Filed on behalf of: DIGITAL EMPIRE LIMITED
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`By: Gokalp Bayramoglu, Ph.D.
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`Bayramoglu Law Offices LLC
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`8275 South Eastern Avenue Suite 200-611
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`Las Vegas Nevada 89123
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`Telephone: 702-724-2628
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`E-mail:gokalp@bayramoglu-legal.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
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`PATENT TRIAL AND APPEAL BOARD
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` Digital Empire Limited
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`Petitioner
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`v.
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`Hilltop Technology LLC
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`Patent Owner
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`Patent 7,864,503
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`DECLARATION OF DR. GEORGE E. GERPHEIDE
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
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`TABLE OF CONTENTS
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`I. INTRODUCTION ......................................................................................... 1
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`II. QUALIFICATIONS .................................................................................... 2
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`III. SUMMARY OF OPINIONS ........................................................................ 4
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`IV. OVERVIEW OF THE ’503 PATENT ......................................................... 6
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`V. CLAIM CONSTRUCTION ......................................................................... 9
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`VI. CERTAIN REFERENCES DISCLOSE ALL THE CLAIMED FEATURES
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`OF THE ’503 PATENT ..................................................................................... 12
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`A. FUJITSU, EITHER INDIVIDUALLY OR IN COMBINATION WITH OTHER
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`REFERENCES, DISCLOSES ALL THE CLAIMED FEATURES ...................................... 12
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`1. Fujitsu Discloses Each and Every Feature Recited in claims 1, 2, and 3. ..... 12
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`a. Claim 1 ......................................................................................................... 13
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`b. Claim 2 ........................................................................................................ 17
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`c. Claim 3......................................................................................................... 18
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`2. Fujitsu and Aoki Disclose Each and Every Feature Recited in claim 9. ........ 19
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`3. Fujitsu and Fong Disclose Each and Every Feature Recited in claim 9. ....... 21
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`4. Fujitsu and Jain Disclose Each and Every Feature Recited in Claim 10. ...... 23
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`5. Fujitsu and Seguine Disclose Each and Every Feature Recited in claim 11. . 24
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`6. Fujitsu, Seguine and Ohtake Disclose Each and Every Feature Recited in
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`claim 12. ............................................................................................................ 27
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`7. Fujitsu, Seguine and Nakanishi-1 Disclose Each and Every Feature Recited in
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`Claim 12. ........................................................................................................... 30
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`8. Fujitsu, Seguine and Nakanishi-2 Disclose Each and Every Feature Recited in
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`Claim 12. ........................................................................................................... 32
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`9. Fujitsu and Lai Disclose Each and Every Feature Recited in Claim 4. ......... 33
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`10.Fujitsu and Takeda Disclose Each and Every Feature Recited in Claim 4.
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` ……………………………………………………………………………….34
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`11.Fujitsu and Bolender Disclose Each and Every Feature Recited in Claims 5, 6,
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`7, and 8. ............................................................................................................. 35
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`a. Claim 5......................................................................................................... 35
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`b. Claim 6 ........................................................................................................ 38
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`c. Claim 7......................................................................................................... 40
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`d. Claim 8 ........................................................................................................ 42
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`12.Fujitsu and Seguine in view of Chen Disclose Each and Every Feature
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`Recited in Claim 12. .......................................................................................... 43
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`B. BOLENDER, EITHER INDIVIDUALLY OR IN COMBINATION WITH OTHER
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`REFERENCES, DISCLOSES ALL THE CLAIMED FEATURES ...................................... 45
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`1. Bolender Discloses Each and Every Feature Recited in Claims 1, 2, 3, and 4.
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` ………………………………………………………………………………45
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`a. Claim 1......................................................................................................... 45
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`b. Claim 2 ........................................................................................................ 51
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`c. Claims 3 and 4.............................................................................................. 53
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`2. Bolender and Lai Disclose Each and Every Feature Recited in Claim 4. ...... 53
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`3. Bolender and Takeda Disclose Each and Every Feature Recited in Claim 4. 55
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`4. Bolender and Jain Disclose Each and Every Feature Recited in Claim 10. ... 56
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`5. Bolender and Seguine Disclose Each and Every Feature Recited in Claim 11.
