
`
`§
`
`§ §
`
`§
`§
`§
`
`In re patent of Kikinis
`
`US. Patent No. 5,779,334
`
`Issued: July 14, 1998
`
`Title: ENHANCED VIDEO
`PROJECTION
`SYSTEM
`
`Declaration of A. Bruce Buckman1 Ph.D.
`
`Under 37 C.F.R. § 1.68
`
`I, Dr. A. Bruce Buckman, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Xilinx in the matter of
`
`the Inter Partes Review of US. Patent No 5,779,334 (“the ’334 Patent”) to Kikinis.
`
`2.
`
`I am being compensated for my work in this matter. My
`
`compensation in no way depends upon the outcome of this proceeding.
`
`3.
`
`In the preparation of this declaration, I have studied:
`
`(1)
`
`The ’334 Patent, XLNX—lOOl;
`
`(2) US. Patent No. 5,264,951 (“Takanashi”), XLNX-lOOZ;
`
`(4) US. Patent No. 5,287,131 (“Lee”), XLNX—1003; and
`
`(5) US. Patent No. 5,777,796 (“Burstyn”), XLNX-1004.
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`(1)
`
`The documents listed above,
`
`_1_
`
`XLNX—lOOS
`
`
`
`Petition for Inter Partes Review
`
`Attorney Docket No.:
`Customer No.:
`Real Party in Interest:
`
`42299.43
`27683
`Xilinx, Inc.
`
`§ §
`
`§
`
`§
`
`§ §
`
`§
`§
`§
`
`In re patent of Kikinis
`
`US. Patent No. 5,779,334
`
`Issued: July 14, 1998
`
`Title: ENHANCED VIDEO
`PROJECTION
`SYSTEM
`
`Declaration of A. Bruce Buckman1 Ph.D.
`
`Under 37 C.F.R. § 1.68
`
`I, Dr. A. Bruce Buckman, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Xilinx in the matter of
`
`the Inter Partes Review of US. Patent No 5,779,334 (“the ’334 Patent”) to Kikinis.
`
`2.
`
`I am being compensated for my work in this matter. My
`
`compensation in no way depends upon the outcome of this proceeding.
`
`3.
`
`In the preparation of this declaration, I have studied:
`
`(1)
`
`The ’334 Patent, XLNX—lOOl;
`
`(2) US. Patent No. 5,264,951 (“Takanashi”), XLNX-lOOZ;
`
`(4) US. Patent No. 5,287,131 (“Lee”), XLNX—1003; and
`
`(5) US. Patent No. 5,777,796 (“Burstyn”), XLNX-1004.
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`(1)
`
`The documents listed above,
`
`_1_
`
`XLNX—lOOS
`
`
`
`(2)
`
`The relevant legal standards, including the standard for obviousness
`
`provided in KSR International Co. v. Teleflex, Inc, 550 US. 398 (2007), and
`
`any additional authoritative documents as cited in the body of this
`
`declaration, and
`
`(3) My knowledge and experience based upon my work in this area as
`
`described below.
`
`Qualifications and Professional Experience
`
`5.
`
`My qualifications are set forth in my curriculum vitae, a copy of
`
`which is provided as Exhibit XLNX—1006. As set forth in my curriculum vitae, l
`
`have over 44 years of experience in Electrical Engineering, including optical
`
`engineering.
`
`6.
`
`My 44 years of experience in optical engineering includes over 15
`
`years of teaching a graduate course in fiber and guided-wave optics at the
`
`University of Texas at Austin, where I held the ranks of associate professor and
`
`professor from 1974 until my retirement in 2009. Course topics included many of
`
`the components that appear in the ’334 Patent, such as filters, prisms and lenses for
`
`redirecting light rays, and dichroic elements for combining or splitting light of
`
`different wavelengths or colors.
`
`I authored a textbook, Guided— Wave Photonics as
`
`an aid in teaching the course.
`
`I concurrently conducted research in optical systems
`
`that resulted in dozens of peer—reviewed publications, including one on a 6-Degree
`
`—2—
`
`XLNX-l 005
`
`
`
`
`of freedom non-contact optical position sensor that won the Best Paper Award at
`
`an international conference in 1994. I am a coinventor on a US. Patent for that
`
`device, and an inventor on three other patents covering various optical systems.
`
`I
`
`have consulted for several companies on optical technology.
`
`I have also served as
`
`an expert witness in several litigations involving optical systems by preparing
`
`declarations and expert reports as well as providing deposition, Markman hearing,
`
`and trial testimony.
`
`7.
