IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re patent of Kikinis
`
`U.S. Patent No. 5,632,545
`
`Issued: May 27, 1997
`
`Title: ENHANCED VIDEO
`PROJECTION SYSTEM
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Petition for Inter Partes Review
`
`Attorney Docket No.: 42299.41
`Customer No.:
`27683
`Real Party in Interest: Xilinx, Inc.
`
`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 5,632,545 (“the ’545 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 ’545 Patent, XLNX-1001;
`
`(2) The file history of the ’545 Patent, XLNX-1008;
`
`IVI LLC EXHIBIT 2017
`XILINX V. IVI LLC
`Case IPR2013-00112
`
`–1–
`
`
`
`In re patent of Kikinis
`
`U.S. Patent No. 5,632,545
`
`Issued: May 27, 1997
`
`Title: ENHANCED VIDEO
`PROJECTION SYSTEM
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Petition for Inter Partes Review
`
`Attorney Docket No.: 42299.41
`Customer No.:
`27683
`Real Party in Interest: Xilinx, Inc.
`
`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 5,632,545 (“the ’545 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 ’545 Patent, XLNX-1001;
`
`(2) The file history of the ’545 Patent, XLNX-1008;
`
`IVI LLC EXHIBIT 2017
`XILINX V. IVI LLC
`Case IPR2013-00112
`
`–1–
`
`
`
`(3) U.S. Patent No. 5,108,172 (“Flasck”), XLNX-1002;
`
`(4) U.S. Patent No. 5,287,131 (“Lee”), XLNX-1004;
`
`(5) U.S. Patent No. 5,692,821 (“Rodriguez”), XLNX-1009;
`
`(6) U.S. Patent No. 5,313,234 (“Edmonson”), XLNX-1010; and
`
`(7) U.S. Patent No. 5,136,397 (“Miyashita”), XLNX-1011.
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`(1) The documents listed above,
`
`(2) 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
`
`1.
`
`My qualifications are set forth in my curriculum vitae, a copy of
`
`which is provided as Exhibit XLNX-1007. As set forth in my curriculum vitae, I
`
`have over 44 years of experience in Electrical Engineering, including optical
`
`engineering.
`
`2.
`
`My 44 years of experience in optical engineering includes over 15
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`–2–
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`
`
`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 ’545 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 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.
`
`3.
`
`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
`
`–3–
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`
`
`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
`
`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.
`
`4.
`
`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.
`
`5.
`
`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
`
`–4–
`
`
`
`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
`
`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 ’545 Patent.
`
`6.
`
`In my opinion, the level of ordinary skill in the art for the ’545 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
`
`7.
`
`I have been asked to provide my opinions regarding whether the
`
`claims of the ’545 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
`
`–5–
`
`
`
`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.
`
`8.
`
`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 ’545 Patent is set
`
`forth below.
`
`Background Of ’545 Patent
`
`9.
`
`The ’545 Patent relates to an “Enhanced Video Projection System.”
`
`(’545 Patent, Title) Specifically, the ’545 Patent teaches a system that combines
`
`–6–
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`
`
`separate light beams into an enhanced projectable beam wherein the color spots are
`
`superimposed, rather than side-by-side. (’545 Patent, Abstract.) To do this, the
`
`’545 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 id. at 1:64-65.) The
`
`Figure 1 from the ’545 illustrates this system:
`
`10.
`
`The light sources and a fan are controlled by a controller. (Id. at 2:52-
`
`54.) Both the light sources and the fan are included in a separate heat containment
`
`system sub-unit. (Id. at 2:55-59.) The heat containment sub-unit also includes heat
`
`filter glass by which the light generated by the light sources leaves the heat
`
`containment sub-unit. (Id.)
`
`11.
