IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Petition for Inter Partes Review
`
`Attorney Docket No.: 42299.43
`Customer No.:
`27683
`Real Party in Interest: Xilinx, Inc.
`
`§§§§§§§§§
`
`In re patent of Kikinis
`
`U.S. Patent No. 5,779,334
`
`Issued: July 14, 1998
`
`Title: ENHANCED VIDEO
`PROJECTION SYSTEM
`
`Declaration of A. Bruce Buckman, Ph.D. under 37 C.F.R. § 1.68
`
`Directed to the Proposed Substitute Claims
`
`I, Dr. A. Bruce Buckman, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Xilinx, Inc. in the matter
`
`of the Inter Partes Review of U.S. 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.
`
`(1)
`
`(2)
`
`In the preparation of this declaration, I have studied:
`
`The ’334 patent, XLNX-1001;
`
`The file history of the ’334 patent, XLNX-1007;
`
`(3) U.S. Patent No. 5,264,951 (“Takanashi”), XLNX-1002;
`
`–1–
`
`XLNX-1011
`
`
`
`Petition for Inter Partes Review
`
`Attorney Docket No.: 42299.43
`Customer No.:
`27683
`Real Party in Interest: Xilinx, Inc.
`
`§§§§§§§§§
`
`In re patent of Kikinis
`
`U.S. Patent No. 5,779,334
`
`Issued: July 14, 1998
`
`Title: ENHANCED VIDEO
`PROJECTION SYSTEM
`
`Declaration of A. Bruce Buckman, Ph.D. under 37 C.F.R. § 1.68
`
`Directed to the Proposed Substitute Claims
`
`I, Dr. A. Bruce Buckman, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Xilinx, Inc. in the matter
`
`of the Inter Partes Review of U.S. 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.
`
`(1)
`
`(2)
`
`In the preparation of this declaration, I have studied:
`
`The ’334 patent, XLNX-1001;
`
`The file history of the ’334 patent, XLNX-1007;
`
`(3) U.S. Patent No. 5,264,951 (“Takanashi”), XLNX-1002;
`
`–1–
`
`XLNX-1011
`
`
`
`(4) U.S. Patent No. 5,287,131 (“Lee”), XLNX-1003;
`
`(5) U.S. Patent No. 5,136,397 (“Miyashita”), XLNX-1010.
`
`4.
`
`(1)
`
`(2)
`
`In forming the opinions expressed below, I have considered:
`
`The documents listed above,
`
`The relevant legal standards, including the standard for obviousness
`
`provided in KSR International Co. v. Teleflex, Inc., 550 U.S. 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, I
`
`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
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`–2–
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`XLNX-1011
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`
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`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
`
`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 U.S. 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.
`
`As I will discuss below, some of the subject matter of the Substitute
`
`Claims proposed by the Patent Owner involve the heat shielding and power control
`
`of high intensity lamps such as those typically used in projection systems. I also
`
`have gained practical experience in those areas. In my optics experiments at the
`
`University of Nebraska and later at the University of Texas, I routinely used high
`
`intensity lamps for a light source for my optical measuring instruments which
`
`incorporated heat filter glass to shield downstream components from the excessive
`
`heat from the lamp. The heat filter glass took the form of a glass coated with a
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`–3–
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`XLNX-1011
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`
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`number of thin films so as to make it pass light in the visible and reflect light in the
`
`infrared. I researched thin film optics for several years, and am familiar with how
`
`film thickness and refractive index is used to make a wavelength-selective coating
`
`such as a heat shield. Such a filter glass is commonly called a “hot mirror.” As for
`
`using fans to move the air next to hot electronic equipment, any electrical engineer
`
`learns early about its necessity.
`
`8.
`
`Control of high intensity lamps may include a feedback loop using a
`
`temperature sensor to determine the temperature of the lamp environment and
`
`incorporating a power adjustment of the lamp if the temperature goes too high.
