Filed on behalf of: Wintek Corporation
`By:
`Joseph E. Palys
`Naveen Modi
`
`FINNEGAN, HENDERSON, FARABOW,
`
`GARRETT & DUNNER, L.L.P.
`
`901 New York Avenue, NW
`
`Washington, DC 20001-4413
`Telephone: 202-408—4000
`Facsimile: 202—408-4400
`
`E—mail: joseph.palys@flnnegan.com
`naveen.modi@f1nnegan.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WINTEK CORPORATION
`
`Petitioner
`
`V.
`
`TPK TOUCH SOLUTIONS INC.
`
`Patent Owner
`
`Patent 8,217,902
`
`DECLARATION OF DR. VIVEK SUBRAMANIAN
`
`Page 1 of 84
`Page 1 of 84
`
`Wintek Exhibit 1013
`Wintek Exhibit 1013
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`TABLE OF CONTENTS
`
`II.
`
`III.
`
`IV.
`
`VI.
`
`Introduction ..................................................................................................... l
`
`Qualifications .................................................................................................. 2
`
`Summary of Opinions ..................................................................................... 4
`
`Overview of the ’902 Patent ........................................................................... 6
`
`Claim Construction ....................................................................................... 13
`
`Certain References Disclose or Suggest All the Features of Claims 20,
`23, 28, and 30 of the ’902 Patent .................................................................. 13
`
`A.
`
`Binstead in Combination with Miller and Other References,
`
`Discloses or Suggests All the Features of Claims 23 and 30 ............. l3
`
`1.
`
`Binstead and Miller Disclose Each and Every Feature
`Recited in Claims 17 and 25 .................................................... 14
`
`a)
`
`b)
`
`Claim 17 ......................................................................... 14
`
`Claim 25 ......................................................................... 37
`
`2.
`
`3.
`
`Binstead, Miller, and Seguine Disclose or Suggest Each
`and Every Feature Recited in Claims 23 and 30 ...................... 42
`
`Binstead, Miller, and Honeywell Disclose or Suggest
`Each and Every Feature Recited in Claims 20, 23, 28,
`and 30 ....................................................................................... 45
`
`B.
`
`Fujitsu in Combination with Miller and Other References,
`Discloses or Suggests All the Features of Claims 23 and 30 ............. 50
`
`1.
`
`Fujitsu and Miller Disclose Each and Every Feature
`Recited in Claims 17 and 25 .................................................... 50
`
`a)
`
`b)
`
`Claim 17 ......................................................................... 50
`
`Claim 25 ......................................................................... 69
`
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`2.
`
`3.
`
`Fujitsu, Miller, and Seguine Disclose or Suggest Each
`and Every Feature Recited in Claims 23 and 30 ...................... 74
`
`Fujitsu, Miller, and Honeywell Disclose or Suggest Each
`and Every Feature Recited in Claims 23 and 30 ...................... 78
`
`VII. Conclusion .................................................................................................... 81
`
`Page 3 of 84
`Page 3 of 84
`
`ii
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`I, Vivek Subramanian, declare as follows:
`
`I.
`
`Introduction
`
`1.
`
`I have been retained by Wintek Corporation (“Petitioner”) as an
`
`independent expert consultant in this proceeding before the United States Patent
`
`and Trademark Office. Although I am being compensated at my rate of $550 per
`
`hour for the time I spend on this matter, no part of my compensation is dependent
`
`on the outcome of this proceeding, and I have no other interest in this proceeding.
`
`2.
`
`I understand that this proceeding involves US. Patent No. 8,217,902
`
`(“the ’902 patent”) (Ex. 1001)], the application for which was filed on August 21,
`
`2007, as US. Patent Application No. 11/842,747, and issued on July 10, 2012.
`
`I
`
`also understand that the ’902 patent is based on Taiwanese Patent Application No.
`96115152, which was filed on April 27, 2007.
`I further understand that the ’902
`
`patent is assigned on its face to TPK Touch Solutions Inc. (“Patent Owner”).
`
`3.