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` ………………………………………………………………………………57
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`6. Bolender, Seguine, and Ohtake Disclose Each and Every Feature Recited in
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`Claim 12. ........................................................................................................... 60
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`C. BINSTEAD, IN COMBINATION WITH FUJITSU, DISCLOSES ALL FEATURES IN
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`CLAIMS 1, 2, 3 AND 11 ........................................................................................ 63
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`1. Claim 1. ....................................................................................................... 63
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`2. Claim 2. ....................................................................................................... 68
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`3. Claim 3. ....................................................................................................... 69
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`4. Claim 11. ..................................................................................................... 70
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`I, George E. Gerpheide, declare as follows:
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`I. Introduction
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`1. I have been retained by Digital Empire (“Petitioner”) as an independent
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`expert consultant in this proceeding before the United States Patent and
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`Trademark Office. Although I am being compensated at my rate of $400 per
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`hour for the time I spend on this matter, no part of my compensation is
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`dependent on the outcome of this proceeding, and I have no other interest in this
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`proceeding.
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`2. I understand that this proceeding involves U.S. Patent No. 7,864,503 (“the
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`‘503 patent”) (Ex. 1001)1, the application for which was filed on April 23, 2008,
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`as U.S. Patent Application No. 12/148,998, and issued on January 4, 2011. I
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`also understand that the ’503 patent is based on Taiwanese Patent Application
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`No.96116883, which was filed on May 11, 2007. I further understand that
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`the ’503 patent is assigned on its face to Hilltop Technology LLC. (“Patent
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`Owner”).
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`3. I have been asked to consider whether certain references disclose or suggest
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`the features recited in the claims of the ’503 patent. My opinions are set forth
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`below.
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`1
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`Where appropriate, I refer to exhibits attached to the petition for Inter Partes Review of the ‘503 patent.
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`1
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
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`II. Qualifications
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`4. My curriculum vitae, which includes a detailed summary of my background
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`and experience and a list of my publications and patents is attached is attached
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`as Exhibit 1019.
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`5. I am an electrical engineer with over 20 years of technological expertise and
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`experience working in particular regards in the area of touchpad technology.
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`6. I obtained my B.S. degree in Electrical Engineering from the Massachusetts
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`Institute of Technology (having received honors from Tau Beta Pi and Eta
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`KappaNu) in 1975 and a Ph.D. in Computer Science from the University of Utah
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`(where I was an IBM Fellow) in 1981.
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`7. From 1978-1980 I was the principal hardware engineer at Optronics Ltd.
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`where I co-created Par-T-Golf computer golf game with optoelectronic ball
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`tracking. I was the founder and president of Aquila Instruments, Inc. from 1981-
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`1983, where I created induced polarization geophysical exploration equipment.
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`Then, from 1983-1984 I was the principal engineer at Impulse Computer
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`Systems, Inc. where I created a retail inventory system for partially-filled liquid
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`containers. In 1984 I was a visiting scientist at MIT’s Artificial Intelligence
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`Laboratory as a technical liaison for a 16 degrees-of-freedom dexterous
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`anthropomorphic robot hand. Additionally, from 1982-1986 I was an adjunct
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`2
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`professor at the University of Utah and in 1984 became a consultant for the
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`University’s Center for Engineering Design where I co-created robot hand
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`control algorithms. I also consulted for Dayna Communications, Inc. from 1983-
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`1988 where I co-created the Dayna Talk network, Netware for the Macintosh
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`computers, DaynaFile storage, and the MacCharlie PC coprocessor for the
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`Macintosh computers. Subsequently, from 1988-1990, I was the founder and
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`president of Proxima, Inc., where I created the first capacitance based touchpad
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`to become commercially successful for portable computers.
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`8. I founded Cirque Corporation in 1991 to further develop and commercialize
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`the capacitance-based touchpad technology I invented in my basement. This
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`became the first commercially successful touchpad for laptop computers, and for
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`which I was awarded US Patent No. 5,305,017. In 2003, I sold Cirque
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`Corporation to Alps Electric Co., Ltd., and became a consultant to Alps in 2004.