`
`In the Patent Owner’s Motion to Amend filed June 26, 2013, the
`
`Patent Owner canceled claims 2 and 3 and proposed claims 4 and 5, reproduced
`
`–7–
`
`
`
`below:
`
`4. (Proposed substitute for Claim 2) The video projection projector system
`
`of claim 1 wherein the light-shutter matrices are monochrome LCD arrays,
`
`and wherein the video projector system further comprises:
`
`a heat containment system, wherein the heat containment system
`
`comprises an enclosure that isolates components in the heat containment
`
`system from other components of the video projector system, and wherein
`
`the heat containment system includes:
`
`the individual light sources;
`
`heat filter glass adapted to filter heat from the separate light
`
`beams as the separate light beams pass through the heat filter glass
`
`and exit the heat containment system; and
`
`a fan in communication with an outside environment, wherein
`
`the fan is adapted to force heat generated by the individual light
`
`sources and heat filtered by the heat filter glass into the outside
`
`environment;
`
`a second controller adapted to control the individual light sources and
`
`the fan; and
`
`a control link adapted to connect the video controller to the second
`
`–8–
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`
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`controller to provide individualized variable control of each of the individual
`
`light sources.
`
`5. (Proposed substitute for Claim 3) The video projector system of claim 1
`
`wherein three light sources provide three beams, and red, green, and blue
`
`filters are used to provide red, green, and blue beams to an LCD matrix
`
`system, and wherein the video projector system further comprises:
`
`a heat containment system, wherein the heat containment system
`
`comprises an enclosure that isolates components in the heat containment
`
`system from other components of the video projector system, and wherein
`
`the heat containment system includes:
`
`the individual light sources;
`
`heat filter glass adapted to filter heat from the separate light
`
`beams as the separate light beams pass through the heat filter glass
`
`and exit the heat containment system; and
`
`a fan in communication with an outside environment, wherein
`
`the fan is adapted to force heat generated by the individual light
`
`sources and heat filtered by the heat filter glass into the outside
`
`environment;
`
`a second controller adapted to control the individual light sources and
`
`–9–
`
`
`
`the fan; and
`
`a control link adapted to connect the video controller to the second
`
`controller to provide individualized variable control of each of the individual
`
`light sources.
`
`12. None of the limitations in proposed claim 4 and 5 appear in the claims
`
`that were presented during prosecution of the application that led to the ’545
`
`Patent.
`
`Claim Construction
`
`13.
`
`It is my understanding that in order to properly evaluate the proposed
`
`claims of the ’545 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.
`
`14.
`
`In order to construe the claims, I have reviewed the entirety of the
`
`’545 Patent, as well as its prosecution history.
`
`“heat filter glass”
`
`15.
`
`The specification does not provide any specific definition for “heat
`
`–10–
`
`
`
`filter glass.”
`
`16.
`
`The specification does, however, describes that light sources are kept
`
`within a heat containment sub-unit and light from the light sources “leaves the heat
`
`containment system 131 via heat filter glass 123.” (Id. at 2:58-59.)
`
`17.
`
`It is my opinion that a person of ordinary skill in the art would
`
`understand the broadest reasonable interpretation of “heat filtered glass” in view of
`
`the specification and file history to be: “transparent material that blocks or absorbs
`
`the passage of infrared radiation.”
`
` “fan in communication with an outside environment”
`
`18.
`
`The specification describes a fan but not a “fan in communication
`
`with an outside environment.” According to the specification, a heat containment
`
`system “exchang[es] heat via fan 136 to the outside.” (Id. at 2:57-58.) As seen in
`
`Figure 1, fan 136 is positioned at an edge of the heat containment system. (See fan
`
`136 in Fig. 1, reproduced below.)
`
`–11–
`
`
`
`Fan
`
`19.
`
`It is my opinion that a person of ordinary skill in the art would
`
`understand the broadest reasonable interpretation of “fan in communication with
`
`an outside environment” in view of the specification and file history to be: “a fan
`
`that circulates a fluid such as air between two separate spaces.”
`
`“second controller”
`
`20.
`
`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.” (Id. at 2:52-
`
`54.)
`
`21.
`
`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
`
`–12–
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`
`
`the specification and file history to be: “one or more control circuits separate from
`
`the video controller.”
