`Filed on behalf of Intellectual Ventures
`By: George E. Quillin
`Paul S. Hunter
`FOLEY & LARDNER LLP
`3000 K Street, N.W., Suite
`600 Washington, D.C. 20007
`Tel: (202) 672-5300 Fax:
`(202) 672-5399
`gquillin@foley.com
`
`Paper No.
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`XILINX, INC.
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES I LLC
`Patent Owner
`
`Case IPR2013-00112
`Patent 5,779,334
`
`
`
` PATENT OWNER’S DEMONSTRATIVE EXHIBITS
`
`
`4849-4518-0696.1
`
`
`
`
`
`IPR2013-00112
`Patent Owner’s Demonstrative Exhibits
`
`PATENT OWNER’S DEMONSTRATIVES
`
`In accordance with the Board’s scheduling order, Patent Owner Intellectual
`
`Ventures submits the following demonstrative exhibits for use at the hearing scheduled
`
`for Tuesday, January 28, 2014.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/George E. Quillin/
`George E. Quillin
`Registration No. 32,792
`Foley & Lardner LLP
`Counsel for Patent Owner
`
`
`
`
`
`4849-4518-0696.1
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing PATENT OWNER’S
`
`DEMONSTRATIVE EXHIBITS is being served on counsel of record by filing this document
`
`through the Patent Review Processing System as well as delivering a copy via commercial
`
`overnight courier directed to the counsel of record for the Petitioner at the following address:
`
`David L. McCombs, Esq.
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`
`Respectfully submitted,
`
`
`
`
`/George E. Quillin/
`George E. Quillin
` Registration No. 32,792
` Counsel for Patent Owner
`
`
`Dated: January 24, 2014
`
`
`
`
`
`
`
`
`
`4849-4518-0696.1
`
`
`
`IPR2013‐00112
`U.S. Patent No. 5,779,334
`
`Demonstratives
`Patent Owner
`Intellectual Ventures I LLC
`
`1
`
`
`
`The Challenge
`
`• Obviousness of Claims 1‐6 and 11‐14 based on
`Takanashi in view of Lee.
`
`The Technology
`
`• ‘334 patent (Monochrome LCD)
`• Takanashi (Light Controlled Light Valve)
`• Lee (Liquid Crystal Panel)
`
`2
`
`
`
`‘334 Patent: Monochrome LCDs
`Figs. 5‐18 and 5‐19, p. 106, of Ex. 2012
`
`3
`
`
`
`Takanashi: Light‐Controlled SLM
`
`Fig. 8 of Takanashi
`
`4
`
`
`
`Lee: Liquid Crystal Panel
`
`Fig. 2 of Lee
`
`5
`
`
`
`Other Technology: Cathode Ray Tube
`
`Fig. 21, p. 98, Ex. 1015
`
`Typical CRT Scan Pattern
`
`6
`
`
`
`Claim Language
`
`• “light‐shutter matrix system comprising a
`number of equivalent switching matrices.”
`
`• “video controller adapted for controlling the
`light‐shutter matrix system.”
`
`7
`
`
`
`“Light‐Shutter Matrix System”
`• Board’s definition:
`
`(Decision Instituting IPR, p.9)
`• Dr. Buckman acknowledges that there is no
`matrix in Takanashi when the write light is off.
`However, he asserts that a matrix is formed in
`Takanashi when the SLM is driven by a “write
`light.” (Ex. 2010 at pp. 23‐24)
`
`8
`
`
`
`“Light‐Shutter Matrix System”
`
`Q. Look at Figure 8 of Takanashi, if you would. How many picture
`elements are on the SLMr illustrated in Figure 8? …
`A. As many picture elements, that is as many local transmissivities are
`created in Figure 8, as are creatable by the apparatus that produces the
`spatial distribution of write light, WL.
`• (Ex. 2010, pp. 31‐32)
`A. That [an overhead projector] could be an exception, yes, that's – one
`that's not using a matrix.