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`I have continued consulting on business development, technological, and patent
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`issues for organizations that include, Hoyama, Inc., Acer Incorporated, TPK
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`Touch Solutions, IMS Expert Services, Immersion Corporation, LaunchRing,
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`Nuvoton Technology Israel, Ltd, Ascent Partners Group, LLC, CleanKeys Inc.,
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`Fusion IO, and Apple Computer. I am currently president of c2mw4, LLC which
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`explores new technologies for areas such as education, energy, space launch, and
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`dynamic light emitting art, CSO for Typesoft Technologies Inc, and CTO for
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`3
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
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`Veristride Inc.
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`9. I am a named inventor in over 19 U.S. patents. Since 1988 I have innovated
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`for, taught, advised and consulted various organizations and companies on
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`capacitive touch pad technology and other areas of technology.
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`10. I am not an attorney and offer no legal opinions, but in the course of my
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`work, I have had experience studying and analyzing patents and patent claims
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`from the perspective of a person skilled in the art.
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`III. Summary of Opinions
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`11. All of the opinions contained in this Declaration are based on the documents
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`I reviewed and my knowledge and professional judgment. In forming the
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`opinions expressed in this Declaration, I reviewed the ’503 patent (Ex. 1001); the
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`prosecution file history for the ’503 patent (Ex. 1002); U.S. Patent No. 6,137,427
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`(“Binstead”) (Ex. 1003; U.S. Patent Application Publication No. 2005/0030048
`
`of Bolender et al. (Ex. 1004); Japanese Published Patent Application No. 60-
`
`75927 to Fujitsu (Ex. 1005); Certified English Translation of Japanese Published
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`Patent Application No. 60-75927 and Certificate of Translation (Ex. 1006);
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`International Application Publication No. WO 2006/029517 A1 of Fong et al. (Ex.
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`1007); U.S. Patent Application Publication No. 2007/0215377 of Aoki et al. (Ex.
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`1017); U.S. Patent Application Publication No. 2007/0254490 of Jain et al. (Ex.
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`1008); U.S. Patent Application Publication No. 2007/0229469 of Seguine (Ex.
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`4
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`1009); U.S. Patent Application Publication No. 2006/0032664 of Ohtake et al.
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`(Ex. 1010); WO Application No. 2007/008518 of Takeda (Ex. 1011); U.S.
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`Patent Application Publication No. 2007/0240914 of Lai (Ex. 1012); Technical
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`Information – Transmittance of Optical Glass (Ex. 1013); U.S. Patent No.
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`6,661,408 of Chen (Ex. 0014); U.S. Patent No. 6,781,642 of Nakanishi et al.
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`(Nakanishi-1) (Ex. 0015), U.S. Patent No. 7,161,588 of Nakanishi et al.
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`(Nakanishi-2) (Ex. 0016) while drawing on my experience and knowledge of
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`touch screens.
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`12. My opinions have been also guided by my appreciation of how a
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`person of ordinary skill in the art would have understood the claims of the ’503
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`patent at the time of the alleged invention, which I have been asked to
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`initially assume is May 11, 2007, the filing date of the Taiwanese priority
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`application.
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`13. In my opinion, a person of ordinary skill in the art relevant to the
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`technology of the ’503 patent would have had a bachelor’s degree in electrical
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`engineering, or an equivalent field, and two to three years of experience working
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`in the relevant field, which includes display and/or related user interface device
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`technologies.
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`14. Based on my experience and expertise, it is my opinion that certain
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`references disclose all the features recited in the claims of the ’503 patent.
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`5
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`IV. Overview of the ’503 Patent
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`15. The ’503 patent issued from U.S. Application No. 12/148,998 (“the ’998
`
`application”) and is directed to a “capacitive type touch panel”. Ex. 1001, Abstract.
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`The ‘503 patent purports to eliminate the difficulty in identifying the location
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`touched by the user. Id. At 1:46-47.
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`16. FIG. 2 of the ’503 patent discloses a capacitive type touch panel, which
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`includes transparent substrate 3 having opposite top and bottom surfaces 31, 32;
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`array of first conductors 41 formed on the top surface 31 of the transparent
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`substrate 3; array of second conductors 42 formed on top surface 31 of transparent
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`substrate 3 and disposed alternately with first conductors 41; plurality of spaced
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`apart conductive first bridging lines 412, each of which interconnects two adjacent
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`ones of first conductors 41; plurality of spaced apart conductive second bridging
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`lines 422, each of which interconnects two adjacent ones of the second conductors
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`42 and each of which intersects insulatively a respective one of first bridging lines
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`412; and plurality of spaced apart insulators 5, each of which is disposed at an
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`intersection of a respective one of the first bridging lines 412 and the respective
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`one of the second bridging lines 422 so as to separate the respective one of the first
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`bridging lines 412 from the respective one of the second bridging lines 422. The
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`first and second conductors 41, 42 and the first and second bridging lines 412, 422
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`cooperatively form into a matrix of capacitive regions when a current is applied to
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`first and second conductors 41, 42 and the first and second bridging lines 412, 422.