`
`“control link”
`
`22.
`
`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
`
`3:35-37.)
`
`23.
`
`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 #5: Claims 4 and 5 are obvious over Flasck in view of
`
`Rodriguez, Lee, and Miyashita.
`
`24.
`
`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 an LCD projector such as
`
`that of Flask with a heat containment system such as that of Rodriguez and second
`
`controllers and control links such as those of Miyashita and Lee. Such a
`
`–13–
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`
`
`combination would have been nothing more than the use of known techniques
`
`taught by Rodriguez, Lee, and Miyashita to improve Flasck’s similar LCD
`
`projector in the same way.
`
`25.
`
`Flasck teaches an LCD projector, (see Flasck, 2:41-45), that includes
`
`embodiments with three individual light sources. (See id. at 7:58-64; id. at Fig. 11.)
`
`Flasck also teaches that heat is deleterious to an LCD panel, (id. at 4:36-28), and
`
`provides a heat absorbing glass plate that absorbs heat generated by the individual
`
`light sources. (Id. at 8:54-56.)
`
`26. Rodriguez also teaches an LCD projector. (See Rodriguez, 3:35-44.)
`
`Similar to the teachings of Flasck, Rodriguez discloses the importance of
`
`managing heat in the LCD projector system. (Id. at 2:26-37.) To manage heat in
`
`the LCD projector, Rodriguez teaches a duct that acts as a heat containment
`
`system. (Id. at 2:47-49; Id. at 6:4-42.) The heat containment system of Rodriguez
`
`uses heat filter glass similar to that used in Flasck to absorb the heat generated by
`
`the light source. (See id. at 6:38-42.) Rodriguez’s heat management system also
`
`includes a fan that exchanges air with an outside environment. (Id. at 6:34-40.)
`
`27.
`
`Lee also teaches an LCD projector. (See Lee, Abstract.) The LCD
`
`projector of Lee is similar to the LCD projector of Flasck in that Lee’s LCD
`
`projector 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
`
`–14–
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`
`
`allows for changes to light intensity emitted from each respective light source. (Id.)
`
`28. Miyashita also teaches an LCD projector. (Miyashita, Abstract.)
`
`Miyashita’s projector includes a second controller with light control circuitry and
`
`fan control circuitry. (See [4.2], below.) The fan control circuitry provides for
`
`variable fan speeds that force air through the projector to keep it from overheating.
`
`(Id. at 4:54-56.) Miyashita also teaches a control link that connects the second
`
`controller 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).
`
`29.
`
`It is my opinion that it would have been obvious to a person of
`
`ordinary skill in the art to combine the prior art element of a heat containment
`
`system such as the one used in Rodriguez’s LCD projector with an LCD projector
`
`such as the one taught in Flasck. Both Flasck and Rodriguez teach reducing heat in
`
`an LCD projector by placing heat absorbing glass between a light source and an
`
`LCD matrix. Rodriguez further teaches that the heat absorbing glass can be used in
`
`conjunction with a heat containment system that encloses the light source and
`
`exhausts the heat produced by the light source using a fan. Combining a heat
`
`containment system such as that taught in Rodriguez with an LCD projector with
`
`multiple light sources such as the LCD projector of Flasck would have been
`
`nothing more than the use of a known technique of reducing heat by enclosing a
`
`–15–
`
`
`
`light source in a separate enclosure to improve a similar LCD projector (e.g.,
`
`Flasck’s projector) in the same way.
`
`30.
`
`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 second controller that
`
`provides variable control of three light sources (e.g., as in Lee’s projector) and a
`
`second controller that controls a light source and a fan (e.g., as in Miyashita’s
`
`projector) with an LCD projector as taught in Flasck. Flask and Lee each teach an
`
`LCD projector with three individual light sources. Lee and Miyashita each teach a
`
`second controller that controls a light source. Miyashita teaches that the second
`
`controller can also be used to control a fan. Combining a second controller as
`
`taught in Lee and a second controller as taught in Miyashita to provide control of
`
`individual light sources and a fan would have been nothing more than the use of
`
`known techniques of using controllers to control lights and a fan (e.g., the second
`
`controllers of Lee and Miyashita) to improve a similar LCD projector (e.g., the
`
`projector of Flasck) in the same way.
