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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re patent of Kikinis
`
`US Patent No. 5,632,545
`
`Issued: May 27, 1997
`
`Title: ENHANCED VIDEO
`
`PROJECTION SYSTEM
`
`Exhibit XLNX—I 006
`
`accompanying
`Petition for Inter Partes Review
`
`Attorney Docket No.:
`Customer No.:
`
`42299.41
`27683
`
`Real Party in Interest: Xilinx, Inc.
`
`¢O°<00€0¢103503<00003007Q0¢
`
`Declaration of A. Bruce Buckman, Ph.D.
`
`Under 37 C.F.R. § 1.68
`
`I, Dr. A. Bruce Buckman, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Xilinx in the matter of
`
`the Inter Petites Review of US 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-IOOI;
`
`(2)
`
`US Patent No. 5,108,172 (“Flasck”), XLNX—1002;
`
`(3)
`
`US Patent No. 5,264,951 (“Takanashi”), XLNX-1003;
`
`(4)
`
`US Patent No. 5,287,131 (“Lee”), XLNX~1004; and
`
`(5)
`
`US Patent No. 5,784,038 (“Irwin”), XLNX-IOOS.
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`«1—
`
`IVI LLC EXHIBIT 2020
`IVI LLC EXHIBIT 2020
`XILINX V. IVI LLC
`XILINX V. IVI LLC
`Case IPR2013-00112
`Case IPR2013-00112
`
`

`

`(l)
`
`The documents listed above,
`
`(2)
`
`The relevant legal standards, including the standard for obviousness
`
`provided in KSR International Co. v. Teleflex, Inc., 550 US. 398 (2007), and
`
`any additional authoritative documents as cited in the body of this
`
`declaration, and
`
`(3) My knowledge and experience based upon my work in this area as
`
`described below.
`
`Qualifications and Professional Experience
`
`5.
`
`My qualifications are set forth in my curriculum vitae, a copy of
`
`which is provided as Exhibit XLNX-1007. 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
`
`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 Photonz‘cs 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.
`
`7.
`
`I am familiar with the knowledge and capabilities one of ordinary skill
`
`in the optical design arts in the period around 1996. Specifically, my work (I) with
`
`students, undergraduates as well as masters and PhD. candidates, (2) with
`
`colleagues in academia, and (3) with engineers practicing in industry allowed me
`
`to become personally familiar with the level of skill of individuals and the general
`
`state of the art. Unless otherwise stated, my testimony below refers to the
`
`knowledge of one of ordinary skill in the optical design arts during the l995~l997
`
`time period, including the priority date of the ’545 Patent.
`
`8.
`
`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 designing optical systems with off the shelf parts.
`
`Relevant Legal Standards
`
`9.
`
`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
`
`ordinary skill in the art to which the subject matter pertains.
`
`I also understand that
`
`the obviousness analysis takes into account factual inquiries including the level of
`
`ordinary skill in the art, the scope and content of the prior art, and the differences
`
`between the prior art and the claimed subject matter.
`
`10.
`
`It is my understanding that the Supreme Court has recognized several
`
`rationales for combining references or modifying a reference to show obviousness
`
`of claimed subject matter. Some 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
`
`11.
`
`The ’545 Patent relates to an “Enhanced Video Projection System.”
`
`(’545 Patent, Title) Specifically, the ’545 Patent teaches a system that combines
`
`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.
`
`(161.; see also ’545 Patent at 1:64—65)
`
`The following figure from the ’545 illustrates this system:
`
`

`

`
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`
`12.
`
`The ’545 Patent has three claims, which are reproduced below:
`
`1. A video projector system comprising:
`
`individual light sources, one each for each color to be projected,
`
`adapted to provide each a separate light beam;
`
`a lens system in the path of the separate light beams, adapted for
`
`focusing the beams;
`
`a number of individual color filters equal to the number of beams, in
`
`the colors to be projected, and placed one each in each beam path;
`
`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 matrices;
`
`and
`
`an optical combination system adapted for combining the several
`
`beams into a single composite beam for projection on a surface to
`
`provide a video display;
`
`wherein each beam passes through a color filter before being
`
`.5-
`
`