`
`I have been asked to consider whether certain references disclose or
`
`suggest the features recited in claims 20, 23, 28, and 30 of the ’902 patent. My
`
`opinions are set forth below.
`
`1 Where appropriate, I refer to exhibits attached to the petition for Inter Partes
`
`Review of the ’902 patent.
`
`Page 4 of 84
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`

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`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`11.
`
`Qualifications
`
`4.
`
`My curriculum vitae, which includes a detailed summary of my
`
`background and experience and a list of my publications and patents is attached as
`
`Exhibit 1014. In addition to the information provided in Exhibit 1014, I have also
`
`provided declarations
`
`regarding the
`
`’902 patent
`
`in IPR2013—00567
`
`and
`
`IPR2013-00568.
`
`5.
`
`I am a Professor in the Department of Electrical Engineering &
`
`Computer Sciences at the University of California, Berkeley, located at Berkeley,
`
`California.
`
`6.
`
`I was awarded a BS. degree from Louisiana State University in 1994,
`
`a MS. degree from Stanford University in 1996, and a Ph.D. degree from Stanford
`
`University in 1998, all in electrical engineering.
`
`7.
`
`Since 2000, I have held various research and teaching positions in the
`
`Department of Electrical Engineering and Computer Sciences at the University of
`
`California, Berkeley.
`
`I have published more than 200 technical papers in journals
`
`and technical conferences and I am an inventor of more than 30 patents covering
`
`various technologies, including semiconductor devices, materials, circuit design,
`
`process technology, and memory architecture.
`
`8.
`
`I also have significant experience in the industry. For example, in
`
`1998, I co-founded Matrix Semiconductor, Inc., a Silicon Valley startup that made
`
`Page 5 of 84
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`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`high-density memory devices.
`
`I served as Chief Technology Advisor at QuSwami,
`
`Inc., from 2008-2011, which is an energy conversion device startup company. I
`
`also founded in 2004 and serve as Scientific Advisor to Kovio, Inc., which is a
`
`printed electronics startup company.
`
`9.
`
`Through the course of my research and development activities in
`
`industry and academia,
`
`I have had extensive experience with touch-screen
`
`technology and more generally with display technology as a whole. Starting in
`
`1994, I developed flat panel process technologies for both touch screens and
`
`displays,
`
`including specifically developing Indium Tin Oxide (ITO)—based
`
`conductor technology as are discussed in the patent at issue herein. Furthermore, I
`
`have worked on resistive and capacitive touch sensors as part of my academic
`
`research, both as a graduate student, and as a professor, and have also continued to
`
`maintain significant research activities in flat panel displays and user interface
`
`technologies throughout this period.
`
`10.
`
`I am a member of the Institute of Electrical and Electronic Engineers
`
`(IEEE) and have served on the technical committees for the Device Research
`
`Conference and the International Electron Device Meeting.
`
`I have also served as
`
`the scientific chair
`
`for
`
`the Large Area, Organic, and Printed Electronics
`
`Conference (LOPE—C), a major international conference catering to large area
`
`electronic systems such as displays, user interfaces, etc.
`
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`11.
`
`I have received accolades for my achievements in academia as well as
`
`in the industry. For example, I was awarded the 2005 EDN Innovation Award, I
`
`was awarded the National Science Foundation Young Investigator Award
`
`(CAREER), I was a finalist for 2003 World Technology Award for Information
`
`Technology Hardware, I was nominated to Scientific American’s SA50 List for
`
`Visionary Technology, I was nominated to Technology Review’s list of top 100
`
`young innovators (TR100), and I was nominated to the National Academy of
`
`Engineering’s “Frontiers of Engineering.”
`
`12.
`
`I have previously served as a technical expert in litigations between
`
`Apple and Nokia and between Apple and Motorola in which the patents at issue
`
`related to touch screen technology.
`
`13.
`
`I am not an attorney and offer no legal opinions, but in the course of
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a person skilled in the art.
`
`III.
`
`Summary of Opinions
`
`14. All of the opinions contained in this Declaration are based on the
`
`documents I reviewed and my knowledge and professional judgment.
