IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`PATENT: RE43,707
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`INVENTOR: TOM KIMPE ET AL.
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`FILED: DECEMBER 28, 2011
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`ISSUED: OCTOBER 2, 2012
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`TITLE: METHODS, APPARATUS, AND DEVICES FOR NOISE REDUCTION
`___________________________________________________________
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. RE43,707
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
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`03220.23279/5705654.4
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`
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`PATENT: RE43,707
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`INVENTOR: TOM KIMPE ET AL.
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`FILED: DECEMBER 28, 2011
`
`ISSUED: OCTOBER 2, 2012
`
`TITLE: METHODS, APPARATUS, AND DEVICES FOR NOISE REDUCTION
`___________________________________________________________
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. RE43,707
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
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`03220.23279/5705654.4
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`TABLE OF CONTENTS
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`I. MANDATORY NOTICES ................................................................................. 1
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`A. Real Parties-in-Interest .................................................................................... 1
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`B. Related Matters ................................................................................................ 1
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`C. Counsel .......................................................................................................... 1
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`D. Service Information ......................................................................................... 1
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`II. CERTIFICATION OF GROUNDS FOR STANDING ...................................... 1
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`III. OVERVIEW OF CHALLENGE AND RELIEF REQUESTED .................... 2
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`A. Prior Art Patents and Printed Publications ...................................................... 2
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`B. Grounds for Challenge ..................................................................................... 3
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`IV. OVERVIEW OF THE ‘707 PaTENT ............................................................. 4
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`V. CLAIM CONSTRUCTION ..............................................................................10
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`VI. LEVEL OF ORDINARY SKILL IN THE ART ...........................................11
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`VII. STATEMENT OF MATERIAL FACTS ......................................................11
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`VIII. IDENTIFICATION OF HOW THE CHALLENGED CLAIMS ARE
`UNPATENABLE ..........................................................................................21
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`
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`A. Claims 36, 46 and 54 are obvious over Kawase (Ex. 1002) in view of Kanai
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`(Ex. 1003) .............................................................................................................21
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`B. Claims 64 and 65 are anticipated by Kamada (Ex. 1004) .............................29
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`C. Claims 77-79 and 94 are anticipated by Nakai (Ex. 1005) ...........................31
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`U.S. Patent RE43,707
`Petition for Inter Partes Review
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`D. Claim 93 is obvious over Nakai (Ex. 1005) in view of Mizukoshi (Ex. 1006)
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`34
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`E. Claim 94 is obvious over Nakai (Ex. 1005) in view of Koyama (Ex. 1007) 36
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`F. Claims 101-104 are obvious over Greene (Ex. 1008) in view of Kamada (Ex.
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`1004) .....................................................................................................................37
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`G. Claim 107 is anticipated by Greene (Ex. 1008) ............................................41
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`H. Claim 107 is obvious over Greene (Ex. 1008) in view of Kuratomi (Ex.
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`1009) .....................................................................................................................42
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`IX. CONCLUSION ..............................................................................................45
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`U.S. Patent RE43,707
`Petition for Inter Partes Review
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`Cases
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`TABLE OF AUTHORITIES
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`In re GPAC Inc., 57 F.3d 1573 (Fed. Cir. 1995)....................................................11
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`In re Geisler, 116 F.3d 1465, 1469 (Fed. Cir. 1997)..............................................26
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`Statutes
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`§ 102 ............................................................................................................. passim
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`§ 103 ............................................................................................................. passim
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`35 U.S.C. § 314(a) ................................................................................................. 4
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`Rules and Other Authorities
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`37 C.F.R. § 42.22 ...............................................................................................2, 11
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`37 C.F.R. § 42.104 .........................................................................................1, 2, 21
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`I. MANDATORY NOTICES
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`A. Real Parties-in-Interest
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`Eizo Corporation (“Petitioner”) is the real party-in-interest.
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`B. Related Matters
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`The following matters would affect or be affected by a decision in this
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`proceeding: Barco, N.V. et al v. Eizo Nanao Corporation et al, 11-cv-00258 (N.D.
