Comparison of Exhibit 1008, Declaration of Prasant Mohapatra, to
` Paper 1, Petition for Inter Partes Review
`
`
`
`This Exhibit highlights the similarities between the Expert Declaration of Prasant Mohapatra (Exhibit 1008) and
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`the corresponding sections of the Petition for Inter Partes Review (Paper 1) in this proceeding. The first column
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`includes paragraphs 15-93 from Dr. Mohapatra’s Declaration. The second column contains the corresponding
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`paragraphs from the Petition. In this comparison, identical text shared between the Declaration and Petition are
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`noted in blue underline text. Differences are in black text.
`
`Declaration of Prasant Mohapatra (Ex. 1008)
`15. The ‘275 Patent is generally directed to driver for
`light emitting diodes (LEDs). Ex. 1001 at 6:4 et seq. The
`driver includes a counter that counts pulses provided on
`an input interface and the determined count is used to
`set an operating mode for LED. Id. at 3:35-39; 4:10-32.
`Thus, control states for the LED are established
`according to the number of pulses provided on the input
`interface. A desired control state is maintained by
`
`Petition for Inter Partes Review (Paper 1)
`The ‘275 Patent is generally directed to driver for light
`emitting diodes (LEDs). Ex. 1001 at 6:4 et seq. The
`driver includes a counter that counts pulses provided on
`an input interface and the determined count is used to
`set an operating mode for LED. Id. at 3:35-39; 4:10-32.
`Thus, control states for the LED are established
`according to the number of pulses provided on the input
`interface. A desired control state is maintained by
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`Skyworks Ex. 2027
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`Declaration of Prasant Mohapatra (Ex. 1008)
`holding the signal on the input interface at logic high, id.
`at 3:43-44, and the device is reset by holding the signal
`on the input interface at logic low for a predetermined
`time period. Id. at 3:47-49; 4:12-15. In one
`embodiment, the driver includes a “boost converter” to
`boost the power provided to the LED above that which
`would ordinarily be provided by a power source (such as
`a battery). Id. at 6:7-23.
`16. As noted above, backlight LED drivers were
`known in the art prior to the filing of the ‘275 Patent.
`One such driver was the Linear Technology LT1932
`Constant-Current DC/DC LED Driver. Ex. 1004 at 1.
`The LT1932 driver “is ideal for driving light emitting
`diodes (LEDs) whose light intensity is proportional to
`the current passing through them.” Id. “The LT1932’s
`small size and high efficiency, and its ability to provide
`uniform brightness, make it an excellent choice for
`applications using white LEDs to backlight or frontlight
`
`Petition for Inter Partes Review (Paper 1)
`holding the signal on the input interface at logic high, id.
`at 3:43-44, and the device is reset by holding the signal
`on the input interface at logic low for a predetermined
`time period. Id. at 3:47-49; 4:12-15. In one
`embodiment, the driver includes a “boost converter” to
`boost the power provided to the LED above that which
`would ordinarily be provided by a power source (such as
`a battery). Id. at 6:7-23.
`Backlight LED drivers were known in the art prior to
`the filing of the ‘275 Patent. One such driver was the
`Linear Technology LT1932 Constant-Current DC/DC
`LED Driver. Ex. 1004 at 1. The LT1932 driver “is ideal
`for driving light emitting diodes (LEDs) whose light
`intensity is proportional to the current passing through
`them.” Id. “The LT1932’s small size and high
`efficiency, and its ability to provide uniform brightness,
`make it an excellent choice for applications using white
`LEDs to backlight or frontlight color liquid crystal
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`Declaration of Prasant Mohapatra (Ex. 1008)
`color liquid crystal displays (LCDs).” Ex. 1010 at 1.
`17. The LT1932 LED driver was powered via an
`input pin (VIN) from an input voltage having a value
`between 1 – 10 volts, Ex. 1004 at 1, and included a DC-
`to-DC boost converter configured to generate a boosted-
`output in response to a control state. Id. at 7 (“If the
`device is turned on without the LEDs present, no current
`feedback signal is provided to the LED pin. The LT1932
`will then switch at its maximum duty cycle, generating
`an output voltage 10 to 15 times greater than it’s the
`input voltage.”); and see Ex. 1010 at 1 (“With an input
`voltage range of 1V to 10V, the LT1932 works from a
`variety of input sources . . . The 36V rating allows
`output voltages as high as 35V to be generated, easily
`driving up to eight white LEDs in series.”). LED
`brightness is controlled using a pulse width modulation
`(PWM) signal. “PWM brightness control provides the
`widest dimming range (greater than 20:1) by pulsing the
`
`Petition for Inter Partes Review (Paper 1)
`displays (LCDs).” Ex. 1010 at 1.