`
`This could be as simple as shutting down the lamp under those conditions. Control
`
`of high intensity lamps may also include a feedback loop incorporating a light
`
`intensity sensor to control light output from the lamp. I taught feedback control
`
`systems for nearly 10 years at the University of Texas, and developed software for
`
`computer-aided design (CAD) that my students used in the conduct of my control
`
`systems course.
`
`9.
`
`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 (1) with
`
`students, undergraduates as well as masters and Ph.D. 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
`
`–4–
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`XLNX-1011
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`
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`state of the art. Unless otherwise stated, my testimony 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.
`
`10.
`
`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 by designing optical systems with off the shelf parts.
`
`Relevant Legal Standards
`
`11.
`
`I have been asked to provide my opinions regarding whether the
`
`claims of the ’334 patent are anticipated or would have been obvious to a person
`
`having ordinary skill in the art at the time of the 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 if the 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
`
`–5–
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`XLNX-1011
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`
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`between the prior art and the claimed subject matter.
`
`12.
`
`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 of these 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)
`
`ready for improvement to yield predictable results; choosing from a finite number
`
`of identified, 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
`
`13.
`
`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
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`–6–
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`XLNX-1011
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`before they are combined into the projectable light beam. (Id.; see also id. at 3:10-
`
`30.)
`
`14. 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 at 3:10-11). These three parallel beams
`
`enter a light shutter matrix system comprising “three monochrome LCD arrays
`
`117, 118, and 119.” (’334 patent at 3:21-27). “Controller 122 controls the three
`
`monochrome matrices 117, 118, and 119.” (’334 patent at 3:39-40). Lastly, “after
`
`passing through the active regions 117-119, the separate beams get combined into
`
`a single beam by mirror and prism system 111, then the combined beam is focused
`
`and projected onto a surface 101.” (’334 patent at 3:27-30). The ’334 specification
`
`mentions only LCD array spatial light modulators that operate in transmission.
`
`15.
`
`The light source is controlled by a controller 130. (Id. at 3:7-14.)
`
`–7–
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`XLNX-1011
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`
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`Controller 130 is connected to controller 122 by a control link 124. (Id. at 3:56-60.)
`
`Control link 124 is used to provide some limited variable control of light output
`
`from the light source. (Id.)
`
`Patent Owner’s Motion to Amend
`
`16.
`
`In the Patent Owner’s Motion to Amend filed August 27, 2013, Patent
`
`Owner proposes to cancel claim 3 and substitute claim 15 in its place contingent on
`
`claim 3 being found unpatentable by the Board.
`
`17.
`
`Proposed claim 15 is reproduced below:
`
`15. (Proposed substitute for Claim 3) The video projector system of
`
`claim 2, wherein the three color filters comprise one each of red, green, and
`
`blue filters, and wherein the video projector system further comprises:
`
`a second controller adapted to control the three white-light sources;
`
`and
`
`a 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.
`
`18.
`
`Patent Owner also proposes to cancel claim 12 and substitute claim
`
`16 in its place contingent on claim 12 being found unpatentable by the Board
`
`19.
`
`Proposed claim 16 is reproduced below:
`
`16. (Proposed substitute for Claim 12) The video projector system of
`
`–8–
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`XLNX-1011
`
`
`
`claim 11 wherein the splitter divides the beam of white light into three
`
`separate beams of colored, one red, one green, and one blue., further
`
`comprising:
`
`a second controller adapted to control the source; and
`
`a control link adapted to connect the video controller to the second
`
`controller to provide variable control of the source.
`
`20. None of the limitations in proposed claim 15 and 16 appear in the
`
`claims that were presented during prosecution of the application that led to the
`
`’334 patent.
`
`Claim Construction
`
`21.
`
`It is my understanding that in order to properly evaluate the proposed
`
`claims of the ’334 patent, the terms of the claims must first be interpreted. It is my
`
`understanding that the claims are to be given their broadest reasonable
`
`interpretation in light of the specification. It is my further understanding that claim
`
`terms are given their ordinary and accustomed meaning as would be understood by
`
`one of ordinary skill in the art, unless the inventor, as a lexicographer, has set forth
`
`a special meaning for a term.