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`Ga.); inter partes reexamination application no. 95/002,047 and ex parte
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`reexamination application no. 90/020,037
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`C. Counsel
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`Lead Counsel: Marc K. Weinstein (Registration No. 43,250)
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`D. Service Information
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`Email: marcweinstein@quinnemanuel.com
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`Post: Quinn Emanuel Urquhart & Sullivan LLP, NBF Hibiya Bldg., 25F,
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`1-1-7 Uchisaiwai-cho, Chiyoda-ku, Tokyo 100-0011, Japan
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`Telephone: +813-5510-1711 Facsimile: +813-5510-1712
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`II. CERTIFICATION OF GROUNDS FOR STANDING
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`Petitioner certifies pursuant to Rule 42.104(a) that the patent for which review
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`is sought is available for inter partes review and that Petitioner is not barred or
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`estopped from requesting an inter partes review challenging the patent claims on
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`the grounds identified in this Petition.
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`U.S. Patent RE43,707
`Petition for Inter Partes Review
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`III. OVERVIEW OF CHALLENGE AND RELIEF REQUESTED
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`Pursuant to Rules 42.22(a)(1) and 42.104(b)(1)-(2), Petitioner challenges
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`claims 36, 46, 54, 64, 65, 77-79, 93, 94, 101-104, and 107 of U.S. Patent No.
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`RE43,707 (“the ‘707 patent,” Ex. 1001).
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`A. Prior Art Patents and Printed Publications
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`Petitioner relies upon the following patents and printed publications. Unless
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`otherwise noted, the listed patents and printed publications were never cited nor
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`applied during the original prosecution of the ‘707 patent:
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`Exhibit 1002 - U.S. Patent No. 7,227,519 (“Kawase”), published June 5,
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`2007, and filed April 4, 2002. Kawase is prior art under 35 U.S.C. § 102(e).
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`Kawase was cited, but not applied during the original prosecution of the ‘707
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`patent.
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`Exhibit 1003 - U.S. Patent App. Pub. No. 2005/0012821 (“Kanai”), published
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`January 20, 2005, and filed July 14, 2004. Kanai is prior art under 35 U.S.C. §
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`102(e).
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`Exhibit 1004 - U.S. Patent App. Pub. No. 2005/0093798 (“Kamada”),
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`published May 5, 2005, and filed May 11, 2004. Kamada is prior art under 35
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`U.S.C. § 102(e).
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`Exhibit 1005 - U.S. Patent No. 5,359,342 (“Nakai”), issued October 25, 1994.
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`Nakai is prior art under 35 U.S.C. § 102(b). Nakai was cited, but not applied
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`during the original prosecution of the ‘707 patent.
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`Exhibit 1006 - U.S. Patent App. Pub. No. 2005/0023986 (“Mizukoshi”),
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`published February 3, 2005, and filed July 29, 2003. Mizukoshi is prior art under
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`35 U.S.C. § 102(e).
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`Exhibit 1007 - U.S. Patent No. 7,050,074 (“Koyama”), issued May 23, 2006,
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`and filed June 13, 2000. Koyama is prior art under 35 U.S.C. § 102(e).
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`Exhibit 1008 - U.S. Patent No. 6,271,825 (“Greene”), published August 7,
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`2001. Greene is prior art under 35 U.S.C. § 102(b).
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`Exhibit 109 - U.S. Patent No. 6,791,566 (“Kuratomi”), published September
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`14, 2004, and filed March 18, 2002. Kuratomi is prior art under 35 U.S.C. §
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`102(e).
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`B. Grounds for Challenge
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`Petitioner requests cancelation of the challenged claims under the following
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`statutory grounds:
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`A. Claims 36, 46 and 54 are obvious over Kawase in view of Kanai under 35
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`U.S.C. § 103(a).
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`B. Claims 64 and 65 are anticipated by Kamada under 35 U.S.C. § 102(e).
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`C. Claims 77-79 and 94 are anticipated by Nakai under 35 U.S.C. § 102(b).
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`D. Claim 93 is obvious over Nakai in view of Mizukoshi under 35 U.S.C.
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`§ 103(a).
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`E. Claim 94 is obvious over Nakai in view of Koyama under 35 U.S.C. §
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`103(a).