`

`processed by a light-switching matrix.
`
`2. The video projection system of claim 1 wherein the light—shutter
`
`matrices are monochrome LCD arrays.
`
`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.
`
`13.
`
`The application leading to the ’545 Patent was filed in July 1996. The
`
`Examiner issued a first action Notice of Allowability in November 1996,
`
`indicating that claims 1-3 (all the claims) were allowed. No reasons for allowance
`
`were stated. The ’545 Patent issued in May 1997.
`
`Summary Of Opinions
`
`14.
`
`In my opinion, the claims of the ’545 Patent would have been
`
`anticipated or obvious to a person having skill in the art in July 1996.
`
`15.
`
`By mid-1996, engineers already knew how to create a light-combining
`
`video projection system. For example, the “Flasck” reference, U.S. Patent No. US
`
`5,108,172 (XLNX — 1002), describes a system in which multiple light sources
`
`create light beams which pass through color filters and LCD arrays before being
`
`combined into a single projectable beam. Fig. 11 of the Flasck reference illustrates
`
`this system:
`
`

`

`
`
`#24
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`
`FIG. 11
`
`As shown above, Flasck uses multiple light sources to create red, green, and blue
`
`images. These images are then combined using a prism/mirror, and then projected
`
`onto a screen.
`
`I discuss Flasck in more detail below and explain why it anticipates
`
`or renders obvious the claims of the ’545 Patent.
`
`16.
`
`The “Takanashi” reference, US Patent No. 5,264,951 (XLNX-1003),
`
`describes a similar enhanced projection system.
`
`In Takanashi, a light source is
`
`used to create three beams of light, which pass through a color separator and a
`
`light-shutter matrix (comprising liquid crystal elements ECB, polarizing elements
`
`PL2, and spatial light modulation elements SLM) before being combined into a
`
`single image, as shown below:
`
`

`

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`Starting on the bottom left, Fig. 17 from Takanashi shows a light source that is
`
`separated into three separate light beams using the three-color separation optical
`
`system, effectively creating three separate light sources———one each for red, green
`
`and blue (R, G, and B, respectively). These colored light beams then pass through
`
`a light-shutter matrix (ECB elements, PL2 elements, and SLM elements) to create
`
`three image beams encoded with image information, which are then combined to
`
`create a single, enhanced projection video image.
`
`I discuss the Takanashi patent in
`
`more detail below and explain why it renders the claims of the ’545 Patent obvious
`
`in combination with the “Lee” reference, US Patent No. 5,287,131 (XLNX—1004),
`
`and the “Irwin” reference, US Patent No. 5,784,038 (XLNX-IOOS).
`
`Anticipation and Obviousness Of ’545 Patent In View Of Flasck
`
`17.
`
`The Flasck reference is entitled “Active Matrix Reflective Image
`
`Plane Module and Projection System.” Flasck was filed on September 24, 1990,
`
`

`

`claims priority to an application dated August 11, 1989, and issued on April 28,
`
`1992. It is my opinion that the claims of the ’545 Patent are anticipated or
`
`rendered obvious in View of Flasck for the reasons set forth below.
`
`Claim 1 .' A video projector system comprising:
`
`18.
`
`Flasck describes a “video projector system.” In The Background of
`
`the Invention, Flasck notes a desire “to replace existing TV and computer
`
`monitors” and describes the use of similar prior art devices to that end. (Flasck,
`
`1:36-37.) Flasck further notes that some markets “require very large, high
`
`resolution, full color and video speed imaging.” (Flasck, 2:27—29.) Flasck’s
`
`disclosure and invention were directed to projection systems for both video and
`
`computer signals. (Flasck, 4:9-11). Thus, the projection system described
`
`throughout in Flasck and as specifically illustrated in Fig. 11 is a video projector
`
`system.
`
`individual light sources, one each for each color to be projected, adapted to
`provide each a separate light beam;
`
`19.
`
`Fig. 11 of Flasck shows a color projection system that includes three
`
`separate light sources (144, 146, and 148):
`
`_10_
`
`