`
`22.
`
`In order to construe the claims, I have reviewed the entirety of the
`
`’334 patent, as well as its prosecution history.
`
`–9–
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`XLNX-1011
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`
`
`“second controller”
`
`23.
`
`The specification does not provide a specific definition for “second
`
`controller.” In fact, the specification does not even use the term “second
`
`controller.” The specification states that: “Light for the projector is generated in
`
`this embodiment by three High Intensity Discharge (HID) lamps 132-134, which
`
`are controlled by controller 130” (Id. at 3:7-9.)
`
`24.
`
`The specification also states that: “A control link 124 is provided
`
`between controllers 122 and 130, and this link is used in some embodiments for
`
`some limited variable control of light output from each of the three light sources
`
`individually.” (Id. at 3:56-59.)
`
`25.
`
`It is my opinion that a person of ordinary skill in the art would
`
`understand the broadest reasonable interpretation of “second controller” in view of
`
`the specification and file history to be: “one or more control circuits separate from
`
`the video controller.”
`
`“control link”
`
`26.
`
`The specification does not provide a definition for “control link.” The
`
`specification states that “[a] control link 124 is provided between controllers 122
`
`and 130, and this link is used in some embodiments for some limited variable
`
`control of light output from each of the three light sources individually.” (Id. at
`
`–10–
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`XLNX-1011
`
`
`
`3:56-59.)
`
`27.
`
`It is my opinion that a person of ordinary skill in the art would
`
`understand the broadest reasonable interpretation of “control link” in view of the
`
`specification file history to be: “an electronic connection between the video
`
`controller and another controller.”
`
`Challenge #4: Proposed claims 15 and 16 are obvious over Takanashi in
`
`view of Lee and Miyashita.
`
`28.
`
`It is my understanding that there are many legal bases under which
`
`prior art references could be combined. It is my opinion that a person of ordinary
`
`skill in the art would have found it obvious to combine a spatial light modulator
`
`such as that of Takanashi with the controllers of Lee and Takanashi and the control
`
`link of Miyashita. Such a combination would have been nothing more than the use
`
`of known techniques taught by Lee and Miyashita to improve Takanashi’s similar
`
`video projector system in the same way.
`
`29.
`
`Takanashi teaches a video projector system, (see Takanashi at 16:1-
`
`63, 20:3-4, Fig. 17.), that includes embodiments with parallel light sources. (See id.
`
`at 16:1-14, Fig. 17.) Takanashi also teaches controlling a light-shutter matrix in the
`
`video projector system. (See id. at 16:28-42.)
`
`30.
`
`Lee also teaches a video projector system. (See Lee, Abstract.) The
`
`–11–
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`XLNX-1011
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`
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`video projector system of Lee is similar to that of Takanashi in that Lee’s video
`
`projector system also includes three individual light sources. (Id. at 3:14-19.) In
`
`addition to three individual light sources, Lee also includes a lamp voltage
`
`controller that allows for changes to light intensity emitted from each respective
`
`light source. (Id.) Further, Lee teaches a video controller for controlling the video
`
`projector system. (Id. at 3:46-52.)
`
`31. Miyashita also teaches a video projector system. (Miyashita,
`
`Abstract.) Miyashita’s projector system includes a light control circuitry that
`
`controls the projector’s lamp. (See [15.2] and [16.2], below.) Miyashita also
`
`teaches a control link that connects the light controlling circuit to a video
`
`controller. (See id. at 5:21-47; id. at Fig. 3.) The video controller can either be
`
`implemented as a series of controllers, (id. at 4:12-20), or as a micro-processor
`
`based system (id. at 5:21-26).
`
`32.