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`F. Claims 101-104 are obvious over Greene in view of Kamada under 35
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`U.S.C. § 103(a).
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`G. Claim 107 is anticipated by Greene under 35 U.S.C. § 102(b).
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`H. Claim 107 is obvious over Greene in view of Kuratomi under 35 U.S.C. §
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`103(a).
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`Section VIII below contains detailed claim charts that demonstrate, for each of
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`the statutory grounds, that there is a reasonable likelihood that Petitioner will
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`prevail with at least one of the challenged claims. See 35 U.S.C. § 314(a).
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`IV. OVERVIEW OF THE ‘707 PATENT
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`The application that issued as the ‘707 patent (Ex. 1001) was filed December
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`28, 2011, as a reissue of U.S. Patent No. 7,639,849 (“the ‘849 patent”), which
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`issued on December 29, 2009 and was filed on May 23, 2005. The ‘849 patent
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`claims priority to provisional application no. 60/681,429, filed May 17, 2005.
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`The ‘707 patent describes a system and method for reduction of the non-
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`uniformity of pixel light-output behavior present in matrix addressed electronic
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`display devices such as plasma displays, liquid crystal displays, LED and OLED
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`displays. (Ex. 1001 at 4:36-41). People skilled in the art understand that light-
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`output values are luminance and/or color values of individual pixels. (9:20-25).
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`As shown in Fig. 1 below, a matrix display 2 has pixels 4 arranged in rows
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`and columns where all pixels have equal luminance response in all pixels 4 when
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`driven with the same signal. (5:35-42).
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`In contrast, Fig. 2 below illustrates a case where the pixels 4 render a
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`different luminance response despite being driven by the same signal, as can be
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`seen by the different grey values. (5:42-46).
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`To be able to correct matrix display pixel non-uniformities, the ‘707 patent
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`teaches that it is desirable to detect the light-output of each individual pixel. (6:7-
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`9). In the embodiments of Figs. 4 and 5, a scanner 6 and a CCD camera 12 are
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`designed to have enough luminance sensitivity and resolution to provide a precise
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`measure of the luminance emitted by each pixel 4. (6:24-34; 6:46-51).
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`To determine the light-output response of each pixel 4, all pixels are driven
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`with the same drive signal or driving level to obtain a test image. (9:25-39). As
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`shown in Fig. 7 below, the response function of each pixel can then be determined
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`by obtaining a test image at a plurality of different driving levels. (9:43-46)
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`The curve 30 in Fig. 7 is constructed using eleven characterization points 32,
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`which result from the display and acquisition of images and the calculation of
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`luminance levels for a given pixel 4. (9:46-49). The light-output response
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`functions of individual pixels 4 may all be different or the response functions may
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`be reduced to a smaller number of typical or representative functions, and each
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`pixel may be assigned to one of these typical functions. (9:58-62). The response
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`function may be represented by a number of suitable means for storage and
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`retrieval, e.g. in the form of an analytical function, in the form of a look-up table or
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`in the form of a curve. (9:40-43).
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`As an example for eliminating non-uniform light-output responses, pixels
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`with curves A, B and C in Fig. 10 can be equalized to show a behavior as indicated
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`by curve D. (12:3-5). A specific transfer curve matched for every pixel 4 may be
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`used to compensate the behavior of every individual pixel's characteristic
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`luminance response curve Ln. (12:19-24). This signal conversion principle, when
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`applied individually to every such pixel 4, allows equalization of the overall
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`response for all pixels. (12:24-27). In this way, any unequal luminance behavior
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`over the display area may be cured or modified. (12:27-28).
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`Fig. 21 below shows a flow chart of a method M100 in which a task T100
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`obtains a measure of a light-output response of at least a portion of the pixel at
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`each of a plurality of driving levels. (29:29-35). To increase a visibility of a
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`characteristic of a displayed image during a use of the display, task T200 modifies
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`a map that is based on the obtained measures. (29:35-38). Based on the modified
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`map and an image signal, task T300 obtains a display signal. (29:38-39).