`
`In forming
`
`the opinions expressed in this Declaration, I reviewed the ’902 patent (Ex. 1001);
`
`the prosecution file history for the ’902 patent (Ex. 1002); a Request for Ex Parte
`
`Reexamination of the ’902 patent and an Order Granting Reexamination (Exs.
`
`Page 7 of 84
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`1003 and 1004); US. Patent No. 6,137,427 (“Binstead”) (Ex. 1005); Japanese
`
`Published Patent Application No. 60-75927 and the corresponding English-
`
`language translation thereof (“Fujitsu”) (Exs. 1006 and 1007); US. Patent No.
`
`5,374,787 (“Miller”)
`
`(Ex.
`
`1008); US. Patent Application Publication No.
`
`2007/0229469 (“Seguine”) (Ex. 1009); Japanese Published Patent Application No.
`
`61-84729 and the English-language translation thereof (“Honeywell”) (Exs. 1010
`
`and 1011); US. Patent Application Publication No. 2005/0030048 (“Bolender”)
`
`(Ex. 1012);
`
`and decisions
`
`from the Patent Trial
`
`and Appeal Board in
`
`IPR2013-00567 and IPR2013—00568, while drawing on my experience and
`
`knowledge of touch screens.
`
`15. My opinions have been also guided by my appreciation of how a
`
`person of ordinary skill in the art would have understood the claims of the ’902
`
`patent at the time of the alleged invention, which I have been asked to initially
`
`assume is April 27, 2007, the filing date of the Taiwanese priority application.
`
`16.
`
`In my opinion, a person of ordinary skill in the art relevant to the
`
`technology of the ’902 patent would have had a bachelor’s degree in electrical
`
`engineering, or an equivalent field, and two to three years of experience working in
`
`the relevant field, which includes display and/or related user interface device
`
`technologies.
`
`Page 8 of 84
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of U.S. Patent No. 8,217,902
`
`17.
`
`Based on my experience and expertise, it is my opinion that certain
`
`references disclose or suggest all the features recited in claims 20, 23, 28, and 30
`
`of the ’902 patent.
`
`IV. Overview of the ’902 Patent
`
`18.
`
`The ’902 patent is directed to a “conductor pattern structure of a
`
`capacitive touch panel,” and a method of constructing such touch panel. Ex. 1001,
`
`Abstract; see also 3:12-19,2 6:17—33. The ’902 patent purports to “[simplify] the
`
`structure and [reduce] the thickness of the structure” of a capacitive touch panel.
`
`Id. at 3:53-54.
`
`19.
`
`In the Background section, the ’902 patent notes that the use of ITO
`
`was well known in the manufacture of conventional touchscreens at the time of the
`
`alleged invention. For example, the ’902 patent states that a “conventional touch
`
`panel comprises a substrate having a surface on which sensing zones are
`
`distributed for sensing a signal associated with the touch of a user's finger or stylus
`
`to effect input and control.” Id. at 1:24-27. The ’902 patent also states that the
`
`sensing zones in the conventional touch panel “are made of transparent conductive
`
`membranes, such as Indium Tin Oxide (ITO).” Id. at 1:27-29.
`
`20.
`
`Fig. 1 of the ’902 patent illustrates a conductor pattern structure.
`
`2 Citations to the ’902 patent (Ex. 1001) refer to column number: line number(s).
`
`Page 9 of 84
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`

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`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`13
`
`131132
`
`X
`._2_,
`
`
`
`FIG]
`
`21.
`
`The structure includes a plurality of first-axis (X axis) conductor
`
`assemblies 13. See e.g.,
`
`id. at Fig. 1. Each first-axis conductor assembly 13
`
`includes a plurality of first-axis conductor cells 131 and a plurality of first—axis
`
`conduction lines 132 respectively connecting between adjacent ones of the-first—
`
`axis conductor cells 131. See id. The structure further includes a plurality of
`
`insulation layers 17, made of transparent insulation material such as silicon oxide,
`
`covering respective first-axis conduction lines 132. See id. at 5:14-17, Fig. 2. The
`
`insulation layers 17 do not cover the first-axis conductor cells 131. See id. at Fig. 8.