`
`It is my opinion that it would have been obvious to a person of
`
`ordinary skill in the art to combine the prior art elements of a light controller that
`
`provides variable control of three light sources (e.g., as in Lee’s projector) with a
`
`video projector system such as that taught in Takanashi. Takanashi and Lee each
`
`teach a video projector system with multiple parallel light sources. Combining a
`
`lamp controller as taught in Lee with a video projector system as in Takanashi
`
`would have been nothing more than the use of known techniques of using
`
`–12–
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`XLNX-1011
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`
`
`controllers to control lights (e.g., the lamp controller of Lee) to improve a similar
`
`video projector system (e.g., the projector system of Takanashi) in the same way.
`
`33.
`
`It is my opinion that it would have been obvious to a person of
`
`ordinary skill in the art to combine the prior art elements of control lines that
`
`connect a light controller to light sources to provide variable control of the light
`
`sources (e.g., as in Lee’s video projector system) and a control link that connects a
`
`light controller with a video controller (e.g., as in Miyashita’s video projector
`
`system) with a video projector system such as that taught in Takanashi. Takanashi,
`
`Lee, and Miyashita teach video projector systems that use LCD arrays. Takanashi
`
`and Lee each teach a projector that includes multiple parallel light sources. Lee and
`
`Miyashita each teach a light controller that controls light sources. Lee further
`
`teaches that the light controller can provide variable control of each individual
`
`light source and Miyashita further teaches a control link that connects a video
`
`controller and a lamp controller. Combining control lines that connect a lamp
`
`controller to each light source to provide variable control of each light source as
`
`taught in Lee and a control link that connects a video controller to a light controller
`
`as taught in Miyashita would have been nothing more than the use of known
`
`techniques of connecting a light controller and a video controller to provide
`
`variable control of multiple light sources to improve a similar video projector
`
`system (e.g., the projector of Takanashi) in the same way.
`
`–13–
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`XLNX-1011
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`34.
`
`It is my opinion that a person of ordinary skill in the art would find
`
`that Takanashi in view of Lee and Miyashita renders obvious each and every
`
`element of claims 15 and 16.
`
`Claim No.
`
`Claim 15
`
`[15.0] The video
`projector system of
`claim 2, wherein
`the
`three
`color
`filters comprise one
`each of red, green,
`and blue filters, and
`wherein the video
`projector
`system
`further comprises:
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`Takanashi teaches a video projector system that utilizes three
`parallel beams of light:
`Next, in the spatial light modulator shown in FIG.
`17, the unpolarized light radiated from the light
`source LS is changed into the linearly polarized
`light by the polarizer PL1 and sent to the three color
`separation system 11.
`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 10 separation optical system 11 is
`incident on the liquid 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.
`(Takanashi at 16:1-14.)
`Lee also teaches a video projector system that utilizes three
`parallel beams of light. Lee also teaches that the individual
`beams of light pass through one of a red, green, or blue filter.
`[I]n the second embodiment, a white light source
`is used as the light source and so, in order to
`obtain the respective light beams of the colors
`red, green and blue, filters of the colors red 28R,
`green 28G, and blue 28B are disposed between the
`focusing lenses 15R, 15G, 15B and the light
`shutters 14R, 14G, 14B.
`
`–14–
`
`XLNX-1011
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`(Lee at 4:15-20.) This is illustrated in Figure 2, reproduced
`below:
`
`Color Filters
`
`White-
`Light
`Sources
`
`(Lee, Fig. 2.)
`
`second
`a
`[15.1]
`adapted
`controller
`to control the three
`white-light sources;
`and
`
`Lee teaches a video projector system that includes a lamp
`controller that controls three white-light sources:
`This system shown in FIG. 1 is such that three
`unicolor light sources 16R, 16G, 16B, e.g. three
`lamps 15 which emit three sources of the lights red,
`green and blue are connected to a lamp voltage
`controlling circuit 18 so as to change the light
`intensity emitted from a respective light source.
`(Lee at 3:14-19 (emphasis added).)