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`Problems may exist that impair the usefulness of this non-uniform correction
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`
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`process, such as due to pixel defects. (16:11-15). To solve this problem,
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`information about defective pixels can be added to the luminance map of the
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`display and to the transfer curve of each individual pixel. (16:41-46). The
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`correction algorithm can behave differently if a pixel is marked as being defective
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`or has a defective pixel in its neighborhood. (16:46-49).
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`In another aspect of modifying the correction, the ‘707 patent discloses
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`defining an area where all pixels are equalized perfectly, but only within a defined
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`luminance interval. (12:13-15). Outside that interval, pixels with non-optimal
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`correction can exist. (12:15-16). Moreover, other reasons can result in deciding
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`whether or not to correct some pixels in a defined luminance-interval. (12:16-18).
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`The ‘707 patent also recognizes that humans experience color in such a way
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`that spectral differences, if small enough, are not perceived. (12:40-41). As a
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`result, a pixel correction can be unnecessary provided that the light output of the
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`complete pixel structure compared to the specified output differs by an amount that
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`lies within a relevant tolerance. (12:46-51). Thus, there is a certain tolerance on
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`differences in luminosity relationships of sub-pixel elements that still provide an
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`apparently uniform display such that all pixels have a luminosity and color range
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`within the acceptable limits. (12:65 – 13:7).
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`To avoid a reduction in display luminance and contrast, the ‘707 patent
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`discloses that any model of the human visual system can be used to modify the
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`correction algorithm to increase contrast and peak luminance. (21:25-58). For
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`example, models of the human visual system can be used to configure the
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`correction algorithm to correct only for those non-uniformities in light-output that
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`can actually be perceived by the human observer. (21:59-63). If the display
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`system has non-uniformities containing spatial frequencies for which the amplitude
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`is below the visual threshold, then these non-uniformities will not be visible for the
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`human observer and there is no need to try to correct them, which can increase the
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`peak luminance and contrast ratio of the display system. (22:5-13).
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`If a particular non-uniformity is visible for the human eye, a correction can
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`be applied to achieve sufficient uniformity so that the remaining non-uniformity is
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`not noticeable to the human observer. (22:15-20). For example, borders of
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`displays often have a luminance fall-off with a low spatial frequency for which the
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`human eye is not very sensitive. (22:27-31). This border luminance fall-off is
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`typically rather large as compared to the center, so that a large loss of peak
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`luminance and contrast ratio could result if the luminance fall-off were corrected
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`perfectly. (22:31-36). To maintain peak luminance and contrast ratio, this
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`luminance fall-off can remain uncorrected or only corrected sufficiently to remain
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`invisible to the human eye. (22:36-39).
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`According to the ‘707 patent, the magnitude of one or more components
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`corresponding to a range of frequencies can be increased relative to a magnitude of
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`components corresponding to frequencies above and below the range, or
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`alternatively a magnitude of components corresponding to frequencies above and
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`below the range is reduced. (23:10-16). Magnitudes of components having a
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`spatial period between one and fifty millimeters may be increased relative to
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`magnitudes of components having a spatial period less than one millimeter and
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`components having a spatial period greater than fifty millimeters. (23:16-21).
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`V. CLAIM CONSTRUCTION
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`The claim terms are presumed to take on their ordinary and customary
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`meaning. This Petition shows that the claims of the ‘707 patent are anticipated or
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`rendered obvious by the prior art identified herein when the challenged claims are
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`given their broadest reasonable interpretation in light of the specification.1
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`1 Other forums, such as the District Courts, require different standards of proof and
`claim interpretation that are not applied by the PTO for inter partes review.
`Accordingly, any interpretation or construction of the challenged claims in this
`Petition, either implicitly or explicitly, should not be viewed as constituting, in
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`VI. LEVEL OF ORDINARY SKILL IN THE ART
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`
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`The level of ordinary skill in the art is evidenced by the references. See In re
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`GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995) (determining that the Board did
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`not err in adopting the approach that the level of skill in the art was best
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`determined by the references of record). The prior art applied herein demonstrates
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`that one of ordinary skill in the art, at the time of the invention, was aware of the
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`problem of non-uniform light-output responses of a display and correcting for such
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`non-uniformities. The prior art further demonstrates that one of ordinary skill in
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`the art was aware that display characteristics and limits of human perception make
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`it unnecessary to correct for all non-uniformities.