`
`31.
`
`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 control link that
`
`connects a second controller to light sources to provide variable control of the light
`
`sources (e.g., as in Lee’s projector) and a control link that connects a second
`
`controller with a video controller (e.g., as in Miyashita’s projector) with an LCD
`
`–16–
`
`
`
`projector as taught in Flasck. Flask, Lee, and Miyashita each teach a video
`
`controller connected to an LCD array. Flask and Lee each teach an LCD projector
`
`that includes three individual light sources. Lee and Miyashita each teach a second
`
`controller that controls a light source. Lee teaches that the second controller can
`
`provide variable control of each individual light source. Combining a control link
`
`as taught in Lee and a control link as taught in Miyashita to a control link that
`
`connects a video controller to a second controller and provide variable control of
`
`individual light sources would have been nothing more than the use of known
`
`techniques of connecting a second controller that controls individual light sources
`
`to a video controller (e.g., the second controllers of Lee and Miyashita) to improve
`
`a similar LCD projector (e.g., the projector of Flasck) in the same way.
`
`32.
`
`It is my opinion that a person of ordinary skill in the art would find
`
`that Flasck in view of Rodriguez, Lee, and Miyashita renders obvious each and
`
`every element of claims 4 and 5.
`
`Claim
`
`Claim 4
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`
`[4.0] The video
`projector system
`of
`claim
`1
`wherein the light-
`shutter matrices
`are monochrome
`LCD arrays, and
`
`Flasck teaches a video projection system with light-shutter
`matrices that are monochrome LCD arrays. For example, in
`Flasck, each active matrix is preferably an LCD matrix:
`The reflective image plane module 30 includes a . . .
`wafer based active matrix 46. . . . The wafer based
`active matrix is covered by an LCD or similar
`characteristic material, such as an electrophoretic
`
`–17–
`
`
`
`Claim
`wherein the video
`projector system
`further comprises:
`
`heat
`
`a
`[4.1]
`containment
`system, wherein
`the
`heat
`containment
`system comprises
`an enclosure that
`isolates
`components
`the
`containment
`system from other
`components
`of
`the
`video
`projector system,
`and wherein the
`heat containment
`system includes:
`
`in
`heat
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`material.
`(Flasck, 5:11-26 (emphasis added).)
`Each LCD matrix is aligned in its respective image plane and
`is used for only one color of light. This is evident by Flasck
`further teaching that each reflective image plane module may
`be used in a monochrome projection system:
`Each of the above reflective image plane modules
`can be utilized as part of a monochrome projection
`system . . . .
`(Flasck, 6:65-66 (emphasis added).)
`Thus, Flasck
`teaches
`light-shutter matrices
`monochrome LCD arrays. (See Buckman ¶ 28.)
`
`that are
`
`Flasck teaches a video projector system that includes a heat
`filter glass component that separates the heat generated by the
`three lights from the LCD arrays:
`A first projection system embodiment of the present
`invention
`is
`illustrated
`in FIG. 16, designated
`generally by
`the reference numeral 170. The
`projection system 170 includes a light source 172,
`which preferably includes a reflector 174. A light
`beam 176 is directed through an optional heat
`absorbing glass plate 178 to a condenser lens or
`lens combination 180.
`(Flasck, 8:50-56 (emphasis added).)
`The heat filter glass of Flasck is shown below in Figure 16:
`
`–18–
`
`
`
`Claim
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`
`Heat Filter Glass
`
`(Flasck, Fig. 16 (annotated).)
`Rodriguez further enhances Flasck by teaching a video
`projector with a heat containment system that comprises an
`enclosure that isolates components in the heat containment
`system from other components of the video projector system:
`A thermal management system is for utilization in a
`compact display device. A duct is provided within
`the lamp housing of the display device and a high-
`wattage light source is mounted within the duct.