`The second embodiment of FIG. 2 is nearly the
`same as the first embodiment of FIG. 1. The same
`reference numbers there between are given to the
`same parts. Description of the same parts will be
`omitted.
`The difference between the first and second
`embodiments is that, in the second embodiment, a
`white light source is used as the light source and
`
`–15–
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`XLNX-1011
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`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`so, in order to obtain the respective light beams of
`the colors red, green and blue, filters of the colors
`red 28R, green 28G, and blue 28B are disposed
`between the focusing lenses 15R, 150, 15B and the
`light shutters 14R, 140, 14B.
`(Lee at 4:10-20 (emphasis added).)
`Figure 2 in Lee shows the lamp controller (controller 18) that
`is connected to three individual white-light sources:
`
`Lamp Controller
`
`White-
`Light
`Sources
`
`(Lee, Fig. 2 (annotated).)
`Combining a lamp controller that allows for variable control
`of multiple light sources such as controller 18 in Lee with
`multiple light sources such as those used in Takanashi’s
`projector would have been obvious to a person of ordinary
`skill in the art. Both Lee and Takanashi teach the use of
`multiple parallel
`light
`sources
`in a projector
`system.
`Combining a lamp controller such as that taught in Lee to the
`multiple light sources in Takanashi would have been nothing
`more than the use of a known technique for individually
`controlling multiple light sources (e.g., the controller in Lee)
`in a projector (e.g., the projector in Takanashi) to improve
`the projector system in the same way.
`
`–16–
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`XLNX-1011
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`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`control
`a
`[15.2]
`adapted
`to
`link
`connect
`the video
`controller
`to
`the
`second controller
`
`Miyashita teaches a control link adapted to connect a video
`controller to a second controller (e.g., lamp controller). The
`lamp controller 72 taught by Miyashita includes circuitry that
`controls a lamp. The lamp is connected to a video controller
`(e.g., control unit 32) by a control link (e.g., I/O port 93). In
`one embodiment shown in Figure 2, functionality of a video
`controller is carried out by at least picture controller 42 and
`display controller 50:
`When LCVP 30 is first turned on, the projection
`lamp may not start right away. If the light detector
`66 senses no light, a number of retries will be
`attempted by the power controller 38 via projection
`lamp power controller 72. A failure of the lamp to
`start after a preset number or retries is stored in the
`memory 80 and is also sent to the display 62 via the
`display controller 50. . . . Several sources of signals
`may be selected by the signal controller 40 and
`signal source selector 74. The signal selection is
`responsive to the instruction decoder 36. For
`example, selections among camera, VCR, and
`broadcast signal input sources can be made. The
`picture controller 42 is also responsive to the
`instruction decoder 36 and provides control to
`set the level of the picture attributes of color,
`hue,
`brightness,
`contrast,
`and
`sharpness
`(peaking). The level of each of
`these picture
`attributes is provided as digital output to the DAC
`84 and stored in the memory 80. . . . The display
`controller 50 supports the display 62 and the
`combination provides a visual status of
`the
`power controller 38,
`selected signal
`source,
`picture attribute levels, sound volume level, and
`lens control information.
`(Miyashita at 4:43-5:16.) In Figure 2, the picture controller
`and the display control are included with other controllers in
`system 32:
`
`–17–
`
`XLNX-1011
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`Video
`Controllers
`
`In the embodiment show in Figure 3, the various controllers
`in system 32,
`including picture controller 42 and video
`controller 50, are implemented in a microprocessor system.
`Thus, the functionality of a video controller is carried out by
`the microprocessor system:
`FIG.
`3
`is
`exemplary microprocessor-based
`implementation of LCVP 30. The functions of
`control unit 32 are all
`implemented by a
`microprocessor
`system.