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`VII. STATEMENT OF MATERIAL FACTS
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`Pursuant to 37 C.F.R. § 42.22, Petitioner submits the following statement of
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`material facts:
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` Kawase (Ex. 1002)
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`1. Kawase is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
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`2. The Kawase patent discloses an image processing method that includes a
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`specific luminance correction operation that may be applied to a method of driving
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`a display panel in which pixels are driven, luminance information is captured from
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`the pixels, correction values are calculated from the measured luminance
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`whole or in part, Petitioner’s own interpretation or construction, except as regards
`the broadest reasonable construction of the claims presented.
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`information and a luminance setting value, the correction values are stored in the
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`correction memory, and the driving amount is corrected in accordance with the
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`correction memory. (Ex. 1002 at 5:54-61).
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`3. Kawase discloses that an inputted video signal is separated into an RGB
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`luminance signal and horizontal and vertical signals by a video decoder 1, a
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`corrector 4 retrieves correction values from a correction value memory 5 to carry
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`out correction of the inputted luminance signals, and the corrected signals are
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`supplied to a signal driver for displaying the video signal. (10:18-60).
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`4. Kawase teaches that a display panel 9 has pixels made up of R, G, and B
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`subpixels, and a CCD 50 having the same resolution as the display panel 9 can
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`capture the luminance information from the RGB subpixels. (14:29-37).
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`5. Luminance information from the RGB subpixels is sent to the correction
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`arithmetic unit 6, and a correction value for each subpixel is calculated and stored
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`in a correction value table 5. (14:37-41).
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`6. Alternatively, Kawase teaches dividing the display panel 9 into small
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`regions, and measuring the luminance of each region by a CCD. (14:58-65).
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`7. To carry out corrections, first luminance information from all the pixels is
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`captured by the luminance capturing means and is compared with target luminance.
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`(17:31-34).
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`8. When there is a deviation from the target luminance, driving voltage is
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`changed and luminance is measured again until a voltage value that converges to
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`the target luminance is determined, and that value is written to a correction value
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`table. (17:34-41).
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`9. Kawase teaches that the correction value can be obtained for multiple
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`levels of target luminance, such as four. (Fig. 16; 17:44-49).
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`Kanai (Ex. 1003)
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`10. Kanai is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
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`11. Kanai discloses a method for correcting luminance unevenness of a
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`display device that includes a plurality of display elements and a correction circuit
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`that outputs signals obtained by performing correction on input signals to the
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`respective display elements. (Ex. 1003 at ¶¶ [0003, 0010]).
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`12. The correction circuit performs the correction so that a spatial frequency
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`distribution of luminance has a predetermined frequency component reduced or
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`omitted. (¶ [0010]).
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`13. Kanai teaches a step of reducing predetermined high frequency
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`components and reducing predetermined low frequency components from among
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`frequency components of spatial frequency data. (¶¶ [0014, 0016]).
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`14. Kanai also teaches it is possible to reduce a correction amount by
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`maintaining or reducing some frequency components causing luminance
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`unevenness to a level where the luminance unevenness is not visible. (¶ [0020]).
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`15. As shown in Fig. 6 illustrating the spatial frequency characteristic of the
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`luminance unevenness discrimination threshold of a human being, human visual
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`sensation generally exhibits a larger discrimination threshold with respect to lower-
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`frequency luminance unevenness, i.e., that human beings have difficulty in
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`discriminating low-frequency luminance unevenness. (¶ [0079]).
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`16. Figs. 8A and 8B show that both low-frequency unevenness and high-
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`frequency unevenness are large and cause image quality problems. (¶ [0087]).
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`17. Kanai teaches that applying correction processing approximately
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`completely eliminates the high-frequency unevenness and reduces the low-
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`frequency unevenness to a negligible degree. (¶ [0088]).
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`18. A "passage region" means a frequency range that cannot easily be
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`detected by human eyes even if its frequency component remains. (¶ [0093]).
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`19. Applying correction to the “passage region,” Kanai teaches only
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`maintaining the frequency components in the passage region. (¶ [0098]).