`
`I am familiar with the knowledge and capabilities one of ordinary skill
`
`in the optical design arts in the period around 1996. Specifically, my work (I) with
`
`students, undergraduates as well as masters and PhD. candidates, (2) with
`
`colleagues in academia, and (3) with engineers practicing in industry allowed me
`
`to become personally familiar with the level of skill of individuals and the general
`
`state of the art. Unless otherwise statedpmltestimonj below refers to the
`
`knowledge of one of ordinary skill in the optical design arts during the 1995-1997
`
`time period, including the priority date of the ’334 Patent.
`
`8.
`
`In my opinion, the level of ordinary skill in the art for the ’334 Patent
`
`is a bachelor’s degree in electrical engineering or physics combined with: i)
`
`coursework including at least two semesters with a specialization in optics and/or
`
`optical systems, and ii) two years of experience designing video based optical
`
`systems, including designing optical systems with off the shelfparts.
`
`~3~
`
`
`
`
`XI.NX—l 005
`
`
`
`
`
`Relevant Legal Standards
`
`9.
`
`I have been asked to provide my opinions regarding whether the
`
`claims ofthe ’334 Patent are anticipated or would have been obvious to a person
`
`having ordinary skill in the art at the time ofthe alleged invention, in light of the
`
`prior art.
`
`It is my understanding that, to anticipate a claim under 35 U.S.C. § 102,
`
`a reference must teach every element of the claim. Further, it is my understanding
`
`that a claimed invention is unpatentable under 35 U.S.C. § 103 ifthe differences
`
`between the invention and the prior art are such that the subject matter as a whole
`
`would have been obvious at the time the invention was made to a person having
`
`ordinary skill in the art to which the subject matter pertains.
`
`I also understand that
`
`the obviousness analysis takes into account factual inquiries including the level of
`
`ordinary skill in the art, the scope and content of the prior art, and the differences
`
`between the prior art and the claimed subject matter.
`
`10.
`
`It is my understanding that the Supreme Court has recognized several
`
`rationales for combining references or modifying a reference to show obviousness
`
`of claimed subject matter. Some ofthese rationales include the following:
`
`combining prior art elements according to known methods to yield predictable
`
`results; simple substitution of one known element for another to obtain predictable
`
`results; a predictable use of prior art elements according to their established
`
`functions; applying a known technique to a known device (method, or product)
`
`—4—
`
`XLNX-1005
`
`
`
`
`ready for improvement to yield predictable results; choosing from a finite number
`
`ofidentified, predictable solutions, with a reasonable expectation of success; and
`
`some teaching, suggestion, or motivation in the prior art that would have led one of
`
`ordinary skill to modify the prior art reference or to combine prior art reference
`
`teachings to arrive at the claimed invention. My analysis of the ’334 Patent is set
`
`forth below.
`
`Background Of ’334 Patent
`
`11.
`
`The ’334 Patent relates to an “Enhanced Video Projection System.”
`
`(’334 Patent, Title). Specifically, the ’334 Patent teaches a system that combines
`
`separate light beams into a single projectable beam. (”334 Patent, Abstract). To do
`
`this, the ’334 Patent uses separate light sources to create separate light beams,
`
`which then pass through color filters and Liquid Crystal Display (“LCD”) arrays
`
`before they are combined into the projectable light beam. (Id; see also ’334 Patent
`
`at 3:10—30)
`
`12.
`
`Claim 1 in relation to Fig.
`
`1 provides a basic overview ofthe
`
`teachings ofthe ’334 Patent.
`
`1. A video projector system comprising:
`a source projecting parallel beams oflight of different colors;
`a light-shutter matrix system comprising a number of equivalent
`switching matrices equal to the number of beams and placed
`one each in the beam paths;
`a video controller adapted for controlling the light-shutter matrix
`system; and
`an optical combination system adapted for combining the separate
`
`—5—
`
`XLNX— l 005
`
`
`
`
`
`beams after the light—shutter matrix system into a single
`composite beam for projection on a surface to provide a video
`display.
`
`13. With respect to Fig. 1 below, the ’334 Patent describes a source
`
`projecting three parallel light beams of different colors: (“The lamps are provided
`
`in a separate sub-unit 131”, ’334 Patent, 3210-1 1). These three parallel beams
`
`enter a light shutter matrix system comprising “three monochrome LCD arrays
`
`117, 118, and 119.” (’334 Patent, 3:21-27). “Controller 122 controls the three
`
`monochrome matrices 117, 118, and 119.” (’334 Patent, 3:39-40). Lastly, “after
`
`passing through the active regions 117—1 19, the separate beams get combined into
`
`a single beam by mirror and prism system 1 1 1, then the combined beam is focused
`
`and projected onto a surface 101 .” (’334 Patent, 3:27—30). The ’334 specification
`
`mentions only LCD array spatial light modulators that operate in transmission.