`The LT1932 LED driver was powered via an input pin
`(VIN) from an input voltage having a value between 1 –
`10 volts, Ex. 1004 at 1, and included a DC-to-DC boost
`converter configured to generate a boosted-output in
`response to a control state. Id. at 7 (“If the device is
`turned on without the LEDs present, no current feedback
`signal is provided to the LED pin. The LT1932 will then
`switch at its maximum duty cycle, generating an output
`voltage 10 to 15 times greater than it’s the input
`voltage.”); and see Ex. 1010 at 1 (“With an input
`voltage range of 1V to 10V, the LT1932 works from a
`variety of input sources . . . The 36V rating allows
`output voltages as high as 35V to be generated, easily
`driving up to eight white LEDs in series.”). LED
`brightness is controlled using a pulse width modulation
`(PWM) signal. “PWM brightness control provides the
`widest dimming range (greater than 20:1) by pulsing the
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`Declaration of Prasant Mohapatra (Ex. 1008)
`LEDs on and off using the control signal. The LEDs
`operate either at zero or full current, but their average
`current changes with the PWM duty cycle.” Ex. 1004 at
`7. PWM dimming with the LT1932 is effected either by
`
`driving the (cid:1845)(cid:1834)(cid:1830)(cid:1840)pin directly or by adding a resistor to
`
`Petition for Inter Partes Review (Paper 1)
`LEDs on and off using the control signal. The LEDs
`operate either at zero or full current, but their average
`current changes with the PWM duty cycle.” Ex. 1004 at
`7. PWM dimming with the LT1932 is effected either by
`
`driving the (cid:1845)(cid:1834)(cid:1830)(cid:1840)pin directly or by adding a resistor to
`
`drive the RSET pin. Id. The LT1932 also included an
`output pin (SW) in communication with the LED driver
`circuit and configured to output the boosted-output for
`the plurality of LEDs, as illustrated in the “Typical
`Application” figure shown on p. 1 of Ex. 1004,
`reproduced above, and on Figure 1, p. 4 of Ex. 1004
`showing the output voltage (VOUT). The DC/DC boost
`converter was configured so that the boosted-output
`voltage was at least four times the input voltage value.
`Id. at 7 (indicating that the output voltage may be as
`high as 10 to 15 times greater than the input voltage).
`value. Id. at 7 (indicating that the output voltage may be
`as high as 10 to 15 times greater than the input voltage).
`
`drive the RSET pin. Id. The LT1932 also included an
`output pin (SW) in communication with the LED driver
`circuit and configured to output the boosted-output for
`the plurality of LEDs, as illustrated in the “Typical
`Application” figure shown on p. 1 of Ex. 1004,
`reproduced above, and on Figure 1, p. 4 of Ex. 1004
`showing the output voltage (VOUT). The DC/DC boost
`converter was configured so that the boosted-output
`voltage was at least four times the input voltage value.
`Id. at 7 (indicating that the output voltage may be as
`high as 10 to 15 times greater than the input voltage).
`value. Id. at 7 (indicating that the output voltage may be
`as high as 10 to 15 times greater than the input voltage).
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`Declaration of Prasant Mohapatra (Ex. 1008)
`18. Other forms of illumination control systems were
`also known in the art prior to the filing of the ‘275
`Patent. For example, Kato (Ex. 1006) teaches a control
`terminal (3) for an illumination load (4) in which pulse
`counts determine activation (on/off) and brightness of
`the load. Ex. 1006 at [0013] - [0014]. More particularly,
`when the terminal (3) is addressed according to signals
`on a transmission line (2), a controller (16) within the
`terminal receives an enable signal (from comparator 15)
`and turns on the illumination load (4). Id. at [0017]. The
`brightness of the load (4) is determind according to a
`pulse count of a data signal on the transmission line (2).
`Id. at [0013] – [0014] (“By the action of counting only,
`at the terminal side, the quantity of pulses in the control
`data . . . there is ability to simply control light
`adjustment with the control data.”). Kato provides an
`example of the “control data” waveform in Figure 3.
