TPK 2017
`Wintek v. TPK Touch Solutions
`IPR2013-00568
`
`
`Wintek v. TPK Touch Solutions
`IPR2013-00568
`
`
`
`Case IPR 2013-00567, 2013-00568
`
`U.S. Patent No. 8,217,902
`
`Declaration of Ted Tsai
`
`In Support of Patent Owncr’s Response Pursuant to 37 C.F.R. § 42.120
`
`I, Ted Tsai, declare as follows:
`
`1.
`
`I am over 18 years of age and otherwise competent to make this
`
`Declaration.
`
`2.
`
`I currently work as Senior Vice President and Chief Sales Officer in
`
`the Sales & Marketing Department of TPK Touch Solutions Inc. (“TPK”). My
`
`office address is No. 13-18, Section 6, Min-Quan E. Rd., Neihu District, Taipei
`
`City 114, Taiwan.
`
`I have held this position since 2006.
`
`3.
`
`TPK was established in 2003 and began manufacturing projected
`
`capacitance touch panels in 2006.
`
`4.
`
`With the rapid development and growth in the mobile consumer
`
`device industry in the 2000s,
`
`there was a significant
`
`increase in demand for
`
`transparent,
`
`lightweight
`
`touch screens that are capable of detecting multiple
`
`touches. However, as of 2006, the industry was still searching for and developing
`
`solutions to achieve that goal.
`
`5.
`
`The first—generation Apple iPhone, released in 2007, was a prominent
`
`example of a device with a transparent touch screen that included multi-touch
`
`capabilities.
`
`The iPhone’s touch screen was transparent and used mutual-
`
`capacitance sensing to detect the positions of multiple simultaneous touches on the
`
`surface of the glass. Specifically, the iPhone’s touch screen sensed the presence of
`
`one or more touches by measuring the capacitance between two separate layers of
`
`transparent indium tin oxide (“ITO”) conductive sensors—a ”driving” layer and a
`
`“sensing” layer—on opposite sides of a glass substrate.
`
`
`
`Case IPR 2013-00567, 2013-00568
`U.S. Patent No. 8,217,902
`
`6.
`
`Exhibit 2018 is a true and correct copy of a March 2012 market report
`
`on touch panel display technology conducted by Daiwa Capital Markets. As
`
`page 7 of this Exhibit illustrates, the iPhone (and Apple’s subsequent products)
`
`made use of a “DITO” (double—sided ITO) touch panel with ITO sensors on
`
`opposing sides of the sensor glass.
`
`7.
`
`Other commercially available transparent mutual-capacitance based
`
`touchscreens in 2006 and 2007—notably, the LG Prada phone-—also relied on
`
`DITO solutions.
`
`8.
`
`In late 2006, TPK developed an improvement on existing DITO
`
`mutual capacitance sensors that used a “SITO” (single—sided ITO) solution.
`
`Specifically, TPK designed a structure for touch panels in which both driving and
`
`sensing conductor elements are on the same surface of the substrate.
`
`The
`
`conductor elements include an array of sensor cells that are interconnected by
`
`conductive lines to form rows and columns along two perpendicular axes, one axis
`
`for driving and the other one for sensing. At the intersection of each driving line
`
`and sensing line, a thin, transparent insulator is placed between the lines to keep
`
`the lines electrically isolated.
`
`9.
`
`An example of TPK’s SITO touch panel structure is shown in Exhibit
`
`2019, which contains diagrams of the touch panel of the Amazon Kindle
`
`Paperwhite, designed and provided by TPK.
`
`l0.
`
`TPK’s single—sided transparent touch panel structure formed the basis
`
`for its “one-glass solution” (or “OGS”) technology, with all electrodes placed on
`
`the underside of the cover lens. TPK’s OGS technology improved on existing
`
`touch screens in multiple ways: First, it allowed for a touch screen that was both
`
`physically thinner and more lightweight than other commercially available options,
`
`making it highly appropriate for use in mobile devices such as laptops and phones.
`
`2
`
`
`
`Case IPR 2013-00567, 2013-00568
`U.S. Patent No. 8,217,902
`
`Second, the reduced thickness of the substrate improved the transparency of the
`
`touch screen as a whole.
`
`11.
`
`Exhibit 2020 is a true and correct copy of an April 2014 quarterly
`
`market analysis of the touch panel industry conducted by NPD DisplaySearch. On
`
`page 29 of this report, OGS sensor structures are compared to other DITO
`
`solutions and recognized as yielding the “best” module thickness and superior
`
`optical performance. As the report further notes, the “major appeal” of OGS
`
`sensor structures is that they are “thin and light.”