`
`However, those of ordinary skill in the art were well aware of LCD array spatial
`
`light modulators that operated in reflection [US Patent No. 5,264,951 (XLNX-
`
`1002) at 1:18—24.] Those of ordinary skill would have known how to redesign an
`
`optical system to accommodate the choice of either transmissive or reflective light
`
`modulators and would have further recognized that the choice between
`
`transmissive and reflective LCD array light modulators was simply a design choice
`
`based on optical power output, cost, space available, and differences in the number
`
`of optical components
`
`
`
`
`
`
`
`required.
`
`
` a light—shutter matrix system comprising a number of
`equivalent switching matrices equal to the number of
`
`
`beams and placed one each in the beam paths
`
`(elements 117, 118, and 119)
`
` a source
`
`
`projecting
`parallel
`beams of
`
`
`
`light of
`different
`
`
`colors
`
`(element
`131)
`
`
`HID ('ummllu
`
` H I) I 'nmmllvr
`1m lllllh lamps.
`........
`um. Lnr \ MW
`
`I:\ IN’ m
`1
`(‘mahilih
`
`
`an optical combination
`
`system adapted for combining
`
`'
`the separate beams after the
`light-shutter matrix system
`
`
`
`a video controller adapted for
`into a single composite beam
`
`
`controlling the light—shutter
`for projection on a surface to
`
`
`
`matrix system (element 122)
`provide a video display
`
`
`(element 111)
`
`
`>
`
`14.
`
`The application leading to the ’334 Patent was filed in January 1997,
`
`and claimed priority as a continuation—in—part to an application filed in July 1996.
`
`The Examiner issued a first action Notice of Allowance in February 1998. No
`
`reasons for allowance were stated. The ’334 Patent issued on July 14, 1998.
`
`Summary of Opinions
`
`15.
`
`In my opinion, the claims of the ’334 Patent would have been obvious
`
`~7~
`
`
`XLNX-lOOS
`
`
`
`to a person having skill in the art in July 1996.
`
`16.
`
`By mid—1996, engineers already knew how to create a light-combining
`
`Video projection system. The “Takanashi” reference, US. Patent No. 5,264,951
`
`(XLNX-1002), describes a system in which multiple light sources create light
`
`beams which pass through color filters and/or separators, and then LCD arrays
`
`before being combined into a single projectable beam.
`
`17.
`
`In Takanashi, a light source is used to create three beams of light,
`
`which pass through a color separator and a light-shutter matrix.
`
`18.
`
`One light-shutter matrix system of Takanashi is composed of
`
`switching matrices (liquid crystal elements ECBtr, ECBtg and ECBtb, polarizers
`
`PL2r, PL2g and PL2b, and transmissive spatial light modulator elements SLMtr,
`
`SLMtg and SLMtb), as shown in Fig. 17. One ofordinary skill in the art would
`
`have recognized that the ECBtr, PLZr, and SLMtg elements combined are a
`
`switching matrix used to process only red beams. One of ordinary skill in the art
`
`would also have recognized that the ECBtg, PL2g, and SLMtg elements combined
`
`are a switching matrix used to process only green beams. And, one of ordinary
`
`skill in the art would also have recognized that the ECBtb, PLZb, and SLMtb
`
`elements combined are a switching matrix used to process only blue beams. After
`
`passing through the light shutter matrix, the light beams are recombined into a
`
`single image.
`
`~8—
`
`
`
`
`XLNX—l 005
`
`
`
`
`
`19.
`
`Fig. 17 of Takanashi depicts its video projection system teachings
`
`with respect to transmissive spatial light modulators:
`
`FIG. I7
`
`LS
`é
`
`RLi
`
`PLI
`
`i8
`
`g
`5%
`+—
`=55
`J; 52:5
`$45
`5&5
`
`.1
`,8.
`8%
`g?
`m g
`mg
`
`PL3
`
`RLo
`
`|
`
`NL
`
`Starting from the left side ofthe figure, Fig. 17 shows a light source that is
`
`separated into three separate light beams using the three—color separation optical
`
`system, effectively creating three separate light sources—one each for red, green
`
`and blue (R, G, and B, respectively). These colored light beams then pass through
`
`a light-shutter matrix (ECB elements, PL2 elements, and SLM elements) to create
`
`three image beams encoded with image information, which are then combined to
`
`create a single, enhanced projection video image.
`
`20.
`
`I discuss the Takanashi patent with respect to the claims ofthe ’334
`
`Patent in more detail below and explain why it renders claims of the ’334 Patent
`
`obvious by itself, as well as in combination with the “Lee” reference, US. Patent
`
`No. 5,287,131 (XLNX-1003), and the “Burstyn” reference, US. Patent No.
`
`
`—9—
`
`
`XLNX-l 005
`
`
`
`
`
`5,777,796 (XLNX-1004).
`
`Obviousness in View of Takanashi
`
`21.