`

`
`
`As shown above, the light sources in Fig. 11 each correspond to a different color
`
`and each provide a separate light beam. Thus, Flasck also teaches a system having
`
`“individual light sources, one each for each color to be projected, adapted to
`
`provide each a separate light beam.”
`
`a lens system in the path ofthe separate light beams, adaptedforfocusing
`the beams;
`
`20.
`
`Flasck also describes a lens system for focusing the beams. Flasck
`
`teaches the use of “color reflective image plane modules” (items 92, 104, and 112
`
`in Fig. 11). Flasck illustrates such a reflective image plane module in Fig. 2C:
`
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`
`IG. 20
`
`This figure shows that the Flasck reflective image plane module contains three
`
`_11_
`
`

`

`lenses (34, 36, and 50). Flasck teaches that “the light is columnated by a lens 34
`
`and condensed or focused by a lens 36 to the reflective image plane module 30.
`
`(Flasck, 521—3) (see also id. at 5:50-53 (“The reflective image plane module can .
`
`.
`
`.
`
`include the light 32 and other light directing elements 34, 36, and 50 if desired.”))
`
`Thus, each light beam path has its own lens system “adapted for focusing the light
`
`beams.”
`
`a number of individual color filters equal to the number of beams, in the
`colors to be projected, andplaced one each in each beam path;
`
`21.
`
`Flasck teaches that “[t] he separate light sources again require the
`
`respective B, G and R filters 124, 126, and 128 to provide the B, G and R. [sic]
`
`light components.” (Flasck, 7:64-66). As shown in Fig. 11, these light filters 124,
`
`126, and 128 are placed in the blue, green, and red light paths, respectively.
`
`
`
`FIG. 11
`
`Thus, Flasck also teaches a system having “a number of individual color filters
`
`equal to the number of beams, in the colors to be projected, and placed one each in
`
`_12_
`
`

`

`each beam path.”
`
`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;
`
`22.
`
`The ’545 Patent explains that one example of “light-shutter” matrix is
`
`a monochrome LCD array. (’545 Patent, 1:64-66). As discussed above, each of
`
`the light paths in Flasck contains an equivalent image plane module. In turn, each
`
`of the image plain modules (as illustrated by Fig. 2C) contains an LCD array,
`
`which is identified as item 46 below:
`
`
`
`Flasck teaches that “the wafer based active matrix 46 .
`
`.
`
`. is covered by an LCD or
`
`similar characteristic material.” (Flasck, 5:20—26) F lasck further teaches that the
`
`preferred active matrix, provides “faster switching speeds” (Flasck, 5:36). Flasck
`
`also teaches that three reflective image plane modules, with three equivalent
`
`switching matrices, can be combined to form a full-color projection system.
`
`(Flask, 6:65—73.) This switching LCD matrix system is a “light—shutter matrix
`
`system.” Thus, Flasck also teaches a system having “a light-shutter matrix system
`
`-13_
`
`

`

`comprising a number of equivalent switching matrices equal to the number of
`
`beams and placed one each in the beam paths.”
`
`a video controller adaptedfor controlling the light—shutter matrices; and
`
`23.
`
`The ’545 Patent explains that a video controller receives a video
`
`signal and “controls the three monochrome matrices 117, 118, and 119.” (“545
`
`Patent, 3:13—17). Although Flasck does not use the phrase “video controller,” it
`
`nevertheless teaches an “electronic interface 118” (also called “TV or computer
`
`interface electronics 1 18”) that controls the light—shutter LCD matrices. (F lasck,
`
`Figs. 9, 11) Specifically, Flasck teaches that the reflective image plane modules
`
`“encode” the light beams with image information. (Flasck, 5:9—20) The
`
`information encoding is provided by an electronic interface 118 coupled to the
`
`reflective image plane modules 92, 104, and 112. (Flasck at 724.) Fig. 1 1
`
`illustrates how the interface 1 18 provides information to the reflective image plane
`
`modules.
`
`
`
`
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`