`Several
`computer-
`implemented processes (programs) are used to
`replace the functional units described above. The
`important parts of each program are described
`below,
`in detail. The microprocessor
`system
`comprises a central processing unit (CPU) 90, a
`read only memory (ROM). . . . Digital interfaces
`are made via the I/O port 93 to control input 60;
`display 62, an alarm 64,
`light detector 66,
`temperature detector, 68, main power controller 70,
`projection lamp power controller 72, signal source
`selector 74, fan motor controller 76, fan motor 78,
`
`–18–
`
`XLNX-1011
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`memory 80, lens controller 82, and DAC 84.
`(Miyashita at 5:21-41 (emphasis added).) As shown below,
`the video controller is included in the microprocessor system
`that is connected to the lamp controller via the control link.
`
`Video
`Controller
`
`Lamp
`Controller
`
`Control
`Link
`
`(Miyashita, Fig. 3 (annotated).) Thus, Miyashita teaches a
`video controller that is connected to a second controller or
`lamp controller by a control link.
`Combining a control link that connects a lamp controller and
`a video controller such as that taught by Miyashita with a
`video projector system such as those taught by Takanashi
`and Lee would have been obvious to a person of ordinary
`skill in the art. Miyashita teaches a control link that connects
`a video controller to a lamp controller. Lee teaches control
`lines that connect a lamp controller to three individual light
`sources. Including a control link between a lamp controller
`
`–19–
`
`XLNX-1011
`
`
`
`Claim No.
`
`[15.2.1] to provide
`individualized
`variable control of
`each of
`the three
`white-light sources.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`and a video controller such as that taught by Miyashita with
`video projector systems such as those in Takanashi and Lee
`would have been nothing more than using a known technique
`of connecting a video controller to a lamp controller to
`improve similar projector systems (e.g., the projectors of
`Takanashi and Lee) in the same way.
`
`individualized
`that provides
`lines
`Lee teaches control
`variable control of each of the three white-light sources:
`This system shown in FIG. 1 is such that three
`unicolor light sources 16R, 16G, 16B, e.g. three
`lamps 15 which emit three sources of the lights red,
`green and blue are connected to a lamp voltage
`controlling circuit 18 so as to change the light
`intensity emitted from a respective light source.
`(Lee at 3:14-19 (emphasis added).)
`The second embodiment of FIG. 2 is nearly the
`same as the first embodiment of FIG. 1. The same
`reference numbers there between are given to the
`same parts. Description of the same parts will be
`omitted.
`The difference between the first and second
`embodiments is that, in the second embodiment, a
`white light source is used as the light source and
`so, in order to obtain the respective light beams of
`the colors red, green and blue, filters of the colors
`red 28R, green 28G, and blue 28B are disposed
`between the focusing lenses 15R, 150, 15B and the
`light shutters 14R, 140, 14B.
`(Lee at 4:10-20 (emphasis added).)
`Figure 2 in Lee shows the second controller (controller 18)
`that is connected to three individual white-light sources:
`
`–20–
`
`XLNX-1011
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`Second Controller
`
`Control
`Lines
`
`(Lee, Fig. 2 (annotated).)
`Combining control lines from a lamp controller to individual
`light sources that provides individualized variable control of
`each light source with a projector such as a projector as
`taught in Takanashi would have been obvious to a person of
`ordinary skill in the art. Both Lee and Miyashita teach lamp
`controllers that provide control over light sources. Further
`both Lee and Takanashi teach multiple light sources and Lee
`teaches that a lamp controller can be used to provide variable
`control of each individual
`light source via control
`lines.
`Using a lamp controller to control each individual
`light
`source such as that taught in Lee with a projector such as that
`of Takanashi would have been nothing more than the use of a
`known technique of using a controller to control individual
`light sources to improve a similar projector in the same way.
`
`See discussion of claim 11 in Petition for Inter Partes
`Review, paper no. 2, at 35-36.