`Multiple cooling fins are mounted to at least one
`inner surface of the duct and extend into the duct. A
`thermal radiation absorbent coating, such as black
`anodization, covers the interior of the duct and the
`cooling fins and provides for an increased surface
`absorption of thermal radiation. A port within the
`duct, which is transparent to visible light, is
`utilized to direct visible light through a display
`
`–19–
`
`
`
`Claim
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`assembly. An infrared filter, which is reflective or
`absorptive of infrared radiation, such as a so-
`called "hot mirror" is utilized to maintain thermal
`radiation within the duct and a fan is then utilized
`to pass cooling fluid through the duct, passing the
`cooling fluid over the cooling fins and removing
`thermal energy from the display device in a highly
`efficient manner.
`(Rodriguez, Abstract (emphasis added).)
`The heat containment system taught by Rodriguez is a separate
`enclosure that isolates components in the heat containment
`system from other components:
`Referring now to FIGS. 2A and 2B, there are
`depicted longitudinal cross-sections of projector 10
`depicting
`its storage/transportation state and
`its
`deployed state, respectively, which illustrate that
`projector 10 is additionally comprised of a light
`source 30 which is mounted within generally
`rectangular duct 32. As illustrated, two of the inner
`surfaces of generally rectangular duct 32 include a
`plurality of cooling
`fins 33.
`In a preferred
`embodiment of the present invention, the inner
`surface of duct 32 and the surface of each cooling fin
`33 is coated with a thermal radiation absorbent
`coating such as a black anodization or black
`oxidation in a manner well-known in the prior art.
`(Rodriguez, 3:55-66 (emphasis added).)
`Figure 2A shows an example of the isolating nature of duct 32,
`Rodriguez’s heat containment system:
`
`–20–
`
`
`
`Claim
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`
`Heat Containment System
`
`(Rodriguez, Fig. 2A (annotated).)
`Combining a heat containment system such as that of
`Rodriguez with the LCD projector of Flasck would have been
`obvious to a person of ordinary skill in the art. Both Flasck and
`Rodriguez teach placing heat filter glass (as shown below in
`[4.1.2]) between a light source and an LCD array. Thus, a
`person of ordinary skill in the art would look to modify Flasck
`by including a heat containment system such as that taught in
`Rodriguez to further insulate the LCD array from the heat of
`the light sources by enclosing the light sources in a
`containment system. Replacing the heat filter glass of Flack’s
`LCD projector with a heat containment system that includes
`heat filter glass such as that taught in Rodriguez would have
`been nothing more than the use of a known technique of
`enclosing a light source in order to control heat to improve a
`similar LCD projector in the same way.
`
`Flasck teaches individual light sources:
`The color projection system 142 again includes the
`three color reflective image plane modules 92,
`104, and 112, but each reflective image plane
`module now includes its own light source 144, 146,
`and 148. The separate light sources again require
`the respective B, G, and R filters 124, 126 and 128
`
`–21–
`
`[4.1.1]
`individual
`sources;
`
`the
`light
`
`
`
`Claim
`
`[4.1.2] heat filter
`glass adapted to
`filter heat from
`the separate light
`beams
`as
`the
`separate
`light
`beams
`pass
`through the heat
`filter glass and
`exit
`the
`heat
`containment
`system; and
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`to provide the B, G, and R light components.
`(Flasck, 7:60-66 (emphasis added).)
`In Rodriguez, the light source is contained within the heat
`containment system:
`. . . projector 10 is additionally comprised of a light
`source 30 which is mounted within generally
`rectangular duct 32.
`(Rodriguez, 3:58-60 (emphasis added).)
`It would have been obvious to a person of ordinary skill in the
`art to include individual light sources such as those of Flasck
`in a heat containment system such as that of Rodriguez to
`further manage heat control within the system of Flasck.