`Given the above information from Flasck, one of ordinaiy skill in the art
`
`would have recognized that the “TV or computer interface electronics” of Flasck
`
`was equivalent to the “video controller” of the ‘545 Patent. Thus, Flasck also
`
`teaches a system having “a video controller adapted for controlling the light-shutter
`
`matrices.”
`
`24.
`
`Further, it also would have been obvious to use a video controller in
`
`View of the disclosure of Flask (to the extent it might be argued that Flasck does
`
`not teach a video controller). For example, Flasck discloses in a similar prior art
`
`system, a video drive circuit for interfacing between a signal source and an LCD:
`
`A video or computer signal source (not illustrated) is coupled
`
`by a line 18 to a video drive circuit 20. The video drive circuit
`
`20 operates on the signal coupled thereto and generates the
`
`required drive signals coupled over a line 22 to the LCD 16.
`
`Typically the drive signals will be the audio, red video, blue
`
`Video, green video, vertical sync, horizontal sync, reset and
`
`pixel clock signals. The drive signals cause the pixels of the
`
`LCD 16 to block or transmit
`
`light
`
`to impart
`
`the required
`
`information onto the light transmitted through the LCD 16 to a
`
`lens or lens system 24 which projects the composite color
`
`picture onto the screen 26. A. monochrome projection system
`
`would operate in the same manner with only one video light
`
`component, rather than the separate blue, green and red video
`
`signals.
`
`(Flasck at 4:9~24.)
`
`

`

`25.
`
`Based at least on 1) the passages at 72-4 and 429—24, and 2) the
`
`position of the interface 118 in Figs. 9 and 11, it would have been obvious to a
`
`person of ordinary skill in the art to implement the TV or computer interface
`
`electronics 118 as a video controller adapted for controlling the image plane
`
`modules (which are light-shutter matrices). Specifically, the passage at 712-4
`
`explains that the interface 118 controls the image plane modules 92, 104, 112 bx
`
`providing information encoding. Also, a Video controller would most likely be
`
`placed as shown in Figs. 9 and 11 so that it can provide signals to the image plane
`
`modules.
`
`an optical combination system adaptedfor combining the several beams into
`a single composite beam for projection on a surface to provide a video
`display;
`
`26.
`
`Flasck describes a “dichroic combining prism/mirror,” that combines
`
`multiple light beams into a composite beam, as illustrated below:
`
`/
`
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`
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`
`With respect to this figure, Flasck teaches that “[t]he combining prism 150
`
`-1 5*
`
`

`

`combines the three B, G and R light components and outputs a single combined
`
`and encoded color signal 152, which is directed to a lens or lens system 154 and
`
`then is projected onto the screen 98.” (Flasck, 8: 1—5). Thus, Flasck teaches a
`
`system having “an optical combination system adapted for combining the several
`
`beams into a single composite beam for projection on a surface to provide a video
`
`display.”
`
`wherein each beam passes through a colorfilter before being processed by a light-
`swiz‘ching matrix.
`
`27.
`
`As discussed above, Fig. 11 of Flasck shows color filters 124, 126,
`
`and 128. (Flasck, 7:64~66) (“The separate light sources again require the
`
`reSpective B, G and R light filters 124, 126, and 128 to provide the B, G, and R.
`
`[sic] light components”) As shown in Fig. 11, these filters are located between the
`
`light sources and the LCD light—switching matrices in the reflective image plan
`
`modules. Thus, Flasck also teaches a system “wherein each beam passes through a
`
`color filter before being processed by a light—switching matrix.”
`
`Claim 2. The video projection system ofclaim 1 wherein the 1ight~shutter
`
`matrices are monochrome LCD arrays.
`
`28.
`
`As discussed above, Flasck describes reflective image plane modules
`
`which contain LCD arrays. (Flasck, 4:65-5:34) Flasck teaches that “[e]ach color
`
`reflective image plane module operates on a single color component, red green or
`
`blue, which then are combined on a screen or before projecting on the screen to
`
`_17_
`
`