`Q. Any others? Any other examples?
`A. None that I can think of as we sit here well, okay, a – a Kodachrome
`35-millimeter slide projector, same basic idea.
`• (Ex. 2018, p. 36)
`
`c
`
`9
`
`
`
`“Light‐Shutter Matrix System”
`
`Q. Does Takanashi teach that its write light is organized as a matrix?
`A. Takanashi -- excuse me, Takanashi doesn't -- doesn't speak much about his write
`light, but somebody of ordinary skill in the art who knows anything about optical
`systems would understand that such a matrix write light can be created using either a
`CRT or a scanned optical system.
`• (Ex. 2018, p. 40)
`Q. Is the system of Lee a CRT system?
`A. No, it's not. The system of Lee does not use write light.
`Q. Are there any CRTs in Lee's system?
`A. No.
`• (Ex. 2018, p. 42)
`
`10
`
`
`
`“Video Controller”
`
`• Board held that “video controller adapted for
`controlling the light shutter matrix system”
`means:
`“a component that controls the light‐shutter
`matrix system to facilitate the display of video.”
`(Decision Instituting IPR, pp. 11‐12.)
`
`11
`
`
`
`Takanashi Alone…
`The Board held that Takanashi does not show the
`claimed “video controller” (Institution of trial, p. 17):
`
`12
`
`
`
`“Video Controller”
`• Relying on Dr. Buckman, the Board held that
`Lee teaches the claimed video controller and
`pointed to “light shutter controlling circuit
`19.” (Decision Instituting IPR, p. 22.)
`• However, Dr. Buckman subsequently testified:
`
`(Deposition of Buckman, Oct. 8, 2013, page 7, lines 11‐22.)
`
`13
`
`
`
`Chronology of Dr. Buckman’s Positions on Lee
`
`
`
`Chronology of Dr. Buckman’s Positions on Lee
`
`
`
`Chronology of Dr. Buckman’s Positions
`on “video controller” ‐ SUMMARY
`• Jan 2013: Buckman’s initial declaration in ‘334
`– Lee 19 is “video controller.”
`• Aug 2013: Buckman’s 1st deposition in ‘334
`– Admits Lee 19 is not a video controller.
`• Sept 2013: Buckman Reply Report in ‘545
`– Identifies Lee 20 as “video controller.”
`• Oct 2013: Petitioner files Reply Brief including
`Buckman Reply Report in ‘334
`– Identifies Lee 20 & 21 as “video controller.”
`
`16
`
`
`
`Petitioner’s new “video controller”
`
`Petitioner’s new ”video controller”
`
`”Video controller” alleged in Petition
`
` h“...—
`
`17
`
`
`
`“Video Controller”
`
`Fig. 8 of Takanashi
`
`18
`
`
`
`Motion to Amend
`
`• “second controller adapted to control the
`three white‐light sources,”
`
`• “control link adapted to connect the video
`controller to the second controller to provide
`individualized variable control of each of the
`three white‐light sources.”
`
`19
`
`
`
`“Second Controller”
`
`‘545 Buckman Declaration
`
`‘334 Buckman Declaration
`
`Nov. 12, 2013 Deposition, p. 78: “Q: So the drawing in the declaration for the 545 patent,
`Exhibit 2017 here, that drawing is incorrect, is that what you’re saying? A: Yes.”
`20
`
`
`
`“Second Controller”
`
`‘334 Buckman Declaration
`
`21
`
`
`
`“Control Link”
`
`‘545 Buckman Declaration
`
`‘334 Buckman Declaration
`
`Nov. 12, 2013 Deposition, p. 75: “Q: So your current position is that the annotation
`should be for control lines not control links? A: Those are control lines, yes.”
`
`22
`
`
`
`“Control Link”
`
`‘334 Buckman Declaration
`
`23
`
`
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