`More particularly, the transmission signal (shown in Fig.
`
`Petition for Inter Partes Review (Paper 1)
`Other forms of illumination control systems were also
`known in the art prior to the filing of the ‘275 Patent.
`For example, Kato teaches a control terminal (3) for an
`illumination load (4) in which pulse counts determine
`activation (on/off) and brightness of the load. Ex. 1006
`at [0013] - [0014]. More particularly, when the terminal
`(3) is addressed according to signals on a transmission
`line (2), a controller (16) within the terminal receives an
`enable signal (from comparator 15) and turns on the
`illumination load (4). Id. at [0017]. The brightness of the
`load (4) is determind according to a pulse count of a
`data signal on the transmission line (2). Id. at [0013] –
`[0014] (“By the action of counting only, at the terminal
`side, the quantity of pulses in the control data . . . there
`is ability to simply control light adjustment with the
`control data.”). Kato provides an example of the
`“control data” waveform in Figure 3. More particularly,
`the transmission signal (shown in Fig. 3(a) and in
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`Declaration of Prasant Mohapatra (Ex. 1008)
`3(a) and in expanded form in Fig 3(b)) includes both an
`address portion and a data portion. Id. at [0015]. The
`address portion of the signal is captured by terminal (3)
`during the time that signal IC1 Q is logic high (see Fig.
`3(c)) and the data portion of the signal is captured by
`terminal (3) during the time that signal IC2 Q is logic
`high (see Fig. 3(e)). Id. at [0019]. The value of the
`control data is acquired by the load data counter during
`the time the QB output of IC2 (Fig. 3(f)) is logic low,
`and it is latched at the rising edge of that signal. Id. at
`[0022]. The count value is output when the output of
`IC5 (the comparator 15) (Fig. 3(h)) is logic low. Id.
`During the time that signal IC2 Q (Fig. 3(e)) is logic
`low, the load data counter is reset. Id.
`19. The output of the load data counter (14) is provided
`to the controller (16), and the controller creates a
`corresponding illumination duty signal (of up to 256
`levels), i.e. a pulse width modulation signal. Id. at
`
`Petition for Inter Partes Review (Paper 1)
`expanded form in Fig 3(b)) includes both an address
`portion and a data portion. Id. at [0015]. The address
`portion of the signal is captured by terminal (3) during
`the time that signal IC1 Q is logic high (see Fig. 3(c))
`and the data portion of the signal is captured by terminal
`(3) during the time that signal IC2 Q is logic high (see
`Fig. 3(e)). Id. at [0019]. The value of the control data is
`acquired by the load data counter during the time the
`QB output of IC2 (Fig. 3(f)) is logic low, and it is
`latched at the rising edge of that signal. Id. at [0022].
`The count value is output when the output of IC5 (the
`comparator 15) (Fig. 3(h)) is logic low. Id. During the
`time that signal IC2 Q (Fig. 3(e)) is logic low, the load
`data counter is reset. Id.
`The output of the load data counter (14) is provided to
`the controller (16), and the controller creates a
`corresponding illumination duty signal (of up to 256
`levels), i.e. a pulse width modulation signal. Id. at
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`Declaration of Prasant Mohapatra (Ex. 1008)
`[0023]. “The duty ratio can be controlled by
`changing the pulse quantity within the control data of
`the transmission signal, so that, for example, by making
`the pulse quantity small there is a reduction of the time
`that [the output of controller 16] is at H [(logic high)]
`level and thereby enabled (sic) changing of the extent of
`illumination.” Ex. 1006 at 11 [0027]. While Kato
`address illumination loads in general, Kato specifically
`mentions LEDs as a potential load. Ex. 1006 at [0009]
`(referring to the example shown in Fig. 9, with an LED
`load) and at Fig.1 (showing an LED load).