`
`The Takanashi reference is entitled “Spatial Light Modulator
`
`System.” Takanashi was filed on November 23 1992, claims priority to a Japan
`
`application dated April 8, 1991, and issued on November 23, 1993, and is therefore
`
`prior art to the ’334 Patent.
`
`It is my opinion that the claims ofthe ’334 Patent are
`
`obvious in view of Takanashi for the reasons set forth below.
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`below in FIG. 17, the projection system includes (i) a light
`
`source,
`
`(ii) a three-color separation optical system, (iii) a
`
`light-shutter matrix system, (iv) a three-color combination
`
`optical system, and (v) a projection lens (PJL) for projecting
`
`images to a screen.
`
`(See, e.g., Takanashi, 16:1—63 and 20:3—
`
`4.)
`
`FHil?
`
` Takanashi teaches a video projector system. As illustrated
`
`[1.0] 1. A video
`
`projector system
`
`comprising:
`
`
`
`
`
`k8?)
`
`.J
`§
`E
`E
`§5
`,5
`ng
`E "’
`
`LS
`é RLi
`
`'
`
`Pu
`
`3
`8%
`915
`Q55
`L“ml-u
`1%
`*-
`
`PL3
`
`RL.
`
`o
`
`mt
`
`
`
`~10—
`
`LNX-lOOS
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`With respect to Fig. 17, Takanashi teaches that an “optical
`
`image projected to the screen by the projection lens PJL is
`
`obtained as the image having good contrast in the color image
`
`of
`
`the object of
`
`the display.”
`
`(Takanashi,
`
`16:40-42.)
`
`Takanashi further notes that its system can be used not only as
`
`a “display unit but also effectively for the optical computer
`
`and many other applications.” (Takanashi, 17:13-16.)
`
`In my opinion,
`
`it would have been apparent
`
`to a person
`
`having ordinary skill
`
`in the art that the projection system
`
`described throughout in Takanashi and specifically illustrated
`
`in Fig. 17 is a projector system that may be used to project
`
`video images onto a screen.
`
`
`
` Takanashi teaches a light-shutter matrix system comprising a
` [1.2] a light—shutter
`
`Thus, one of skill
`
`in the art would have recognized that
`
`Takanashi discloses a video projection system.
`
`
`[1.1] a source
`
`Takanashi
`
`teaches that
`
`the projection system uses a light
`
`projecting parallel
`
`source (LS) to produce three parallel colored light beams
`
`beams of light of
`
`“red” (R), “green” (G), and “blue” (B)) using the separation
`
`different colors;
`
`optical system 11, as shown in Fig. 17 (See also, Takanashi,
`
`16: 1—14).
`
`matrix system
`
`number of equivalent switching matrices equal to the number
`
`comprising a
`
`number of
`
`equivalent
`
`switching matrices
`
`equal to the number
`
`of beams and
`
`of beams and placed one each in the beam paths:
`
`“In this spatial light modulator shown in FIG. 17, the
`
`polarizer PLl,
`
`the liquid crystal elements ECBtg,
`
`ECBtr and ECBtb,
`
`the polarizers PL2r, PL2g and
`
`PLZb,
`
`the modulator elements SLMtr, SLMtg and
`
`SLMtb and the polarizer PL3 form the wavelength
`placed one each in
`
`
`_11_
`
` XLNX-IOOS
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
` the beam paths;
`
`[1.3] a video
`
`controller adapted
`
`for controlling the
`
`42; discussion of [1.2] above).
`light-shutter matrix
`
`
`
`
`selection filter.” (Takanashi, 16:28—33.)
`
`“The linearly polarized light of red light emitted from
`
`the three-color separation optical system 11 is incident
`
`on the liquid crystal element ECBtr,
`
`the linearly
`
`polarized light of green light emitted from the three—
`
`color separation optical system 11 is incident on the
`
`liguid crystal element ECBtg and the
`
`linearly
`
`polarized light of blue light emitted from the three-
`
`color separation optical system 11 is incident on the
`
`liquid crystal element ECBtb.
`
`The light emitted from each of liquid crystal elements
`
`ECBtr, ECBtg or ECBtb is supplied to the respective
`
`modulator element SLMtr2 SLMtg or SLMtb
`
`through the respective polarizer PL2r, PLZg or PL2b
`
`respectively.” (Takanashi, 1626-19).
`
`in the art would have
`As already discussed, one of skill
`recognized that Takanashi’s combination of ECB elements,
`polarizers PL, and SLM elements is a “light-shutter matrix
`system.”
`
`Thus, Takanashi
`
`teaches
`
`a
`
`light—shutter matrix system
`
`comprising a number of equivalent switching matrices (e.g.,
`
`there are three equivalent matrices) equal to the number of
`
`beams (e.g., there are three beams) and placed one each in the
`
`beam paths.
