UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`XILINX, INC, Petitioner
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`v.
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`Patent of INTELLECTUAL VENTURES MANAGEMENT, LLC,
`Patent Owner.
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`Inter Partes Review No. IPR2013-00112
`Patent No. 5,779,334
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`________________________________________________________
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`SUPPLEMENTAL DECLARATION of A. BRUCE BUCKMAN, PH.D
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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`XILINX, INC, Petitioner
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`v.
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`Patent of INTELLECTUAL VENTURES MANAGEMENT, LLC,
`Patent Owner.
`
`Inter Partes Review No. IPR2013-00112
`Patent No. 5,779,334
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`________________________________________________________
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`SUPPLEMENTAL DECLARATION of A. BRUCE BUCKMAN, PH.D
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`I, Dr. A. Bruce Buckman, do hereby declare:
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`1.
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`I am making this declaration at the request of Xilinx in IPR2013-
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`00112 of US Patent No 5,779,334 (“the ’334 Patent”) to Kikinis.
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`2.
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`I previously submitted a declaration explaining why the ’334 patent is
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`invalid. That declaration is marked as XLNX-1005, and sets forth my experience,
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`qualifications, publications, materials considered and compensation.
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`3.
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`As described in my prior declaration, I have over forty years of
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`experience in the field of optics, including thirty-five years of experience as a
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`professor in the electrical engineering department of the University of Texas at
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`Austin. During this time, my teaching and research have focused on a wide range
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`of topics in field of optics.
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`4.
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`I understand that Patent Owner Intellectual Ventures has objected to
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`my testimony on the grounds that I “lack[] expertise in the relevant field” and do
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`not possess “special skill, knowledge, or experience concerning the particular issue
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`before the Board.” I disagree—I believe my experience and qualifications in the
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`field of optics speak for themselves. Nevertheless, to eliminate any doubt, I have
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`been asked to provide the following elaboration on my experience and expertise as
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`it pertains to the subject matter of the ’334 patent.
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`5.
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`As noted in my previous declaration, my 44 years of experience in
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`XLNX-1008
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`optical engineering includes over 15 years of teaching a graduate course in fiber
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`and guided-wave optics at the University of Texas at Austin. Course topics
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`included many of the components that appear in the ’545 Patent, such as filters,
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`prisms and lenses for redirecting light rays, and dichroic elements for combining or
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`splitting light of different wavelengths or colors. For example, that course dealt
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`with many image processing topics, including using a dynamic mask to create a
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`desired output pattern or image. LCDs and spatial light modulators are just two of
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`many types of dynamic masks that can be used to selectively block or transmit
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`light to create dynamically changing images or patterns, of which video is but one
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`example.
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`6.
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`I authored a textbook, Guided-Wave Photonics as an aid in teaching
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`the course. I concurrently conducted research in optical systems that resulted in
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`dozens of peer-reviewed publications, including one on a 6-Degree of freedom
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`non-contact optical position sensor that won the Best Paper Award at an
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`international conference in 1994. I am a co-inventor on a US Patent for that
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`device, and an inventor on three other patents covering various optical systems.
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`This combined teaching and research experience with varying realizations of each
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`of the above optical components has given me familiarity with the results of
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`substituting one realization of a particular component for another.
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`7.
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`I also taught courses on fiber and guided wave optics that included
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`XLNX-1008
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`significant discussions of the components that make up the systems discussed in
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`the ’334 patent and the prior art references at issue, including components such as
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`dichroic prisms, filters, polarizers, spatial light modulators, and other similar
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`components.
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`8.
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`During my career, I also designed and built systems using these
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`components. These systems included prisms and mirror systems for separating
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`light, lens systems for focusing light, lens / mirror systems for recombining light,
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`polarizers for controlling light polarity, color filters, and interferometers that split
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`and then subsequently recombine light.
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`9.
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`This experience is directly relevant to the ’334 patent. Claim 1 of the
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`’334 patent reads:
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`1. A video projector system comprising:
`a source projecting parallel beams of light 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
`beams after the light-shutter matrix system into a single composite
`beam for projection on a surface to provide a video display.
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`10.
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`I have experience with all of the components of this system. For
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`example, a source projecting parallel beams of light of different colors can be built
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`in a variety of ways, including by using dichroic prisms to divide the light, and
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`XLNX-1008
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`light collimators to ensure that the beams of light are roughly parallel. I have
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`consulted about dichroic mirrors and coatings for a company that uses them in the
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`illumination systems they manufactured. Earlier in my career, I routinely created
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`parallel beams of light in connection with my work on six-degree-of-freedom
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`optical sensors, some of which received a “best paper” award at an international
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`conference.
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`11.
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`I also have experience with light-shutter matrix systems. In particular,
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`I have experience with spatial light modulators (SLMs), which are pixelated
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`devices used to create light masks. A liquid crystal display is but one type of
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`SLM.. Additionally, the graduate course I taught for many years from my
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`textbook entitled Guided-Wave Photonics, XLNX-1009, and earlier from note-sets
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`that became the book, involved extensive discussions of SLMs and their
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`application to the field of optics. The guided-wave versions of SLM’s that I taught
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`are pixilated and operate on essentially the same principles as conventional SLM’s.
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`XLNX-1009 at 253.
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`12. My textbook also describes the electrical devices that control a
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`guided-wave SLM. A video controller is a form of SLM controller that uses
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`electrical signals to control SLM pixels, typically modulating the SLM pixels
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`around 30 times per second. With the electronic SLM controllers I researched for
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`my textbook, the spectrum analyzer application incorporates modulation of the
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`XLNX-1008
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`SLM at frequencies up to at least MHz. [XLNX-1009 at 250] Thus I am very
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`familiar with SLM applications, including pixelated applications, that run at speeds
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`that are even much higher than video speeds.
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`13.
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`I also have experience with optical combination systems. Many
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`optical systems use optical combination systems to recombine light. My
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`experience with optical combination systems includes research on fiber-optic and
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`free space optical systems that recombine light beams as part of their operations..
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`14. Because of this experience, I am very comfortable providing opinions
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`regarding a wide range of optical applications, including optical projection
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`systems. I see nothing in the ’334 patent to suggest that it is anything other than a
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`combination of well-known optical components in well-known ways used
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`throughout the field of optics, to create a predictable optical projection system.
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`This is confirmed by my review of the ’334 patent and the prior art references at
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`issue in this IPR, all of which deal with standard optical components of the sort
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`that I have used throughout my career.
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`15.
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`I declare that all statements made herein on my own knowledge are
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`true and that all statements made on information and belief are believed to be true,
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`and further, that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`–6–
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`XLNX-1008
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`Executed July 19, 2012.
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`By: _____________________________
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`A. Bruce Buckman, Ph.D.
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`–7–
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`XLNX-1008
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