`20. In my opinion, it would have been obvious for a
`person of ordinary skill in the art at the time of the
`alleged invention of the ‘275 Patent to the teachings of
`LT1931 concerning a DC/DC boost converter in a
`controller that used pulse counts and reset to control the
`brightness of an illumination load (such as an LED), as
`taught by Kato, inasmuch as the desire to drive more
`
`Petition for Inter Partes Review (Paper 1)
`[0023]. “The duty ratio can be controlled by
`changing the pulse quantity within the control data of
`the transmission signal, so that, for example, by making
`the pulse quantity small there is a reduction of the time
`that [the output of controller 16] is at H [(logic high)]
`level and thereby enabled (sic) changing of the extent of
`illumination.” Ex. 1006 at 11 [0027]. While Kato
`address illumination loads in general, Kato specifically
`mentions LEDs as a potential load. Ex. 1006 at [0009]
`(referring to the example shown in Fig. 9, with an LED
`load) and at Fig.1 (showing an LED load).
`Alternatively, or in addition, it would have been obvious
`for a person of ordinary skill in the in the art at the time
`of the alleged invention of the ‘275 Patent to incorporate
`the teachings of LT1931 concerning a DC/DC boost
`converter in a controller that used pulse counts and reset
`to control the brightness of an illumination load (such as
`an LED), as taught by Kato, inasmuch as the desire to
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`Declaration of Prasant Mohapatra (Ex. 1008)
`than a single LED would have led the person of ordinary
`skill to recognize the benefit of (and need for) the boost
`converter. Hence, such a combination would have been
`nothing more than one involving known elements by
`known methods with no change in their respective
`functions, to yield nothing more than predictable results.
`Further, because the LT1932 was already adapted to
`use pulse width modulation (PWM) signals as a control
`means, Ex. 1004 at 1, 7, the person of ordinary skill in
`the art would have recognized and appreciated that
`Kato’s teachings regarding the conversion of pulse
`count (of an input signal) into a pulse width modulation
`signal (for brightness control of an LED) provides the
`very form of signal contemplated for use with the
`DC/DC boost converter of LT1932.
`
`21. Alternatively, or in addition, it would have been
`obvious for a person of ordinary skill in the art at the
`
`Petition for Inter Partes Review (Paper 1)
`drive more than a single LED would have led the
`person of ordinary skill to recognize the benefit of (and
`need for) the boost converter. Ex. 1008 at 20. Hence,
`such a combination would have been nothing more than
`one involving known elements by known methods with
`no change in their respective functions, to yield nothing
`more than predictable results. KSR Int’l., supra, 550
`U.S. at 419. Further, because the LT1932 was already
`adapted to use pulse width modulation (PWM) signals
`as a control means, Ex. 1004 at 1, 7, the person of
`ordinary skill in the art would have recognized and
`appreciated that Kato’s teachings regarding the
`conversion of pulse count (of an input signal) into a
`pulse width modulation signal (for brightness control of
`an LED) provides the very form of signal contemplated
`for use with the DC/DC boost converter of LT1932. Id.
`It would have been obvious for a person of ordinary
`skill in the art at the time of the alleged invention of the
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`Declaration of Prasant Mohapatra (Ex. 1008)
`time of the alleged invention of the ‘275 Patent to
`incorporate the teachings of Kato regarding use of pulse
`counts and reset to control the brightness of an
`illumination load (such as an LED) in an LED
`backlight controller such as the one described in
`LT1931 inasmuch as LT1932 was already adapted to
`use pulse width modulation (PWM) signals as a control
`means. Ex. 1004 at 1, 7 (“When a PWM control signal
`
`is used to drive the (cid:1845)(cid:1834)(cid:1830)(cid:1840)pin of the LT1932 (see Figure
`
`6), the LEDs are turned off and on at the PWM
`frequency.”). Hence, incorporating the teachings of Kato
`in such a device would have been nothing more than a
`combination of known elements by known methods with
`no change in their respective functions, to yield nothing
`more than predictable results. Indeed, the use of pulsed
`signals (as in Kato) in a LED driver can be seen as
`simply the application of a known solution in the field to
`which the LT1932 is directed, inasmuch as the device
`
`Petition for Inter Partes Review (Paper 1)
`‘275 Patent to incorporate the teachings of Kato
`regarding use of pulse counts and reset to control the
`brightness of an illumination load (such as an LED) in
`an LED backlight controller such as the one described in
`LT1931 inasmuch as LT1932 was already adapted to
`use pulse width modulation (PWM) signals as a control
`means. Ex. 1004 at 1, 7 (“When a PWM control signal
`
`is used to drive the (cid:1845)(cid:1834)(cid:1830)(cid:1840)pin of the LT1932 (see Figure
`
`6), the LEDs are turned off and on at the PWM
`frequency.”). Hence, incorporating the teachings of Kato
`in such a device would have been nothing more than a
`combination of known elements by known methods with
`no change in their respective functions, to yield nothing
`more than predictable results. KSR Int’l., supra, 550
`U.S. at 419. Indeed, the use of pulsed signals (as
`in Kato) in a LED driver can be seen as simply the
`application of a known solution in the field to which the
`LT1932 is directed, inasmuch as the device data sheet
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`Declaration of Prasant Mohapatra (Ex. 1008)
`data sheet specifically contemplates the use of such
`control signals. Stated differently, to the person of
`ordinary skill in the art, incorporating such techniques in
`a driver such as the LT1932 would have been
`recognized as simply arranging well-known elements,
`with each performing the same function it had been
`known to perform, to yield no more than one would
`expect from such an arrangement. The control solution
`offered by Kato allows for “complex control of the
`load,” Ex. 1006 at p. 9, and having such finegrained
`control over would be an obvious benefit to the person
`of ordinary skill in the art that was concerned with the
`design of LED drivers.