`
`Takanashi teaches controlling the light—shutter matrix system
`
`(e.g., ECBs, PLs, and SLMs) to encode the three light beams
`
`(R, G, B) with color image information (see Takanashi 16:28-
`
`
`
`~12~
`
`LNX—IOOS
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`system; and
`
`Specifically, Takanashi teaches that each SLM is controlled
`
`by sending a “write light WL” to the “modulator element,”
`
`and “according to the intensity distribution of write light
`
`WL,” the SLM will change the “read light RL
`
`according to
`
`said charge image.” (Takanashi, 1:46 — 2:10).
`
`In my opinion,
`
`it would have been obvious to a person of
`
`ordinary skill in the art that the device that supplies the write
`
`light WL (i) that is sent to each spatial light modulator, and
`
`(ii) that causes the spatial light modulator to change the read
`
`light RL according to the intensity distribution of the write
`
`light WL,
`
`is a video controller adapted for controlling the
`
`light—shutter matrix system.
`
`the use of a video controller in a video projector
`In fact,
`system was basic, standard practice and would have been
`abundantly evident to even beginners in the art as a way to
`control
`a light—shutter matrix or other matrix to output
`spatially and temporally modulated light.
`
`
` Takanashi teaches three-color combination optical system 12
`
`[1.4] an optical
`
`combination system
`
`adapted for
`
`combining the
`
`separate beams after
`
`the light-shutter
`
`matrix system into a
`
`single composite
`
`beam for projection
`
`on a surface to
`
`provide a video
`
`display.
`
`that combines the three light beams into a single composite
`
`beam for projection on a screen to provide a video display:
`
`“Since information is written in said each modulator
`
`element SLMtr, SLMtg or SLMtb by the write light
`
`WL, the linearly polarized light of each color incident
`
`on the modulator element SLMtr, SLMtg or SLMtb
`
`as described above is incident
`
`to the three—color
`
`combination optical
`
`system 12 in the condition
`
`modulated by the information which is written in each
`
`modulator element SLMtr, SLMtg or SLMtb.
`
`
`
`
`
`*13_
`
`XLNX—l 005
`
`
`
`
`
`
`Claim
`
`Claims 1 and 4—14 are obvious over Takanashi
`
`
`
`In this spatial light modulator shown in FIG. 17. Also,
`
`the optical
`
`image projected on the screen by the
`
`projection lens PJL is obtained as the image having
`
`good contrast in the color image of the object of
`
`display.
`
`(Takanashi, 16:21-42; see also Takanashi
`
`FIG. 17 reproduced above.)
`
`Thus, Takanashi
`
`teaches that
`
`the three-color combination
`
`optical system 12 is adapted for combining the separate
`
`beams after the light—shutter matrix system into a single
`
`composite beam for projection on a screen to provide a
`
`display.
`
`
`[4.0] The system of
`
`See [l.0]—[l .4]
`
`claim 1
`
`source projecting
`
`that sends a single light to a three color separation system
`
`parallel beams of
`
`(element 11). Fig. 16 discloses element SCA, which is an
`
`light comprises a
`
`example of a three color separation system that separates a
`
` [4.1] wherein the
`
` As shown in Fig. 17, Takanashi discloses a light source LS
`
`single white-light
`
`source projecting a
`
`white beam on a
`
`prism system
`
`adapted to separate
`
`the white beam into
`
`three color beams,
`
`white beam into three color beams:
`
`“Next, the three-color separation optical system SCA
`
`used in the spatial light modulator shown in FIG. 16 is
`
`formed of the dichroic prism DP and the prism Pr, Pb
`
`In the dichroic prism DP, the linearly polarized
`
`light incident on it is separated into three colors.”
`
`and
`
`(Takanashi, 15: 22-32).
`
`
`—l 4—
`
`LNX-1005
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`In the dichroic prism
`DP, the linearly
`polarized, white light
`incident on it is
`
`separated into three
`
`colors.
`
`
`White light
`
` Takanashi teaches that the dichroic prism DP, in conjunction
` [4.2] a redirection
`
`Portion of Fig. 16 (annotated)
`
`“[G]reen light of three separated colors of light
`
`is
`
`transmitted through
`
`[R]ed light of three colors of
`
`light separated by the dichroic prism DP is transmitted
`
`through the prism Pr
`
`The blue light of three color
`
`lights
`
`separated
`
`by
`
`the
`
`dichroic
`
`prism DP
`
`is
`
`transmitted through the prism Pb.” (Takanashi, 15:32—
`
`42).