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`See Id. at 2:28-52.
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`
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`17. The ’503 patent further discloses that each of the first and second conductors
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`41, 42 is formed with a plurality of holes 413, 423, and more preferably, each of
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`the holes 413, 423 is a through-hole. Since the area of each of the first and
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`second conductors 41, 42 is a key parameter to the capacitance, sensitivity in
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`detecting the coordinates of a touched location by the user can be adjusted
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`through changing of the number and/or the diameter of the holes 413, 423. Id.
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`2:58-65.
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`18. The ‘503 patent further discloses plurality of conductive first connecting lines
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`61 formed on the top surface 31 of the transparent substrate 3, and the plurality of
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`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`conductive second conducting lines 62 formed on the top surface 31 of the
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`transparent substrate 3. The first conductors 41 are arranged into parallel columns.
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`The first conductors 41 of each of the columns are interconnected by respective
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`ones of the first bridging lines 412. The second conductors 42 are arranged into
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`parallel rows. The second conductors 42 of each of the rows are interconnected
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`by respective ones of the second bridging lines 422. Each of the first connecting
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`lines 61 is connected to an endmost one of the first conductors 41 of respective
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`one of the columns of the first conductors 41. Each of the second connecting
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`lines 62 is connected to an endmost one of the second conductors 42 of a
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`respective one of the rows of the second conductors 42. Id. 3:21-36.
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`19. ‘503 patent further discloses the plurality of first bonding wires 63 and the
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`plurality of second bonding wires 64. Each of the first bonding wires 63 is
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`connected to a respective one of the first connecting lines 61, and extends
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`outwardly therefrom through a side edge 33 of the transparent substrate 3. Each
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`of the second bonding wires 64 is connected to a respective one of the second
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`connecting lines 62, and extends outwardly therefrom through the side edge 33 of
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`the transparent substrate 3. The first and the second bonding wires 63, 64 are
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`normally formed on a flexible board. A controller 2 is connected to the first and
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`second bonding wires 63, 64 for detecting the location where a change in the
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`electric field among first and second conductors 41, 42 occurs during the use of
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`Declaration of Dr. George E. Gerpheide
`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`the capacitive type touch panel. Id. 3:38-51.
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`
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`V. Claim Construction
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`20. I understand that in these types of proceedings, a claim is given its
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`broadest reasonable construction in light of the specification of the patent in
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`which it appears. I also understand that, at the same time, claim terms are
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`given their ordinary and customary meaning as would be understood by one of
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`ordinary skill in the art. I have followed these principles in my analysis. I
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`discuss a claim term below and what I understand to be Petitioner’s construction
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`of the term.
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`21. Claims 1-12 of the ‘503 patent recite “transparent substrate” in similar
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`context. Applying the broadest reasonable construction, consistent with the
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`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`specification, the term “transparent substrate” as used in claims 1-12 of the ‘503
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`patent includes a substrate with a transmittance of less than 100 percent. The
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`amount of transparency of a substrate is determined by its transmittance, and
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`transmittance is defined as the amount of light that travels through the substrate.
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`The amount of light transmitted through the substrate is determined by 1) the
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`substrate’s thickness, 2) the wavelength of the incident light on the substrate, and
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`3) the refractive index of the material that is used to build the substrate. (Ex.