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`Kamada (Ex. 1004)
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`20. Kamada is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
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`21. Kamada discloses a display correction circuit for a display apparatus,
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`such as a liquid crystal display, that corrects uneven image appearance caused by
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`the characteristics of the display apparatus. (Ex. 1004 at ¶¶ [0002, 0004]).
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`22. Liquid crystal display apparatus 10 includes a memory 12 that stores
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`correction data for use in the correction of uneven appearance, a signal source 13
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`that supplies image data signals for display on a liquid crystal display panel 14, and
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`an image processing apparatus 11 that corrects the image data signals supplied
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`from the signal source 13 based on the correction data supplied from the memory
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`12, thereby adjusting the gray levels of the image data signals. (¶ [0042]).
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`23. Kamada teaches that the gray levels of the image data signals are
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`adjusted to display an image with reduced uneven appearance. (¶ [0042]).
`
`24. The image processing apparatus 11 includes a correction data storage
`
`unit 21 that stores correction data and provides the stored data to a correction
`
`processing unit 22, which corrects image data signals from a FIFO 23 by adjusting
`
`the gray levels of the image data signals. (¶ [0043]).
`
`25. As shown in Fig. 2, Kamada teaches reducing the amount of correction
`
`applied to pixels located in a surrounding border region of the display. (¶ [0045]).
`
`26. Within the rectangular region defined by points (x1, y1) and (x2, y2), a
`
`constant correction value k is applied, but the correction value gradually decreases
`
`in the surrounding region toward an outer edge of the surrounding region until it
`
`becomes zero at distance w1 from the edge of the rectangular region. (¶ [0045]).
`
`27. Defining gray level changes in the surrounding region in an isotropic
`
`manner with respect to the x direction and the y direction has an advantage in the
`
`small size of correction data. (¶ [0047]).
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`28. Kamada also teaches that uneven appearance becomes conspicuous
`
`depending on halftone (i.e., gray level) such that when display data is close to
`
`black (i.e., close to zero) or close to white (i.e., close to 255 in the case of 256 gray
`
`levels), there is no need for uneven appearance correction. (¶ [0049]).
`
`29. As shown in Fig. 4, the correction value is set to k for halftones inside a
`
`range between a gray level g1 and a gray level g2, and linearly decreases from k to
`
`zero in the regions having the width w2. (¶ [0049]).
`
`30. In relation to Fig. 7, Kamada teaches adjusting the correction value
`
`based both on the input gray level and display position. (¶ [0059]).
`
`
`
`Nakai (Ex. 1005)
`
`31. Nakai is prior art against the ‘707 patent under 35 U.S.C. § 102(b).
`
`32. Nakai recognizes that display non-uniformity characteristics differ at
`
`individual screen positions in liquid crystal displays and addresses this problem by
`
`teaching the use of a look-up-table memory that stores correction data for each of a
`
`plurality screen split regions. (Ex. 1005 at 1:61-64; 2:37-40)
`
`33. Nakai discloses that a liquid crystal display device includes a video
`
`signal compensation apparatus 10, a correction processor 11, and a look-up-table
`
`memory 11b. (4:1-4).
`
`34. Video input signals are inputted to the address of the look-up-table
`
`memory 11b and subjected to correction based on the data in the table, and the
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`corrected video signals are converted to analog signals for display on the liquid
`
`crystal panel. (4:11-20).
`
`35. To determine the correction data, Nakai teaches detecting brightness
`
`levels at measured points A, B and C denoting representative points of the screen
`
`split region and determining correction data to store in the look-up-table memory
`
`by calculating inverse curves as shown in Fig. 4. (4:49-66).
`
`36. As shown in Fig. 5, a normalization level can be set to the minimum
`
`output level for the maximum screen brightness output level of the screen split
`
`regions, which is the value c at the measuring point C. (5:9-18).
`
`37. Using the value c as the normalization level, the correction data stored in
`
`the look-up-table memory by screen split region is calculated by using the portion
`
`of the screen brightness from zero level to the normalization level c, which limits
`
`the maximum screen brightness output to the normalization level c, as shown by
`
`the solid line in Fig. 6. (5:18-35).