`
`Page 10 of 84
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`
`
`131 132
`
`13
`
`15
`14
`141
`
`17
`
`
`0
`W o-o-o-
`
`11.
`
` O
`
`o”0000”. 0 0 0 0
`
`
`000000§Efiflr
`
`
`
`
`a.1;ng
`
`0000000 00
`
`16b
`
`22.
`
`The structure further includes a plurality of second—axis (Y axis)
`
`conductor assemblies 14. See id. at Figs.
`
`1 and 2. Each second-axis conductor
`
`FIGS
`
`Page 11 of 84
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`
`8
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`assembly 14 includes a plurality of second-axis conductor cells 141 and a plurality
`
`of second-axis conduction lines 142 respectively connecting between adjacent ones
`
`of the second-axis conductor cells 141. See id. at 5:17-29. Each of the second-axis
`
`conduction lines 142 “extends over and across a surface of each insulation layer
`
`17.” Id.
`
`23. According to the ’902 patent, “the first-axis conductor assemblies 13
`
`and the second—axis conductor assemblies 14, and the first-axis and second-axis
`
`conduction lines 132, 142 are made of transparent conductive film, such as ITO
`
`conductive film.” Id. at 5:48-52.
`
`24.
`
`Further,
`
`the ’902 patent describes a method to manufacture a
`
`conductor pattern structure of a capacitive touch panel. See id. at 6:20-67, Figs.
`
`7—9. Specifically, the ’902 patent discloses:
`
`FIG. 7 illustrates the schematic View of a surface of a
`
`substrate on which a plurality of first-axis conductor cells
`
`131, first-axis conduction lines 132, signal transmission
`
`lines 16a, 16b, and second—axis conductor cells 141 are
`
`just formed, and FIG. 8 illustrates the schematic view of
`
`the substrate surface on which an insulation covering
`
`layer 17 is formed to cover the surface of each first-axis
`
`conduction line 132, after the step of FIG. 7. Further, FIG.
`
`9 illustrates a schematic view of the substrate surface on
`
`which a second-axis conduction line 142 is formed to
`
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`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of U.S. Patent No. 8,217,902
`
`connect between each pair of adjacent
`
`second-axis
`
`conductor cells 141 of the same second—axis conductor
`
`assembly, after the step of FIG. 8, to thereby complete
`
`the manufacturing of the conductor pattern structure of
`
`the touch panel.
`
`Id. at 6:20-33.
`
`25. With respect to sensing a touch on the capacitive touch panel, the ’902
`
`patent discloses that when a user’s finger touches the touch panel, “the first-axis
`
`conductor cell 131 of the first—axis conductor assembly 13 and the second-axis
`
`conductor cell 141 of the second—axis conductor assembly 14 .
`
`.
`
`.
`
`induce a
`
`capacitor effect therebetween and a signal caused thereby is transmitted through
`
`the signal
`
`transmission lines 16a, 16b to the control circuit” to calculate the
`
`position of touch. Id. at 5:64—6:5.
`
`26.
`
`Claims 20, 23, 28, and 30 of the ’902 patent depend on claims 17 and
`
`25, respectively. As shown in the chart below, claims 17 and 25 include many
`
`identical elements.
`
`Specifically claim elements [17.pre]
`
`through [17.e] are
`
`identical to claim elements [25.pre] through [25 .e], respectively. Similarly, claim
`
`elements [17.g] and [17h] are identical to claim elements [25g] and [25h],
`
`respectively. As listed in the chart below, claim 25 has no recitation corresponding
`
`to claim element [25.f].
`
`In the following, I refer to the labels [17.pre], [17.a],
`
`[25 .a] etc. when discussing the specific elements of claims 17 and 25 .