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`1013 Technical Information, Optics for Devices, Transmittance of Optical Glass,
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`University of Arizona, October 2005, “http:// fp.optics.arizona.edu/optomech/
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`references/glass/Schott/tie35_transmittance_us.pdf ). The ‘503 specification does
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`not provide the details of the thickness of the substrate nor the wavelength of the
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`light. The materials described in the ‘503 specification have a wide range of
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`refractive
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`indexes,
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`thus generating substrates with differing
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`levels of
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`transmittance and varying degrees of transparency, none of which is perfectly
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`100% transparent. Therefore, applying the broadest reasonable construction, the
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`term “transparent substrate” should be construed as a substrate with transparency
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`less than 100% and varying depending on which materials are used; and in my
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`opinion this meaning would commonly be expressed as the term “substantially
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`transparent substrate”.
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`22. Claim 5-8 of the ’503 patent recite “plurality of holes” in similar context.
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`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`Applying the broadest reasonable construction, consistent with the specification,
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`the term “plurality of holes” as used in claims 5-8 of the ’503 patent means that
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`holes are made on the conductive film and once the hole is made no material
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`exists on the conductive film where the holes are located. I understand that the
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`Petitioner has offered that the broadest reasonable construction of the term
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`“plurality of holes” that is consistent with the specification is that “holes are
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`made on the conductive film and once the hole is made no material exists on the
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`conductive film where the holes are located” I have used this construction in my
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`analysis and agree with it because the claim language and the examples in the
`
`specification support this construction.
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`23. Claim 6 of the ’503 patent recites “through-holes” in similar context.
`
`Applying the broadest reasonable construction, consistent with the specification,
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`the term “through-holes” as used in claims 5-8 of the ’503 patent means that
`
`holes are made on the conductive film and once the hole is made no material
`
`exists on the conductive film where the holes are located. I understand that the
`
`Petitioner has offered that the broadest reasonable construction of the term
`
`“through holes” that is consistent with the specification is that “holes are made on
`
`the conductive film and once the hole is made no material exists on the
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`conductive film where the holes are located.” I have used this construction in my
`
`analysis and agree with it because the claim language and the examples in the
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`Regarding Petition for IPR of U.S. Patent No. 7,864,503
`specification support this construction.
`
`VI. Certain References Disclose All the Claimed Features of the ’503
`Patent
`
`24. In my opinion, several references disclose the features recited in the
`
`claims of the ’503 patent.
`
`A. Fujitsu, Either Individually or in Combination with Other References,
`
`Discloses All the Claimed Features
`
`25. In my opinion, Fujitsu, either individually or in combination with other
`
`references, i.e., Bolender, Lai, Takeda, Aoki, Fong, Jain, Seguine, Chen,
`
`Ohtake, Nakanishi-1, and Naknishi-2 discloses the features recited in the claims
`
`of the ’503 patent. It is noted that the English translation of Fujitsu (Ex. 1006)
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`contains page and line references which I have cited in this report, and Petitioner
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`indicates that each such reference relates the English text following in Ex. 1006
`
`to a location in the Japanese Fujitsu patent Ex. 1005.
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`1. Fujitsu Discloses Each and Every Feature Recited in claims 1, 2,
`and 3.
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`26. In my opinion, and as shown in the chart below, Fujitsu discloses each and
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`every feature recited in claims 1, 2, and 3.
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`Declaration of Dr. George Declaration of Dr. George E. Gerpheide
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`Regarding Petition for IPR of U.S. Patent No. 7,864,503Regarding Petition for IPR of U.S. Patent No. 7,864,503
`
`a. Claim 1
`
`
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`27. Fujitsu discloses eacheach and every feature of claim 1.