`

`form the full color projection image.” (Flask, 2:60-64.) Flask further teaches that
`
`“[e]ach of the above reflective image plane modules can be utilized as part of a
`
`monochrome projection system.” (Flask, 6:65—66.) Thus, the individual LCD
`
`arrays within the reflective image plane modules are “monochrome LCD arrays.”
`
`29.
`
`Further, in view of the above teaching of Flask, it would have been
`
`obvious to one of ordinary skill in the an to implement the LCD arrays in each
`
`reflective image plane module as a monochrome LCD array (to the extent it may
`
`be argued that Flasck does not disclose monochrome LCD arrays). Further,
`
`implementing monochrome LCD arrays in the reflective image plane modules
`
`would have been nothing more than a combination of known elements according to
`
`known methods to yield predictable results.
`
`Claim 3. The video projector system of claim 1 wherein three light sources
`provide three beams, and red, green, and bluefilters are used to provide
`red, green, and blue beams to an LCD matrix system.
`
`30.
`
`As discussed above, Flasck describes reflective image plane modules
`
`92, 104, and 112 which contain LCD arrays. (Flasck, 4:65-5:34) Fig. 11 of Flasck
`
`shows a system having red, green, and blue light sources and filters that provide
`
`light beams to the image plane modules, which contain LCD arrays:
`
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`As such, the image plane modules are collectively an LCD matrix system. Thus,
`
`Flask also teaches that the “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.”
`
`Obviousness In View Of Takanashi In View Of Lee {and Irwin!
`
`31.
`
`The Takanashi reference is entitled “Spatial Light Modulator
`
`System.” Takanashi was filed on November 23 1992, claims priority to a Japan
`
`application dated April 8, 1991, and issued on November 23, 1993. Lee was filed
`
`on November 25, 1992, and issued on February 15, 1994. Irwin was filed on
`
`October 24, 1995, and issued on July 21, 1998. It is my opinion that the claims of
`
`the ’545 Patent are obvious in view of Takanashi in combination with Lee (and
`
`Irwin to the extent that it may be argued that Takanashi does not contain an
`
`adequate disclosure of a monochrome LCD array) for the reasons set forth below.
`
`“19...
`
`

`

`Claim 11/1 video projector system comprising:
`
`32.
`
`Takanashi describes a “video projector system.” For example, with
`
`respect to Fig. 17, Takanashi teaches that an “optical image projected to the screen
`
`by the projection lens PIL is obtained as the image having good contrast in the
`
`color image of the object of the display.” (Takanashi, 16:40~42.) It would have
`
`been apparent to a person having ordinary skill in the art that the projection system
`
`described throughout in Takanashi and specifically illustrated in Fig. 17 is a
`
`projector system that may be used to project Video images onto a screen.
`
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`PLl
`
`Takanashi Fig. 17
`
`33.
`
`Thus, one of skill in the art would have recognized that Takanashi
`
`discloses a video projection system.
`
`individual light sources, one each for each color to be projected, adapted to
`provide each a separate light beam;
`
`34.
`
`Fig. 7 of Takanashi shows that the projection system uses a single
`
`

`

`light source (LS) to produce three separately colored light beams (red, blue, and
`
`green). (Takanashi, 16: 1-14.)
`
`PLS
`
`RLO
`
`M.
`
`8SYSTBVI
`
`E g
`
`S g
`
`Takanashi Fig. 17
`
`35.
`
`In contrast to the single—light system of Talcanashi, other light
`
`projection systems use three different light sources, each paired with its own color
`
`filter in the path of its respective light beam. An example of such a system is
`
`shown in Lee Fig. 2 (reproduced below). As illustrated in Lee Fig. 2, three
`
`individual light sources 26 each provide a separate light beam. Thus, there is one
`
`light source for each color to be projected (red, blue, and green). (See Lee, 4:14—
`
`20.)
`
`-21-
`
`