`
`Page 13 of 84
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`
`10
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`17. A conductor pattern structure of a
`
`25. A conductor pattern structure of a
`
`capacitive touch panel formed on a
`surface of a substrate, the conductor
`
`capacitive touch panel formed on a
`surface of a substrate, the conductor
`
`attem structure com Mrisin:
`
`. attem structure com a risin_ :
`
`a plurality of first-axis conductor
`assemblies, each first-axis conductor
`
`a plurality of first—axis conductor
`assemblies, each first—axis conductor
`
`assembly comprising a plurality of
`first-axis conductor cells arranged on
`the surface of the substrate along a
`first axis in a substantially equally-
`spaced manner, a disposition zone
`being delimited between adjacent
`ones of the first-axis conductor
`
`assembly comprising a plurality of
`first-axis conductor cells arranged on
`the surface of the substrate along a
`first axis in a substantially equally-
`spaced manner, a disposition zone
`being delimited between adjacent
`ones of the first—axis conductor
`
`assemblies and between adjacent
`ones of the first-axis conductor cells;
`
`assemblies and between adjacent
`ones of the first-axis conductor cells;
`
`a plurality of first—axis conduction
`lines respectively connecting
`between adjacent ones of the first-
`axis conductor cells of each first-axis
`
`a plurality of first-axis conduction
`lines respectively connecting
`between adjacent ones of the first-
`axis conductor cells of each first-axis
`
`
`
`conductor assembly so that the first-
`axis conductor cells of each
`
`conductor assembly so that the first-
`axis conductor cells of each
`
`respective first-axis conductor
`assembly are electrically connected
`to ether;
`
`respective first-axis conductor
`assembly are electrically connected
`to ether;
`
`a plurality of insulation layers, each
`insulation layer of the plurality of
`insulation layers covering a surface
`of each first-axis conduction line
`
`a plurality of insulation layers, each
`insulation layer of the plurality of
`insulation layers covering a surface
`of each first-axis conduction line
`
`without encompassing the adjacent
`first-axis conductor cells;
`
`without encompassing the adjacent
`first-axis conductor cells;
`
`a plurality of second-axis conductor
`assemblies, each second-axis
`
`a plurality of second-axis conductor
`assemblies, each second—axis
`
`conductor assembly comprising a
`plurality of second-axis conductor
`cells arranged on the surface of the
`substrate along a second axis in a
`substantiall e uall -s-aced manner,
`
`conductor assembly comprising a
`plurality of second-axis conductor
`cells arranged on the surface of the
`substrate along a second axis in a
`substantiall e uall -s - aced manner,
`
`Page 14 of 84
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`11
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`each second-axis conductor cell
`
`each second-axis conductor cell
`
`being set in each disposition zone;
`
`being set in each disposition zone;
`and
`
`a plurality of second-axis conduction
`lines respectively connecting
`between adjacent ones of the second—
`axis conductor cells of each second-
`
`a plurality of second-axis conduction
`lines respectively connecting
`between adjacent ones of the second-
`axis conductor cells of each second-
`
`axis conductor assembly so that the
`second-axis conductor cells of each
`
`axis conductor assembly so that the
`second—axis conductor cells of each
`
`respective second-axis conductor
`assembly are electrically connected
`together, the second—axis conduction
`line being extended across a surface
`of the insulation layer of the
`respective first-axis conduction line;
`and
`
`respective second-axis conductor
`assembly are electrically connected
`together, the second-axis conduction
`line being extended across a surface
`of the insulation layer of the
`respective first-axis conduction line,
`
`
`
`a plurality of signal transmission
`lines formed on the surface of the
`
`substrate, each signal transmission
`line respectively connecting each
`first-axis conductor assembly and
`each second-axis conductor
`
`assembl ,
`
`, and.
`
`wherein first-axis conductor cells and
`
`wherein first—axis conductor cells and
`
`the second-axis conductor cells
`
`the second-axis conductor cells
`
`consist of a transparent conductive
`material,
`
`consist of a transparent conductive
`material,
`
`and wherein a capacitance between a
`first cell of the plurality of first-axis
`conductor cells and a second cell of
`
`and wherein a capacitance between a
`first cell of the plurality of first-axis
`conductor cells and a second cell of
`
`the plurality of second-axis
`conductor cells is measured to detect
`
`the plurality of second-axis
`conductor cells is measured to detect
`
`osition of touch.
`
`a .osition of touch.