`22. Claim 1 recites, “A backlight driver, comprising a
`first circuit for generating a count value by counting
`clock pulses” and “a second circuit for generating a
`control state for a light source in response to the count
`value.” As discussed above, in my opinion it would have
`
`Petition for Inter Partes Review (Paper 1)
`specifically contemplates the use of such control signals.
`Stated differently, to the person of ordinary skill in the
`art, incorporating such techniques in a driver such as the
`LT1932 would have been recognized as simply
`arranging well-known elements, with each performing
`the same function it had been known to perform, to yield
`no more than one would expect from such an
`arrangement. Ex. 1008 at 21. The control solution
`offered by Kato allows for “complex control of the
`load,” Ex. 1006 at p. 9, and having such fine-grained
`control over would be an obvious benefit to the person
`of ordinary skill in the art that was concerned with the
`design of LED drivers.
`Claim 1 recites, “A backlight driver, comprising a first
`circuit for generating a count value by counting clock
`pulses” and “a second circuit for generating a control
`state for a light source in response to the count value.”
`As discussed above, it would have been obvious for a
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`been obvious for a person of ordinary skill in the art at
`the time of the alleged invention of the ‘275 Patent to
`combine the teachings of LT1932 and Kato.
`Collectively, the teachings of LT1932 and Kato teach a
`backlight driver having a first circuit for generating a
`count value by counting clock pulses. In particular, the
`load data counter (14) described by Kato is a “first
`circuit for generating a count value by counting clock
`pulses.” The load data counter counts the quantity of
`pulses in the control data portion of the signal on
`transmission line 2, Ex. 1006 at [0014].
`23. Collectively, the teachings of LT1932 and Kato also
`teach, “a second circuit for generating a control state for
`a light source in response to the count
`value.” The count value produced by the load data
`counter (14) is provided to the controller (16), which
`creates a corresponding illumination duty signal (a
`control state) of up to 256 levels. Ex. 1006 at [0023].
`
`Petition for Inter Partes Review (Paper 1)
`person of ordinary skill in the art at the time of the
`alleged invention of the ‘275 Patent to combine the
`teachings of LT1932 and Kato. Collectively, the
`teachings of LT1932 and Kato teach a backlight driver
`having a first circuit for generating a count value by
`counting clock pulses. In particular, the load data
`counter (14) described by Kato is a “first circuit for
`generating a count value by counting clock pulses.” Ex.
`1008 at 22. The load data counter counts the quantity of
`pulses in the control data portion of the signal on
`transmission line 2, Ex. 1006 at [0014].
`Collectively, the teachings of LT1932 and Kato also
`teach, “a second circuit for generating a control state for
`a light source in response to the count
`value.” Ex. 1008 at 23. The count value produced by the
`load data counter (14) is provided to the controller (16),
`which creates a corresponding illumination duty signal
`(a control state) of up to 256 levels. Ex. 1006 at [0023].