`Replacing a single lamp such as that in Rodriguez with three
`lights as taught in Flasck would have been nothing more than a
`simple substitution of one known element for another to obtain
`predictable results. Further, it would have been nothing more
`than a use of a known technique to improve a similar LCD
`projector in the same way.
`
`Flasck teaches a video projector system that includes heat filter
`glass that separates the heat generated by the three lights from
`the LCD arrays:
`A first projection system embodiment of the present
`invention
`is
`illustrated
`in FIG. 16, designated
`generally by
`the reference numeral 170. The
`projection system 170 includes a light source 172,
`which preferably includes a reflector 174. A light
`beam 176 is directed through an optional heat
`absorbing glass plate 178 to a condenser lens or
`lens combination 180.
`(Flasck, 8:50-56 (emphasis added).)
`The heat filter glass of Flasck is shown below in Figure 16:
`
`–22–
`
`
`
`Claim
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`
`Heat Filter Glass
`
`(Flasck, Fig. 16 (annotated).) While Fig. 16 shows one light
`source, a person of ordinary skill in the art would understand
`that the single light source illustration of Fig. 16 describes one
`of the three light sources that can be used in an LCD projector.
`Rodriguez teaches a heat containment system (e.g., duct 32)
`that not only includes heat filter glass similar to that used in
`Flasck but also includes a light source and a fan adapted to
`direct heat produced by the light source out of the containment
`system.
`As further illustrated within FIG. 4, a cooling fan 72
`is mounted to one end of duct 32 and is utilized to
`draw cooling fluid through duct 32, eliminating
`excessive heat within duct 32 by passing that cooling
`fluid over the surface of cooling fins 38 and the inner
`surface of duct 31. Further, a port is provided
`within one surface of duct 32 which is transparent
`to visible light. That port is filled with infrared
`
`–23–
`
`
`
`Claim
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`filter 38 which, as described above, may be
`provided utilizing a conventional hot mirror.
`(Rodriguez, 6:34-43 (emphasis added).)
`Figure 4 offers an example of Rodriguez’s heat containment
`system that includes infrared filter 38 (i.e., heat filter glass).
`
`Heat Filter Glass
`
`(Rodriguez, Fig. 4 (annotated).)
`Both Flasck and Rodriguez teach the use of heat filter glass
`and the importance of regulating heat in an LCD projector.
`Consistent with the proposed combination in [4.1], including a
`heat containment system like the one taught by Rodriguez with
`an LCD projector with three individual light sources like that
`taught in Flasck would result a heat containment system with
`three individual light sources where the light from each light
`source passes through heat filter glass.
`
`[4.1.3] a fan in
`communication
`with an outside
`environment,
`
`Rodriguez teaches a heat containment system (e.g., duct 32)
`that includes a fan in communication with an outside
`environment where the fan is adapted to force heat generated
`by the individual light sources and heat filtered by the heat
`
`–24–
`
`
`
`Claim
`wherein the fan is
`adapted to force
`heat generated by
`the
`individual
`light sources and
`heat filtered by
`the heat
`filter
`glass
`into
`the
`outside
`environment;
`
`Challenge #5: Flasck, Rodriguez, Lee, and Miyashita
`filter glass into the outside environment.
`As further illustrated within FIG. 4, a cooling fan
`72 is mounted to one end of duct 32 and is utilized
`to draw cooling fluid through duct 32, eliminating
`excessive heat within duct 32 by passing that cooling
`fluid over the surface of cooling fins 38 and the inner
`surface of duct 31. Further, a port is provided within
`one surface of duct 32 which is transparent to visible
`light. That port is filled with infrared filter 38 which,
`as described above, may be provided utilizing a
`conventional hot mirror.
`(Rodriguez, 6:34-43 (emphasis added).)
`Figure 4 offers an example of Rodriguez’s heat containment
`system that includes fan 72.
`
`Fan 72
`
`(Rodriguez, Fig. 4 (annotated).)
`As shown in Figure 3, fan 72 in Rodriguez’s heat containment
`system is positioned to force
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