`

`
`
`Lee Fig. 2
`
`36.
`
`A person of ordinary skill in the art would have seen a three-light
`
`source system versus a single—light source system as a simple matter of design
`
`choice. Various factors that might affect such a decision include available space
`
`for the apparatus, ability to dissipate heat, cost of a prism or mirror system versus
`
`cost of three separate sources with individual color filters, etc. A person of
`
`ordinary skill in the art would have understood the differences between two such
`
`systems and would have chosen the best one for a particular application. Further, a
`
`person of ordinary skill in the art would recognize that the choice of i) a single
`
`white light source illuminating color filters, or ii) three white light sources
`
`illuminating color filters, essentially exhausts the possibilities for obtaining three
`
`separate colored light beams from incident white light, thereby making either
`
`choice obvious to try.
`
`37.
`
`One example modification would replace the single-source apparatus
`
`of Takanashi Fig. 17 with a three-source apparatus, similar to that shown in Lee.
`
`_22_
`
`

`

`In this example, a person of ordinary skill in the art would have omitted the single
`
`light source (LS) and the three-color separation optical system 10 in Fig. 17 of
`
`Takanashi. In its stead, a person of ordinary skill would adopt a three-source
`
`system that would include features similar to Lee’s sources 17/26, lenses 15, and
`
`filters 28 to provide colored light beams at each of the R, G, and B portions of
`
`Takanashi’s liquid crystal elements ECB.
`
`I do not propose a bodily incorporation
`
`of Lee’s components into Takanashi’s system, but rather, I note that a person of
`
`ordinary skill in the art would have been quite capable of replacing Takanashi’s
`
`single-source apparatus with a three—source apparatus having three sources, three
`
`filters, and three lenses. Such a modification is a simple design choice, as noted
`
`above. Also, it is a combination of prior art elements according to known
`
`techniques to give predictable results.
`
`a lens system in the path offhe separate light beams, adaptedforfocusing the
`beams;
`
`38.
`
`Lee also describes a lens system for focusing the separate light beams.
`
`Lee teaches using “focusing lenses 15R, ISG, 15B.” (Lee, 4: 19-20.) The focusing
`
`lenses are “for focusing the light emitted from the respective light source[s].”
`
`(Lee, 3 :21 -22.) As shown in Fig. 2, each light beam path has its own lens “adapted
`
`for focusing the light beams.”
`
`-23-
`
`

`

`
`
`Lee Fig. 2
`
`39.
`
`Once a person of ordinary skill in the art had decided to use a three—
`
`source apparatus, as described above, such person would know to use a three lens
`
`system similar to that of Lee’s to focus beams from the source to components
`
`downstream. Such implementation would have been a matter of simple
`
`substitutions and common sense.
`
`a number of individual colorfilters equal to the number ofbeams, in the colors to
`be projected, and placed one each in each beam path;
`
`40.
`
`Lee also teaches that “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 used. (Lee, 4:16-19.) As shown in Fig. 2, the three color filters 28R,
`
`286, and 28B, are placed in the beam paths from the three light sources and are
`
`equal to the three colors (red, green, and blue) to be projected.
`
`-24-
`
`

`

`
`
`Lee Fig. 2
`
`41.
`
`Once a person of ordinary skill in the art had decided to use a three-
`
`source apparatus and the three lens system, as described above, such person would
`
`know to use three color filters, similar to that of Lee’s, to provide separate R, G,
`
`and B light beams to components downstream. Such implementation would have
`
`been a matter of simple substitutions and common sense.
`
`a light—shutter matrix system comprising a number ofequivalent switching
`matrices equal to the number ofbeams andplaced one each in the beam paths;
`
`42.
`
`Takanashi teaches a light—shutter matrix system comprising switching
`
`matrices (liquid crystal elements ECBtr, ECBtg and ECBtb, polarizers PLZr, PL2g
`
`and PLZb, and spatial light modulator elements SLMtr, SLMtg and SLMtb) in Fig.
`
`l 7. One of ordinary skill in the art would have recognized that the ECBtr, PLZr,
`
`and SLMtr elements combined are a switching matrix used to process only red
`
`beams. One of ordinary skill in the art would also have recognized that the ECBtg,
`
`PL2g, and SLMtg elements combined are a switching matrix used to process only
`
`_2 5...
`
`