`
`apparatus for
`
`with prism Pr and prism Pb direct the three light beams into
`
`directing the color
`
`parallel paths:
`
`beams into parallel
`
`paths to the light
`
`shutter matrix
`
`“[G]reen light of three separated colors of light
`
`is
`
`transmitted through
`
`[R]ed light of three colors of
`
`system.
`through the prism Pr The blue light of three color
`
`
`
`light separated by the dichroic prism DP is transmitted
`
`—15—
`
`XLNX—lOOS
`
`
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`
`
`lights
`
`separated
`
`by
`
`the
`
`dichroic
`
`prism DP
`
`is
`
`transmitted through the prism Pb.” (Takanashi, 15:32—
`
`42).
`
` Blue light
`
`ECBtb
`
`Pb
`
`Portion of Fig. 16 (annotated)
`
`My annotation of this portion of Fig. 16 highlights how the
`
`color beams are directed into parallel paths to (i.e., toward)
`
`the light shutter matrix system. The embodiment of Fig. 16
`
`uses
`
`reflective spatial
`
`light modulators
`
`and hence,
`
`the
`
`resulting reflected light comes back through the redirection
`
`apparatus in the opposite directions. Nevertheless, one of
`
`ordinary skill
`
`in the art would know that the above depicted
`
`portion of the Fig. 16 apparatus could be used to separate the
`
`color beams
`
`and direct
`
`them into parallel paths
`
`to a
`
`transmissive light shutter matrix system as well.
`
`
`
`[5.0] The system of
`
`See [1.0]-[l.4]
`
`
`
`
`
`—l6—
`
`XLNX-lOOS
`
`
`
`
`
`
`Claim
`
`Claims 1 and 4—14 are obvious over Takanashi
`
`
`
`claim 4
`
`
`
`[5.1] wherein the
`
`Takanashi teaches that the dichroic prism DP, in conjunction
`
`three color beams
`
`with prism Pr and prism Pb results in three color beams of
`
`produced by the
`
`red, green and blue beams:
`
`prism system are
`one each ofred
`green, and blue
`beams.
`
`is
`“[G]reen light of three separated colors of light
`transmitted through
`[R]ed light of three colors of
`light separated by the dichroic prism DP is transmitted
`.
`.
`through the prism Pr
`The blue light of three color
`
`lights
`
`separated
`
`by
`
`the
`
`dichroic
`
`prism DP
`
`is
`
`transmitted through the prism Pb.” (Takanashi, 15:32—
`
`42).
`
`
`[6.0] The video
`
`See [1.0]-[1.4]
`
`projection system of
`
`claim 1
`
` [7.0] A method for
`
`
`
`
`
`
`[6.1] wherein the
`
`As discussed above in [1.4], Takanashi
`
`teaches a light-
`
`light-shutter matrix
`
`switching matrix having three components:
`
`(i) a “liquid
`
`system comprises a
`
`crystal” elements ECB, (ii) a “polarizer PL”, and (iii) a spatial
`
`monochrome LCD
`
`light modulator element SLM, where each matrix processes a
`
`array.
`
`single beam of color (See, e.g., Takanashi, 9:16 and Fig. 17).
`
`Since Takanashi
`
`teaches using three liquid crystal display
`
`elements—one for each of three light colors—one of skill in
`
`the art would have understood that the liquid crystal display
`
`elements are a monochrome LCD array.
`
`One of ordinary skill in the art would have understood that the
`write light distribution of Takanashi could be dynamic, i.e.,
`projecting a
`could vary with time. Thus, Takanashi teaches a method for
`dynamic color
`
`
`~17~
`
`
`
`XLNX—IOOS
`
`
`
`
`
`
`
`Claims 1 and 4-14 are obvious over Takanashi
`Claim
`
`
`image, comprising
`steps of:
`
`projecting a dynamic color image generally throughout the
`specification.
`
`
`
`[7.1] a) providing
`
`See [1.1]
`
`separate parallel
`
`beams of colored
`
`light;
`
`[7.2] b) directing
`
`See [6.1]
`
`the separate color
`
`beams on separate
`
`cells of a
`
`monochrome LCD
`
`array;
`
`
`[7.3] 0) switching
`
`See [1.3]
`
`the monochrome
`
`matrix by action of
`
`a Video signal
`
`through an LCD
`
`controller;
`
`
`
`
`
` [7.5] e) focusing the Takanashi teaches, after recombining the three color lights in
`
`[7.4] d)
`
`See [1.4]
`
`recombining the
`
`beams of colored
`
`light into a single
`
`beam; and
`
`the three—color combination optical system 12, a projection
`recombined beam
`
`
`~18~
`
`
`
`
`XLNX-IOOS
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`lens P] L projects the optical image onto a surface:
`
`“[T]he optical
`
`image projected to the screen by the
`
`projection lens PJL is obtained as the image having
`
`good contrast
`
`in the color
`
`image of the object of
`
`display.” (Takanashi 16: 38—42).