`
`Page 15 of 84
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`12
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`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`V.
`
`Claim Construction
`
`27.
`
`I understand that in these types of proceedings, a claim is given its
`
`broadest reasonable construction in light of the specification of the patent in which
`
`it appears.
`
`I also understand that, at the same time, claim terms are given their
`
`ordinary and customary meaning as would be understood by one of ordinary skill
`
`in the art.
`
`I further understand that the Board has already addressed several claim
`
`terms of the ’902 patent in the institution decisions in the IPR2013-00567 and
`
`IPR2013-00568 proceedings. See IPR2013-00567, Paper No. 10 at 8—12; IPR2013-
`
`00568, Paper No. 10 at 8-11. My opinions in this declaration take into account and
`
`are consistent with the Board’s constructions in those decisions to the extent they
`
`apply.
`
`VI. Certain References Disclose or Suggest All the Features of Claims 20, 23,
`28, and 30 of the ’902 Patent
`
`28.
`
`In my opinion, several references disclose or suggest the features
`
`recited in claims 20, 23, 28 and 30 of the ’902 patent.
`
`A.
`
`Binstead in Combination with Miller and Other References,
`Discloses or Suggests All the Features of Claims 23 and 30
`
`29.
`
`In my opinion, Binstead in combination with Miller and other
`
`references, i.e., the ’902 patent’s background description of conventional touch
`
`screens known in the art, Seguine, or Honeywell, discloses or suggests the features
`
`recited in claims 23 and 30 of the ’902 patent.
`
`Page 16 of 84
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`13
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`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`1.
`
`Binstead and Miller Disclose Each and Every Feature
`Rec-ited in Claims 17 and 25
`
`30.
`
`In my opinion, and as shown in the charts below, Binstead and Miller
`
`disclose each and every feature recited in claims 17 and 25.
`
`a)
`
`Claim 17
`
`31.
`
`Binstead and Miller disclose each and every feature of claim 17.
`
`
`
`
`
`Binstead (Ex. 1005) and Miller (Ex. 1008)
`
`
`
`[17.pre]. A conductor
`
`pattern structure of a
`
`capacitive touch panel
`
`formed on a surface of a
`
`
`Binstead teaches “[a] conductor pattern structure of a
`capacitive touch panel formed on a surface of a
`substrate,” as recited in claim 17 of the ’902 patent.
`
`
`
`
`For example, Binstead discloses a pattern of
`conductor elements formed on a surface of a dielectric
`pattern structure
`
`
`film of a touchpad.
`comprising:
`
`
`
`
`A touchpad is formed of an electrically
`insulating membrane (10) with a first series of
`
`spaced apart conductors (12) on a first face of
`membrane (10) and a second series of spaced
`apart conductors (14) on or proximal thereto, in
`
`which there is no electrical contact between the
`
`
`first and second series of conductors (12, 14)
`Each conductor in the first and second series of
`
`
`conductors is sensitive to the proximity of a
`finger to modify the capacitance of the
`
`proximate conductor to detect the presence of
`
`the finger positioned close to that conductor.
`
` Binstead, Abstract.
`
`substrate, the conductor
`
`
`
`
`
`
`
`
`
`FIG. 10 shows a pattern of conductor
`
`elements demonstrating one embodiment of a
`
`
`multiplexed touchpad.
`
`
`
`Page 17 of 84
`Page 17 of 84
`
`14
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`Binstead (Ex. 1005) and Miller (Ex. 1008)
`
`Binstead, 3:41-42.
`
`With reference to FIGS. 1 and 2a, and
`
`according to one embodiment of the invention,
`there is provided a thin dielectric film 10 on
`which is deposited on one face by an
`appropriate technique such as screen printing or
`similar lithographic process, a pattern of
`electrically conducting material forming a first
`series of parallel conductor elements 12 with
`appropriate connections at one or both ends.