`
`
`‘503 patent ‘503 patent
`
`‘503 patent ‘503 patent
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`(Ex. 1001) (Ex. 1001)
`
`(Ex. 1001) (Ex. 1001)
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`claim 1claim 1
`
`claim 1claim 1
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`[1.pre] A
`capacitive type
`touch panel
`comprising
`
`[1.a] a
`transparent
`substrate
`having opposite
`top and bottom
`surfaces;
`
`[1.b] an array
`
`
`
`
`FujitsuFujitsu(Ex. 1006)(Ex. 1006)(Ex. 1006)(Ex. 1006)
`
`
`FujitsuFujitsu
`
`
`
`(Ex. 1006)(Ex. 1006)(Ex. 1006)(Ex. 1006)
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`
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`Fujitsu disclodiscloses a capacitive touch panel:
`
`
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`“The present invention relates to a coordinates input device The present invention relates to a coordinates input device The present invention relates to a coordinates input device
`
`
`for detecting instructed coordinates using a change of for detecting instructed coordinates using a change of for detecting instructed coordinates using a change of
`
`
`capacitance and more particularly to a coordinates input capacitance and more particularly to a coordinates input capacitance and more particularly to a coordinates input
`
`
`device disposed on a surface of a screen of a displaydevice disposed on a surface of a screen of a displaydevice disposed on a surface of a screen of a display device
`
`
`and suitable for providing an input function to the display and suitable for providing an input function to the display and suitable for providing an input function to the display
`
`
`devicedevice.” [Ex. 1006, Ex. 1005 (JP): Page 2, upperPage 2, upper-left
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`column, lines 1 to 5column, lines 1 to 5]
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`
`
`Fujitsu didiscloses a pattern of electrodes formedformed on a transparent
`
`
`substrate.substrate. Fig. 5-(A) of Fujitsu shows the transparent substrate 100 and shows the transparent substrate 100 and
`
`
`the substrate has top and bottom surfacesthe substrate has top and bottom surfaces. [Ex. 1006, Ex. 1005:. [Ex. 1006, Ex. 1005: Page 4,
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`upper-left column, line 19 to upperleft column, line 19 to upper-right column, line 13right column, line 13]
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`FujitsuFujitsu Fig. 5-(A) below discloses X electrodes 101 formed on discloses X electrodes 101 formed on
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`13
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`Page 17 of 77
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`Wintek Exhibit 1029
`IPR2013-00568
`
`

`
`
`Declaration of Dr. George Declaration of Dr. George E. Gerpheide
`
`Regarding Petition for IPR of U.S. Patent No. 7,864,503Regarding Petition for IPR of U.S. Patent No. 7,864,503
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`the surface of transparent substrate 100.the surface of transparent substrate 100. FujitsuFujitsu Fig. 5-(B) shows
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`that both X electrode 101 and Y electrode 102 are on thethat both X electrode 101 and Y electrode 102 are on thethat both X electrode 101 and Y electrode 102 are on the same
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`surface (surface (which may be designated the “top” surface) of may be designated the “top” surface) of
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`transparent substrate 100.transparent substrate 100. [Ex. 1006, Ex. 1005 (JP): [Ex. 1006, Ex. 1005 (JP): Page 2,
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`upper-left column, lines 1 to 5left column, lines 1 to 5].
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`of first
`conductors
`formed on said
`top surface of
`said transparent
`substrate
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`FujitsuFujitsu Fig. 7-(A) discloses an X electrode 101 that101 that is narrower
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`in an intersection portionin an intersection portion, and wider in otd wider in other portions. As
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`illustrated in the annotated Fig. 7illustrated in the annotated Fig. 7-(A), the wider p(A), the wider portions
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`correspond to first conductors correspond to first conductors of ‘503. [Ex. 1006, Ex. 1005 (JP): [Ex. 1006, Ex. 1005 (JP):
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`Page 4, lowerPage 4, lower-left column, line 12 to lower-right column, line 9]right column, line 9]
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`FujitsuFujitsu Fig. 5-(A) discloses Y electrodes 102 formed on the (A) discloses Y electrodes 102 formed on the
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`same surface of transparent substrate 100. surface of transparent substrate 100. [Ex. 1006, Ex. 1005 [Ex. 1006, Ex. 1005
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`(JP): Page 2, uppePage 2, upper-left column, lines 1 to 5]. ]. It is apparent from
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`Fig. 5-(B(B) that X and Y electrodes are on the same surface of ) that X and Y electrodes are on the same surface of
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`transparent substrate 100, which may be called the “top”.transparent substrate 100, which may be called the “top”.transparent substrate 100, which may be called the “top”.
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`[1.c] an array of
`second
`conductors
`formed on said
`top surface of
`said transparent
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`14
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`Page 18 of 77
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`Wintek Exhibit 1029
`IPR2013-00568
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`

`
`
`Declaration of Dr. George Declaration of Dr. George E. Gerpheide
`
`Regarding Petition for IPR of U.S. Patent No. 7,864,503Regarding Petition for IPR of U.S. Patent No. 7,864,503
`
`substrate and
`disposed
`alternatively
`with said first
`conductors
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`FujitsuFujitsu Fig. 7-(A) discloses a Y electrode 102 that102 that is narrower
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`(designated by W2) (designated by W2) in an intersection portion in an intersection portion and wider in other
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`portions (designated by W1). As illustrated in the annotated Fig. portions (designated by W1). As illustrated in the annotated Fig. portions (designated by W1). As illustrated in the annotated Fig.