`
`One of ordinary skill in the art would have understood that the
`
`write light distribution of Takanashi could be dynamic, i.e.,
`
`could vary with time.
`
`See [7.0]—[7.5]
`
`f
`
`See [5.1]
`
`See [7.0]
`
`on a surface to
`
`provide a dynamic
`
`color image.
`
`[8.0]The method of
`
`claim 7
`
`[8.1] wherein the
`
`separate beams of
`
`colored light
`
`comprise beams of
`
`red, green and blue
`
`light.
`
`[9.0] A method for
`
`projecting a
`
`dynamic color
`
`image, comprising
`
`
`
`
`
`
`
`
`
`steps of:
`
`
`[9.1] a) directing a
`
`beam of white light
`
`See [4.1]
`
`on a prism system;
`..__—_-__—___.__L__..
`
`
`
`49*
`
`
`
`
`
`XLNX—lOOS
`
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`[9.2] b) splitting the
`
`See [4.1]
`
`beam of white light
`
`into separate beams
`
`of colored light by
`
`action of the prism
`
`system;
`
`
`[9.3] c) directing
`
`See [6.1]
`
`the separate beams
`
`of colored light
`
`onto a monochrome
`
`LCD matrix having
`
`as many cells as the
`
`separate beams of
`
` See [1.4]
` [9.6] f) focusing the
`
`colored light;
`
`
`[9.4] d) switching
`
`See [1.3]
`
`the monochrome
`
`matrix by action of
`
`a video signal
`
`through an LCD
`
`controller;
`
`
`[9.5] e)
`
`See [1.4]
`
`recombining the
`
`beams of colored
`
`light into a single
`
`beam; and
`
`
`
`recombined beam
`
`
`_2 0m
`
` XLNX— l 005
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`on a surface to
`
`provide a dynamic
`
`color image.
`
`
`[10.0] The method
`
`See [9.0]-[9.6]
`
`of claim 9
`
`
`
` See [4.1]
` [11.2] a splitter
`
`
`
`[10.1] wherein in
`
`See [5.1]
`
`step b) the beam of
`
`white light is split
`
`into three color
`
`beams, one red, one
`
`green, and one blue.
`
`
`[11.0] A Video
`
`See [1.0]
`
`projector system
`
`comprising:
`
`
`[11.1] a source
`
`See [4.1]
`
`projecting a beam
`
`of white light;
`
`adapted to split the
`
`beam of white light
`
`into separate
`
`parallel beams of
`
`light of different
`
`colors;
`
`
`#21—
`
`XLingth
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`See [1.2]
`
`[11.3] a light-
`
`shutter matrix
`
`system comprising
`
`a number of
`
`equivalent
`
`switching matrices
`
`equal to the number
`
`of beams of light of
`
`different colors and
`
`placed one each in
`
`each beam path;
`
`
` [11.5] an optical
` See [1.4]
`
`[1 1.4] a video
`
`See [1.3]
`
`controller adapted
`
`for controlling the
`
`light—shutter matrix
`
`system; and
`
`combination system
`
`adapted for
`
`combining the
`
`separate beams after
`
`the light-shutter
`
`matrix system into a
`
`single composite
`
`beam for projection
`
`on a surface to
`
`provide a video
`
`display.
`
`
`—22~
`
`XLNX—l 005
`
`
`
`
`
`
`
`
`Claim
`
`Claims 1 and 4-14 are obvious over Takanashi
`
`
`
`[12.0] The Video
`
`See [11.0]—[11.5]
`
`projector system of
`
`claim 11
`
`
`
`[See [5.1]
`
`[12.1] wherein the
`
`splitter divides the
`
`beam of white light
`
`into three separate
`
`beams of colored
`
`light, one red, one
`
`green, and one blue.
`
`
`
`
` See [6.1]
` [14.1] wherein the
`
`[13.0] The Video
`
`See [11.0]—[1 1.5]
`
`projector system of
`
`claim 1 1
`
`
`
`[13.1] wherein the
`
`See [4.1]
`
`splitter is an
`
`apparatus
`
`comprising prisms.
`
`[14.0] The video
`
`See [1 1.0] * [11.5]
`
`projection system of
`
`claim 11
`
`light—shutter matrix
`
`system comprises a
`
`monochrome LCD
`
`array.
`
`
`723*
`
`
`
`XLNX-l 005
`
`
`
`Obviousness in View of Takanashi and Lee
`
`22.
`
`In addition to the teachings of Takanashi, a person of ordinary skill in
`
`the art would have known to use a video controller to control a shutter light matrix
`
`versus a write light.