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`24. Claim 1 further recites, "a third circuit for
`generating a drive voltage for the light source in
`response to the control state." The drive voltage
`in Kato is shown in a cropped version of Fig. 2
`of Ex. 1006 below. This drive voltage is
`responsive to the illumination duty signal (a
`control state) from IClO. See Ex. 1006 at Fig
`4(i) (showing the output of IClO Q is the
`illumination duty signal). In the combination
`of LT1932 and Kato, the illumination duty
`signal is fed into the SHDN pin, which causes
`the drive voltage (VOUT) to be responsive to the
`illumination duty signal (the control state). See
`Ex. 1004, at Figure 5, p. 7 (VOUT will vary
`proportional to ILED because of Ohm's Law,
`V=IR).
`25. Claim 1 further recites, “a fourth circuit for
`resetting the count value to zero in response to a
`
`Petition for Inter Partes Review (Paper 1)
`Claim 1 further recites, “a third circuit for generating a
`drive voltage for the light source in response to the
`control state.” The drive voltage in Kato is shown in a
`cropped version of Fig. 2 of Ex. 1006 below. This drive
`voltage is responsive to the illumination duty signal (a
`control state) from IC10. See Ex. 1006 at Fig 4(i)
`(showing the output of IC10 Q is the illumination duty
`signal). In the combination of LT1932 and Kato, the
`
`illumination duty signal is fed into the (cid:1845)(cid:1834)(cid:1830)(cid:1840) pin, which
`
`causes the drive voltage (VOUT) to be responsive to the
`illumination duty signal (the control state). See Ex.
`1004, at Figure 5, p. 7 (VOUT will vary proportional to
`ILED because of Ohm’s Law, V=IR). Ex. 1008 at 24.
`
`Claim 1 further recites, “a fourth circuit for resetting the
`count value to zero in response to a received signal
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`received signal being low for a period that exceeds a
`predetermined timeout value, the predetermined timeout
`value being longer than a width of one of the clock
`pulses.” Kato teaches a fourth circuit for resetting the
`count value to zero in response to a received signal
`being low for a period that exceeds a predetermined
`timeout value that is longer than a width of one of the
`clock pulses. As explained by Kato, “IC4 of load data
`counter 14 is cleared during the time IC2 Q output is at
`L level, and counting cannot be performed.” As shown
`in Fig. 3(c), the period of this timeout value during
`which the counter is cleared (reset to zero) is longer than
`the width of one clock pulse (shown in Fig. 3(b)). Thus,
`the combined teachings of LT1932 and Kato include
`each and every element of claim 1.
`
`Petition for Inter Partes Review (Paper 1)
`being low for a period that exceeds a predetermined
`timeout value, the predetermined timeout value being
`longer than a width of one of the clock pulses.” Kato
`teaches a fourth circuit for resetting the count value to
`zero in response to a received signal being low for a
`period that exceeds a predetermined timeout value that
`is longer than a width of one of the clock pulses. Ex.
`1008 at 26. As explained by Kato, “IC4 of load
`data counter 14 is cleared during the time IC2 Q output
`is at L level, and counting cannot be performed.” As
`shown in Fig. 3(c), above, the period of this timeout
`value during which the counter is cleared (reset to zero)
`is longer than the width of one clock pulse (shown in
`Fig. 3(b)). Id. Thus, the combined teachings of LT1932
`and Kato include each and every element of claim 1 and
`for at least the reasons given above it would have been
`obvious for a person of ordinary skill in the art to
`combine the teachings of these references. Accordingly,
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`Declaration of Prasant Mohapatra (Ex. 1008)
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`26. Claim 3 of the ‘275 Patent recites, “The driver of
`claim 1 wherein the count value includes at least five
`bits.” Kato shows the use of an 8 bit counter. Ex. 1006
`at Fig. 2 (IC4 shows 8 output lines). In addition, Kato
`indicates that the control level can be up to 256 levels
`(i.e., 28 ). Id. at [0023].
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`27. Claim 4 recites, “A backlight driver, comprising an
`input pin configured to be able to receive power from a
`power source.” As discussed above, it would have been
`obvious for a person of ordinary skill in the art at the
`time of the alleged invention of the ‘275 Patent to
`combine the teachings of LT1932 and Kato.
`Furthermore, LT1932 describes a backlight driver
`having an input pin (VIN) configured to be able to
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`Petition for Inter Partes Review (Paper 1)
`claim 1 is obvious under 35 U.S.C. § 103 in view of
`LT1932 and Kato.
`Claim 3 of the ‘275 Patent recites, “The driver of claim
`1 wherein the count value includes at least five bits.”