`

`green beams. And, one of ordinary skill in the art would also have recognized that
`
`the ECBtb, PL2b, and SLMtb elements combined are a switching matrix used to
`
`process only blue beams.
`
`43.
`
`Further, as illustrated in Fig. 17, these elements are placed one each in
`
`the color beam paths to encode the beams with image information for display on a
`
`projection screen. (see e.g., Takanashi, 1621—42.)
`
`5 H T
`
`3 E E t
`
`;
`
`akanashi Fig. 17
`
`44.
`
`Thus, one of skill in the art would have recognized that Takanashi’s
`
`combination of ECB elements, polarizers PLZ, and the SLM elements is a “light—
`
`shutter matrix system.”
`
`a video controller adaptedfor controlling the light-Shutter matrices; and
`
`45.
`
`Takanashi teaches controlling the light-shutter matrix system (e. g.,
`
`ECB, PL2, and SLM elements) to encode the three light beams (R, G, B) with
`
`color image information, (see Takanashi 16:3 8-42.)
`
`as
`
`LS
`
`é Ru
`
`PL!
`
`PLS
`
`RLo
`
`RM.
`
`

`

`46.
`
`It would have been apparent to one of ordinary skill in the art to
`
`utilize a Video controller in the embodiment of Fig. 17 of Takanashi to pass video
`
`signals to the light—shutter matrix system. In fact, the use of a video controller in a
`
`video projector system was basic, standard practice and would have been
`
`abundantly evident to even beginners in the art as a. way to control a light-shutter
`
`matrix or other matrix to output spatially and temporally modulated light.
`
`47. An example of a Video controller is shown in Lee Fig. 2 at item 19.
`
`With respect to item 19, Lee notes using a “light shutter controlling circuit 19” for
`
`controlling light shutters 14R, 14G, and 14B in order to modulate the light beams.
`
`
`
`Lee Fig. 2
`
`48.
`
`In view of the teaching ofTakanashi and Lee, utilizing a video
`
`controller adapted for controlling the light—shutter matrices was simply a matter of
`
`ordinary skill and common sense, not innovation. Furthermore, such an addition to
`
`Takanashi would have been obvious to try, as well as a combination of prior art
`
`elements according to known techniques to yield predictable results.
`
`_27_
`
`

`

`an optical combination system adaptedfor combining the several beams into
`a single composite beam for projection on a surface to provide a video
`display;
`
`49.
`
`Takanashi teaches three—color combination optical system 12 that
`
`combines the several beams into a single composite beam for projection of an
`
`image on a screen.
`
`LS
`
`é RLi
`
`
`PL! SEPARATlON
`OPTICAL
`
`
`
`THREE~COLOR
`
`Takanashi Fig. 17
`
`50. With respect to this figure, Takanashi notes that an “optical image
`
`projected on the screen by the projection lens PJL is obtained as the image having
`
`good contrast in the color image of the object of display.” (Takanashi, 16:21—42.)
`
`Thus, it would have been obvious to use the projector system of Takanashi, which
`
`combines several beams into a composite beam, to display color video images with
`
`good contrast on a screen.
`
`wherein each beam passes through a colorfilter before being processed by a light-
`
`n2 3-
`
`

`

`switching matrix.
`
`51.
`
`As discussed above, Fig. 2 of Lee shows three color filters 28R, 28G,
`
`and 28B. (Lee, 4: 16—19) (“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 288”
`
`are used”) As shown in Fig. 2, these color filters are located between the light
`
`sources 26 and the light shutters 14R, 146, and 148. Thus, Lee also teaches a
`
`system “wherein. each beam passes through a color filter before being processed by
`
`a light—switching matrix.”
`
`52.
`
`Once a person of ordinary skill in the art had decided to use a three—
`
`source apparatus, the three lens system, and the three color filters, as described
`
`above, such person would know to position the color filters upstream of the light
`
`shutters such that the light beams pass through a color filter before being processed
`
`by the light shutters or any appropriate matrix, to thereby allow the light shutters or
`
`any matrix to only modulate a single color. Such implementation was simply a
`
`matter of ordinary s

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