`
`In fact, the use ofa video controller in a projector system was
`
`basic, standard practice and would have been abundantly evident to even beginners
`
`in the art as a way to control a light—shutter matrix or other matrix to output
`
`spatially and temporally modulated light.
`
`23.
`
`An example ofa video controller is shown in Lee Fig. 2 at item 19.
`
`With respect to item 19, Lee notes using a “light shutter controlling circuit 19” for
`
`controlling light shutters 14R, 14G, and 14B in order to modulate the light beams.
`
`
`
`Lee Fig. 2
`
`24.
`
`In view ofthe teachings of Takanashi and Lee, utilizing a video
`
`controller adapted for controlling the light-shutter matrices was simply a matter of
`
`ordinary skill and common sense, not innovation. Furthermore, such an addition to
`
`Takanashi would have been obvious to try, as well as a combination of prior art
`
`
`—24~
`
`
`
`
`XLNX— l 005
`
`
`
`elements according to known techniques to yield predictable results.
`
`25. Additionally, a person of ordinary skill in the art would have seen a
`
`three-light source system versus a single-light source system as a simple matter of
`
`design choice. Various factors that might affect such a decision include available
`
`space for the apparatus, ability to dissipate heat, cost of a prism or mirror system
`
`versus cost of three separate sources with individual color filters, etc. A person of
`
`ordinary skill in the art would have understood the differences between two such
`
`systems and would have chosen the best one for a particular application. Further, a
`
`person of ordinary skill in the art would recognize that the choice ofi) a single
`
`white light source illuminating color filters, or ii) three white light sources
`
`illuminating color filters, essentially exhausts the possibilities for obtaining three
`
`separate colored light beams from incident white light, thereby making either
`
`choice obvious to try.
`
`26.
`
`One example modification would replace the single—source apparatus
`
`of Takanashi Fig. 17 with a three-source apparatus, similar to that shown in Lee.
`
`In this example, a person of ordinary skill in the art would have omitted the single
`
`light source (LS) and the three-color separation optical system 10 in Fig. 17 of
`
`Takanashi.
`
`In its stead, a person of ordinary skill would adopt a three—source
`
`system that would include features similar to Lee’s sources 17/26, lenses 15, and
`
`filters 28 to provide colored light beams at each of the R, G, and B portions of
`
`~25—
`
`LNX-l 005]
`
`
`
`Takanashi’s liquid crystal elements ECB.
`
`I do not propose a bodily incorporation
`
`of Lee’s components into Takanashi’s system, but rather, I note that a person of
`
`ordinary skill in the art would have been quite capable of replacing Takanashi’s
`
`single-source apparatus with a three-source apparatus having three sources, three
`
`filters, and three lenses. Such a modification is a simple design choice, as noted
`
`above. Also, it is a combination ofprior art elements according to known
`
`techniques to give predictable results.
`
`27. Accordingly, it is my opinion that claims 1—14 ofthe ”334 Patent are
`
`obvious in view of Takanashi and Lee for the reasons set forth below.
`
`
`
`
`Claim Claims 1—14 are obvious over Takanashi in View of Lee
`
`projector 53’5th
`comprising:
`
`
` [1.0] 1.Avideo
`
`
`teaches a video projector system. As illustrated
`Takanashi
`below in FIG. 17, the projection system includes (i) a light
`source, (ii) a three-color separation optical system, (iii) a light—
`shutter matrix system, (iv) a three-color combination optical
`
`system, and (v) a projection lens (PJL) for projecting images to
`
`a screen.
`
`(See, e.g., Takanashi, 1621-63 and 2023-4.)
`
`—26—
`
`
`
`XLNX-l 005
`
`
`
`
`
`
`Claim
`
`
`4 Claims 1-14 are obvious over Takanashi in View of Lee
`
`j
`
`FIG. I?
`
` [1.1] a source
` Takanashi teaches that the projection system uses a light source
`
`SYSTEM
`
`3 8| N
`
`g
`E
`gl-U)
`d
`g
`F33
`
`a‘E
`
`a:
`
`PL3
`
`RLo
`
`PJL
`
`g
`
`“5%
`LIJ2
`$8
`
`With respect to Fig. 17, Takanashi
`
`teaches that an “optical
`
`image projected to the screen by the projection lens PJL is
`
`obtained as the image having good contrast in the color image
`
`ofthe object ofthe display.” (Takanashi, 16:40—42.) Takanashi
`
`further notes that its system can be used not only as a “display
`
`unit but also effectively for the optical computer and many
`
`other applications.” (Takanashi, 17:13-16.)
`
`In my opinion, it would have been apparent to a person having
`
`ordinary skill
`
`in the art that the projection system described
`
`throughout in Takanashi and specifically illustrated in Fig. 17 is
`
`a projector system that may be used to project video images
`onto a screen.
`
`Thus, one of skill
`
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