`
`38. Nakai alternatively teaches normalizing by color within each screen split
`
`region, as shown in Figs. 8 and 9, which results in the maximum screen brightness
`
`output shown in Fig. 10. (5:44 – 6:10).
`
`39. Calculating the correction data as explained with respect to Figs. 8-10
`
`prevents the deterioration of screen contrast when performing a linearity correction
`
`while improving the uniformity of the whole screen. (6:13-17).
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` Mizukoshi (Ex. 1006)
`
`40. Mizukoshi is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
`
`41. Mizukoshi teaches an efficient use of a lookup table for adjusting
`
`luminance through gamma compensation of a display device. (Ex. 1006 at ¶
`
`[0014]).
`
`42. Mizukoshi discloses generating data for the table according to a stored
`
`equation, making it unnecessary to store all the table data or to have a large
`
`capacity storage. (¶ [0019]).
`
`43. The stored equation is obtained by making the panel emit light at
`
`different input signal levels, detecting the luminous amount, determining a
`
`relationship between the input image signal level and the luminous amount, and
`
`calculating an approximate expression or a prescribed coefficient of the
`
`approximate expression indicating their relationship. (¶ [0021]).
`
`44. More specifically, Mizukoshi teaches measuring L-V (luminance-input
`
`voltage) characteristics of several points for RGB, creating an expression of the
`
`curve passing through the obtained points and the origin point, and obtaining an
`
`expression of the reverse characteristic to determine coefficients a, b, c, d of this
`
`expression. (¶¶ [0050, 0051]).
`
`
`
`Koyama (Ex. 1007)
`
`45. Koyama is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
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`46. Koyama relates to an apparatus for suppressing color unevenness in
`
`displayed images of a liquid crystal panel (Ex. 1007 at 1:24-52).
`
`47. In particular, Koyama teaches correcting image data displayed on a
`
`liquid crystal panel 160 with a gain corrector 120 to suppress color unevenness, the
`
`gain corrector 120 having a constant table 220 that stores correction gains for each
`
`pixel. (4:15-20; 4:43-47).
`
`48. For generating the correction gains, the pixels can be divided into
`
`multiple areas beforehand, and the correction gain of any given pixel present in an
`
`area can be determined by interpolation from the correction gains determined for
`
`particular pixels of the area. (10:51-55).
`
`49. Using this interpolation is advantageous in not requiring the correction
`
`gains of all pixels to be calculated in advance and reduces the size of the constant
`
`table for storing the determined correction gains. (10:55-60).
`
`
`
`Greene (Ex. 1008)
`
`50. Greene is prior art against the ‘707 patent under 35 U.S.C. § 102(b).
`
`51. Greene discloses an apparatus for correcting spatial non-uniformities in
`
`brightness in flat-panel displays, both for gradual non-uniformities in monolithic
`
`displays and for abrupt variations in tiled displays. (Ex. 1008 at Abstract).
`
`52. Greene teaches acquiring correction parameters via brightness
`
`measurements over selected pixels, storing them after suitable transformations, and
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`U.S. Patent RE43,707
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`performing corrections for selected pixels or all pixels of the display such that any
`
`remaining gradual and abrupt brightness non-uniformities over the selected display
`
`pixels fall below a detectable threshold under the intended viewing conditions.
`
`(Abstract; 4:35-36; 4:50-58).
`
`53. Greene recognizes that human factors are significant in the perception of
`
`displayed colors, and that perception tests show that gradual color non-uniformities
`
`occurring continuously over many pixels are less perceptible such that gradual
`
`color coordinate changes as large as 10 to 20% over the size of the display screen
`
`may not be disturbing to an average viewer. (6:4-5; 6:56-64).
`
`54. Greene describes brightness as the appearance of the radiant flux of an
`
`object, and the psychophysical equivalent to brightness is luminance. (7:43-47).
`
`55. Greene teaches that luminance is quantified as luminous flux per
`
`projected area of the source of light, and that Weber’s fraction measures the ability
`
`of the human eye to discriminate between two luminances. (7:49-54).
`
`56. To make an electronic color display uniform in terms of luminance, the
`
`resultant luminance must be controlled wit
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