`
`–21–
`
`XLNX-1011
`
`Claim 16
`
`[16.0] The video
`projector system of
`claim 11,
`further
`comprising:
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`second
`a
`[16.1]
`adapted
`controller
`to
`control
`the
`source; and
`
`Lee teaches a video projector system that includes a lamp
`controller adapted to control white-light sources:
`This system shown in FIG. 1 is such that three
`unicolor light sources 16R, 16G, 16B, e.g. three
`lamps 15 which emit three sources of the lights red,
`green and blue are connected to a lamp voltage
`controlling circuit 18 so as to change the light
`intensity emitted from a respective light source.
`(Lee at 3:14-19 (emphasis added).)
`The second embodiment of FIG. 2 is nearly the
`same as the first embodiment of FIG. 1. The same
`reference numbers there between are given to the
`same parts. Description of the same parts will be
`omitted.
`The difference between the first and second
`embodiments is that, in the second embodiment, a
`white light source is used as the light source and
`so, in order to obtain the respective light beams of
`the colors red, green and blue, filters of the colors
`red 28R, green 28G, and blue 28B are disposed
`between the focusing lenses 15R, 150, 15B and the
`light shutters 14R, 140, 14B.
`(Lee at 4:10-20 (emphasis added).)
`Figure 2 in Lee shows the lamp controller (controller 18) that
`is connected to individual white-light sources:
`
`–22–
`
`XLNX-1011
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`Lamp Controller
`
`White-Light
`Sources
`
`(Lee, Fig. 2 (annotated).)
`Combining a lamp controller that allows for control of light
`sources such as controller 18 in Lee with a light source such
`as that in Takanashi’s projector would have been obvious to
`a person of ordinary skill in the art. Both Lee and Takanashi
`teach the use of
`light sources in a projector system.
`Combining a lamp controller such as that taught in Lee to the
`light source in Takanashi would have been nothing more
`than the use of a known technique for controlling a light
`source (e.g., the controller in Lee) with a light source of
`Takanashi’s
`video
`projector
`to
`improve Takanashi’s
`projector system in the same way.
`
`Miyashita teaches a control link adapted to connect a video
`controller to a second controller (e.g., lamp controller). The
`lamp controller 72 taught by Miyashita includes circuitry that
`controls a lamp. The lamp is connected to a video controller
`(e.g., control unit 32) by a control link (e.g., I/O port 93). In
`one embodiment shown in Figure 2, functionality of a video
`controller is carried out by at least picture controller 42 and
`display controller 50:
`When LCVP 30 is first turned on, the projection
`
`–23–
`
`XLNX-1011
`
`control
`a
`[16.2]
`adapted
`to
`link
`connect
`the video
`controller
`to
`the
`second controller
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`lamp may not start right away. If the light detector
`66 senses no light, a number of retries will be
`attempted by the power controller 38 via projection
`lamp power controller 72. A failure of the lamp to
`start after a preset number or retries is stored in the
`memory 80 and is also sent to the display 62 via the
`display controller 50. . . . Several sources of signals
`may be selected by the signal controller 40 and
`signal source selector 74. The signal selection is
`responsive to the instruction decoder 36. For
`example, selections among camera, VCR, and
`broadcast signal input sources can be made. The
`picture controller 42 is also responsive to the
`instruction decoder 36 and provides control to
`set the level of the picture attributes of color,
`hue,
`brightness,
`contrast,
`and
`sharpness
`(peaking). The level of each of
`these picture
`attributes is provided as digital output to the DAC
`84 and stored in the memory 80. . . . The display
`controller 50 supports the display 62 and the
`combination provides a visual status of
`the
`power controller 38,
`selected signal
`source,
`picture attribute levels, sound volume level, and
`lens control information.
`(Miyashita at 4:43-5:16.) In Figure 2, the picture controller
`and the display control are included with other controllers in
`system 32:
`
`–24–
`
`XLNX-1011
`
`
`
`Claim No.
`
`Challenge #4: Takanashi, Lee, and Miyashita
`
`Video
`Controllers
`
`In the embodiment show in Figure 3, the various controllers
`in system 32,
`including picture controller 42 and video
`controller 50, are implemented in a microprocessor system.
`Thus, the functionality of
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