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`7-(A), the wider p(A), the wider portions correspond to second conductors ortions correspond to second conductors of
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`‘503. [Ex. 1006, Ex. 1005 (JP): [Ex. 1006, Ex. 1005 (JP): Page 4, lowerPage 4, lower-left column, line
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`12 to lower12 to lower-right column, line 9]
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`[1.d] a plurality
`of spaced apart
`conductive first
`bridging lines,
`each of which
`interconnects
`two adjacent
`ones of said
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`
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`FujitsuFujitsu Fig. 7-(A) discloses an X electrode 101101 that is narrower
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`in an intersection portion in an intersection portion and wider in other portionsin other portions. As
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`illustrated in the annotated Fig. 7illustrated in the annotated Fig. 7-(A), the (A), the narrower portions
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`(designated W4)(designated W4) correspond to first bridging linesbridging lines of ‘503, which
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`interconnect interconnect interconnect
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`adjacent wider portions adjacent wider portions adjacent wider portions
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`(designated W3) (designated W3) (designated W3)
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`corresponding to “first conductors” of ‘503.corresponding to “first conductors” of ‘503. [Ex. 1[Ex. 1006, Ex. 1005
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`(JP): Page 4, lowerPage 4, lower-left column, line 12 to lowerleft column, line 12 to lower-right column,
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`line 9]
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`15
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`Page 19 of 77
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`Wintek Exhibit 1029
`IPR2013-00568
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`first conductors
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`
`Declaration of Dr. George Declaration of Dr. George E. Gerpheide
`
`Regarding Petition for IPR of U.S. Patent No. 7,864,503Regarding Petition for IPR of U.S. Patent No. 7,864,503
`
`
`
`
`
`FujitsuFujitsu Fig. 7-(A) discloses a Y electrode 102 that is narrower (A) discloses a Y electrode 102 that is narrower
`
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`in an intersection portion and wider in other portions. As in an intersection portion and wider in other portions. As in an intersection portion and wider in other portions. As
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`illustrated in the annotated Fig. 7illustrated in the annotated Fig. 7-(A), the narrower portions (A), the narrower portions
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`(designated W(designated W2) correspond to second bridging lines of ‘503, bridging lines of ‘503,
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`which interconnect adjacent wider portions (designated W1) which interconnect adjacent wider portions (designated W1) which interconnect adjacent wider portions (designated W1)
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`corresponding to “second conductors” of ‘503. [Ex. 1006, Ex. corresponding to “second conductors” of ‘503. [Ex. 1006, Ex. corresponding to “second conductors” of ‘503. [Ex. 1006, Ex.
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`1005 (JP): 1005 (JP): Page 4, lower-left column, line 12 to lowerleft column, line 12 to lower-right
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`column, line 9]column, line 9]
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`[1.e] a plurality
`of spaced apart
`conductive
`second bridging
`lines, each of
`which
`interconnects
`two adjacent
`ones of second
`conductors and
`each of which
`intersects
`insulatively a
`respective one
`of said first
`bridging lines
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`
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`It is apparent from Fig. 7parent from Fig. 7-(A) Annotated that bridging lines cross, (A) Annotated that bridging lines cross,
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`and FujitsuFujitsu discloses that X electrodes 101 and Y electrodes 102 discloses that X electrodes 101 and Y electrodes 102
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`are disposed in an insulated manner relative to each other. [Ex. are disposed in an insulated manner relative to each other. [Ex. are disposed in an insulated manner relative to each other. [Ex.
`
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`1006, Ex. 1005 (JP): 1006, Ex. 1005 (JP): Page 3, upper-right column, line 2 to lowerright column, line 2 to lower-
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`left column, line 20]eft column, line 20]. See also Fujitsu Fig. 5-(B).(B).
`
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`[1.f] a plurality
`of spaced apart
`insulators, each
`of which is
`disposed at an
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`Fujitsu Figs. 5(A) and (B) illustrate insulating film 103 covering a Figs. 5(A) and (B) illustrate insula