`
`
`
`[17.a] a plurality of first-
`axis conductor assemblies,
`
`each first-axis conductor
`
`assembly comprising a
`plurality of first-axis
`conductor cells arranged
`on the surface of the
`
`substrate along a first axis
`in a substantially equally-
`spaced manner, a
`disposition zone being
`delimited between
`
`adjacent ones of the first-
`axis conductor assemblies
`
`and between adjacent ones
`of the first—axis conductor
`
`cells;
`
`Binstead, 3:43-49.
`
`See also, e.g., Binstead, 3:21-56, Fi s. 1-7, 9.
`Binstead teaches “a plurality of first-axis conductor
`assemblies, each first—axis conductor assembly
`comprising a plurality of first-axis conductor cells
`arranged on the surface of the substrate along a first
`axis in a substantially equally-spaced manner,” as
`recited in claim 17 of the ’902 patent.
`
`For example, Binstead discloses first series of
`conductor elements 12, which include conductor cells,
`
`arranged on the surface of a dielectric film 10 along a
`first axis with substantially identical inter-element
`spacing 18 between adjacent pairs of the first series of
`conductor elements 12.
`
`“[I]n FIG. 2b the first series of conductor elements 12
`
`may be deposited onto the thin dielectric film 10.”
`Binstead, 4:5-7.
`
`3 Citations to Binstead (Ex. 1005) refer to column number:line number(s).
`
`Page 18 of 84
`Page 18 of 84
`
`15
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`
`
`
`
`
`Binstead (Ex. 1005) and Miller (Ex. 1008)
`
`With reference to FIGS. 1 and 2a, and
`
`according to one embodiment of the invention,
`there is provided a thin dielectric film 10 on
`which is deposited on one face by an
`appropriate technique such as screen printing or
`
`similar lithographic process, a pattern of
`
`electrically conducting material forming a first
`
`series of parallel conductor elements 12 with
`
`appropriate connections at one or both ends.
`
`
`Binstead, 3:43-49.
`
`
`
`
`The first series of conductor elements 12 include
`
`conductor cells. For example, parts of the first series
`of conductor elements 12 having wider width 22, as
`
`illustrated in Fig. 3a of Binstead, are conductor cells.
`
`
`.-
`z.
`first-axis
`
`conductor cells
`
`
`
`Binstead, Fig. 3a (annotations added).
`
`
`
`
`In FIG. 3a, where the conductor elements
`have a more substantial width 22, at the
`
`
`
`intersections 20 the width 24 is greatly reduced.
`
`Binstead, 4:63-65.
`
`Page 19 of 84
`Page 19 of 84
`
`16
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`Binstead Ex. 1005) and Miller (Ex. 1008)
`
`embodiment of Fig 3a of Binstead illustrate that the
`first series of conductor elements 12 are arranged on
`the surface of the dielectric film 10 along a first axis
`in substantially equally—spaced manner (e.g., the
`distances between the centers of adjacent conductor
`cells or between the edges of adjacent conductor cells
`are substantially equal) as is shown in the annotated
`version of Fig. 1 as shown below.
`
`substantially equally-spaced
`
`first-axis
`
`conductor cells
`
`
`
`x
`‘\
`' f~‘-%¢$;::'/mss
`.5 ,
`“11%.:====.=-_r-:='=-—;=r‘ A
`
`For example, Binstead discloses substantially
`
`identical inter-element spacing 18 between adjacent
`
`Page 20 of 84
`Page 20 of 84
`
`17
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`
`
`Binstead (Ex. 1005) and Miller (Ex. 1008)
`pairs of the first series of conductor elements 12 and
`between adjacent pairs of the second series of
`conductor elements 14.
`
`
`
`
`
`
`
`
`
`
`2c, the width 16 of the conductor elements 12
`
`
`In the embodiments of FIGS. 1 and 2a-
`
`and 14 is small compared with the inter-
`element spacing 18. If the conducting material
`being used to form conductor elements 12, 14
`
`is of low conductivity, an alternative pattern of
`
`conductor element may be used as described
`
`later.
`
`
`In another embodiment, the inter-element
`spacing 18 need not be identical for each
`adjacent pair of conductor elements.
`
`
` Binstead, 4:28-35.