`
`12.
`
`To the best of my knowledge and belief, TPK’s SITO mutual-
`
`capacitance touch screens were the first commercially available mutual capacitance
`
`touch panels that used this single—layer solution.
`
`13.
`
`TPK began selling touch panels implementing its single~layer solution
`
`in the year 2008 to mobile handset makers,
`
`including to RIM for use in the
`
`BlackBerry Storm, and to Palm for use in the Palm Pre. Both products were
`
`commercially successful. A February 2009 article from Economic Daily News (Ex.
`
`2021) reported that the Storm and Pre were two of only five touch—screen mobile
`
`phone devices to sell more than one million units.
`
`14.
`
`TPK’s SITO touch panels were attractive to its customers for their
`
`thin profile—a key advantage in mobile devices. For instance,
`
`in 2009 RIM
`
`specifically requested that TPK reduce the thickness of its panels to support the
`
`thinnest possible product design.
`
`15.
`
`As market demand for touch—screen devices has continued to increase,
`
`TPK has expanded to provide touch panels to customers for use in tablets and
`
`notebook computers as well.
`
`For instance, in 2012, TPK supplied single-layer
`
`
`
`Case IPR 2013-00567, 2013-00568
`U.S. Patent No. 8,217,902
`
`touch panels to Amazon for use in the Kindle Fire, and to Google/Asus for use in
`
`the Nexus 7.
`
`16.
`
`Exhibit 2022 is a true and correct copy of a research report on TPK
`
`published by J.P. Morgan in October 2012. As page 3 of the report notes, by 2012,
`
`OGS had “emerge[d] as the mainstream” among tablet devices, resulting in a
`
`positive outlook for TPK. Figure 1 on page 3 of the report illustrates the “touch-
`
`panel structure evolution” from DITO solutions to single—layer solutions. Table 2
`
`on page 4 of the report compares a number of touch-panel technologies known in
`
`2012 and awards OGS a grade “A” for thickness and cost.
`
`17.
`
`Exhibit 2023 is a true and correct copy of a December 2012 quarterly
`
`market analysis of the touch panel industry conducted by NPD Display/Search. As
`
`page 19 of this report notes, “OGS has become the major touch screen solution for
`
`Windows 8 notebook PCs,” as the technology provides “a better balance in terms
`
`of weight, thickness, cost, and supply sources.” Page 7 of this report estimates that
`
`OGS accounts for “more than 80% of the shipment share” of Windows-based
`
`notebook PCs optimized for touch.
`
`18.
`
`TPK also has distinguished its competitors by introducing its SITO
`
`technology to customers outside the mobile computing industry. Electric vehicle
`
`manufacturer Tesla chose TPK to supply the 17-inch touch panel for its Model S, a
`
`prominent feature of the award-winning vehicle. Tesla awarded TPK as its
`
`“Excellent Development Partner.”
`
`19.
`
`TPK’s other customers have expressed appreciation for the improved
`
`thinness, weight and transparency of TPK’s SITO touch screens, and have
`
`presented TPK with a number of awards recognizing its products. An exemplary
`
`chart of awards received from TPK’s customers appears below.
`
`
`
` Award
`
`Sony —- "Supplier Performance Award"
`
`2013
`
`Case IPR 2013-00567, 2013-00568
`U.S. Patent No. 8,217,902
`
`Asus -- "2012 Supplier Performance Award"
`
`Lenovo -— "Outstanding Serviceability"
`
`2012
`
`Acer —— "The Best Partner"
`
`ZTE -- "Global Excellent Partnership"
`
`Intel -- "Supplier Recognition Award for First Smartphone Launch in Q2’ 12"
`
`Tesla —— "Excellent Development Partner"
`
`2011
`
`ZTE -- "Best Agile Delivery Award"
`
`ZTE -- "Excellent Supplier Quality Representative"
`
`
`
`
`Huawei —— "TP/LCD Quality Outcomes Number 1 "
`
`Asus -- "201l Outstanding Supplier Award"
`
`
`
`
`
`Case IPR 2013-00567, 2013-00568
`U.S. Patent No. 8,217,902
`
`20.
`
`I declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct.
`
`Executed on the 27th day of June, 2014.
`
`7509:
`
`Ted Tsai
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