`
`
`Because the inter-element spacing 18 exist between
`adjacent second series of conductor elements 14, the
`
`first-axis conductor cells of the first series of
`
`
`conductor elements 12 are arranged in a substantially
`equally-spaced manner.
`
`
`
`Binstead also teaches “a disposition zone being
`delimited between adjacent ones of the first-axis
`
`conductor assemblies and between adjacent ones of
`
`the first-axis conductor cells,” as recited in claim 17
`of the ’902 patent.
`
`
`
`
`
`
`
`
`
`
`For example, Figs. 1 and 3a of Binstead illustrate the
`inter-element spacing 18 being delimited between
`adjacent ones of the first series of conductor elements
`12 and between adjacent first-axis conductor cells of
`the first series of conductor elements 12.
`
`
`Page 21 of 84
`Page 21 of 84
`
`18
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`Binstead (Ex. 1005) and Miller (Ex. 1008
`
`Disposition
`Zone
`
`Binstead, Fig. l (emphasis added).
`
`1:.
`
`first-axis
`
`conductor cells
`
`10.
`
`“
`
`disposition zone
`
`Binstead, Fig. 3a (emphasis added).
`
`See also, e.g., ’429 patent, Figs. 2a, 2b, 3a, 3b, 4-7, 9-
`
`[17.b] a plurality of first—
`axis conduction lines
`
`Binstead teaches “a plurality of first-axis conduction
`lines res nectivel connectin between ad'acent ones
`
`Page 22 of 84
`Page 22 of 84
`
`19
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of U.S. Patent No. 8,217,902
`
`
`
`Binstead (Ex. 1005) and Miller (Ex. 1008)
`of the first-axis conductor cells of each first-axis
`respectively connecting
`
`
`
`conductor assembly so that the first-axis conductor
`between adjacent ones of
`
`cells of each respective first-axis conductor assembly
`the first-axis conductor
`
`
`are electrically connected together,” as recited in
`cells of each first-axis
`
`
`conductor assembly so that claim 17 of the ’902 patent.
`
`
`the first-axis conductor
`
`
`
`
`assembly are electrically
`
`
`
`connected together;
`
`
`
`cells of each respective
`first—axis conductor
`
`
`
`For example, Binstead discloses that the first series of
`conductor elements 12 include wider width 22 parts,
`which constitute conductor cells, as well as narrower
`width 24 parts, which constitute conduction lines, at
`the intersections 20.
`
`
`
`
`
`Binstead, Fig. 3a.
`
`
`In FIG. 3a, where the conductor elements
`have a more substantial width 22, at the
`
`intersections 20 the width 24 is greatly reduced.
`
`
`
`
`
`The narrower width 24 parts connect adjacent ones of
`the wider width 22 parts of the first series of
`conductor elements 12 so that the wider width 22
`
`parts of each respective first series of conductor
`elements 12 are electrically connected together.
`
`
`Binstead, 4:63-65.
`
`Page 23 of 84
`Page 23 of 84
`
`20
`
`

`

`Declaration of Dr. Vivek Subramanian
`
`Regarding Petition for IPR of US. Patent No. 8,217,902
`
`[17.c] a plurality of
`insulation layers, each
`insulation layer of the
`plurality of insulation
`layers covering a surface
`of each first-axis
`conduction line without
`
`Binstead
`x. 1005) and Miller (Ex. 1008)
`Binstead teaches “a plurality of insulation layers, each
`
`
`
`insulation layer of the plurality of insulation layers
`
`
`covering a surface of each first-axis conduction line
`
`
`
`without encompassing the adjacent first-axis
`
`
`conductor cells,” as recited in claim 17 of the ’902
`
`
`
`
`
`patent.
`
`
`
`
`For example, Binstead discloses that insulating
`encompassing the adjacent
`
`material 13’ are deposited over the narrower width 24
`first-axis conductor cells;
`
`
`parts of the first series of conductor elements 12 at the
`intersections 20 without encompassing the adjacent
`
`wider width 22 parts of the first series of conductor
`
`elements 12.
`
`
`
`
`
`
`It is also possible to effect the
`
`superposition of the conducting elements in
`
`other ways. For example