`Collectively, LT1932 and Kato teach all of the elements
`of claim 1. Kato shows an 8 bit counter. Ex. 1006 at Fig.
`2 (IC4 shows 8 output lines). In addition, Kato indicates
`that the control level can be up to 256 levels (i.e., 28). Id.
`at [0023]. Accordingly, Claim 3 is obvious in view of
`the combined teachings of MAX1848 and Kato.
`Claim 4 recites, “A backlight driver, comprising an
`input pin configured to be able to receive power from a
`power source.” As discussed above, it would have been
`obvious for a person of ordinary skill in the art at the
`time of the alleged invention of the ‘275 Patent to
`combine the teachings of LT1932 and Kato.
`Furthermore, LT1932 describes a backlight driver
`having an input pin (VIN) configured to be able to
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`Declaration of Prasant Mohapatra (Ex. 1008)
`receive power from a power source. Ex. 1004 at 4
`(“VIN (Pin 6): Input Supply Pin.”).
`28. Claim 4 further recites, “a light emitting diode
`(LED) driver circuit in communication with the input
`pin and configured to drive a plurality of LEDs.” At p. 4
`of Ex. 1004, Fig. 1, LT1932 teaches an LED driver
`circuit in communication with the input pin and
`configured to drive a plurality of LEDs.
`29. Claim 4 further recites, “the LED driver circuit
`including a first circuit configured to generate a count
`value by counting clock pulses,” and “a second circuit
`configured to generate a control state in response to the
`count value.” As discussed above, the combined
`teachings of LT1932 and Kato teach a first circuit for
`generating a count value by counting clock pulses. In
`particular, the load data counter (14) described by Kato
`is a “first circuit for generating a count value by
`counting clock pulses.” The load data counter counts the
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`Petition for Inter Partes Review (Paper 1)
`receive power from a power source. Ex. 1004 at 4
`(“VIN (Pin 6): Input Supply Pin.”).
`Claim 4 further recites, “a light emitting diode (LED)
`driver circuit in communication with the input pin and
`configured to drive a plurality of LEDs.” At p. 4 of Ex.
`1004, Fig. 1 (reproduced below), LT1932 teaches an
`LED driver circuit in communication with the input pin
`and configured to drive a plurality of LEDs.
`Claim 4 further recites, “the LED driver circuit
`including a first circuit configured to generate a count
`value by counting clock pulses,” and “a second circuit
`configured to generate a control state in response to the
`count value.” As discussed above, the combined
`teachings of LT1932 and Kato teach a first circuit for
`generating a count value by counting clock pulses. In
`particular, the load data counter (14) described by Kato
`is a “first circuit for generating a count value by
`counting clock pulses.” Ex. 1008 at 29. The load data
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`Declaration of Prasant Mohapatra (Ex. 1008)
`quantity of pulses in the control data portion of the
`signal on transmission line 2, Ex. 1006 at [0014]. The
`combined teachings of LT1932 and Kato also teach, “a
`second circuit for generating a control state for a light
`source in response to the count value.” The count value
`produced by the load data counter (14) is provided to the
`controller (16), which creates a corresponding
`illumination duty signal (a control state) of up to 256
`levels. Ex. 1006 at [0023].
`30. Claim 4 further recites, “a boost converter
`configured to generate a boosted-output in response to
`the control state, the boosted-output configured to
`control brightness of the plurality of LEDs.” LT1932
`teaches a boost converter configured to generate a
`boosted-output in response to a control state. Ex. 1010 at
`1 (“With an input voltage range of 1V to 10V, the
`LT1932 works from a variety of input sources . . . The
`36V rating allows output voltages as high as 35V to be
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`Petition for Inter Partes Review (Paper 1)
`counter counts the quantity of pulses in the control data
`portion of the signal on transmission line 2, Ex. 1006 at
`[0014]. The combined teachings of LT1932 and Kato
`also teach, “a second circuit for generating a control
`state for a light source in response to the count value.”
`Ex. 1008 at 29. The count value produced by the load
`data counter (14) is provided to the controller (16),
`which creates a corresponding illumination duty signal
`(a control state) of up to 256 levels. Ex. 1006 at [0023].
`Claim 4 further recites, “a boost converter configured to
`generate a boosted-output in response to the control
`state, the boosted-output configured to control
`brightness of the plurality of LEDs.” LT1932 teaches a
`boost converter configured to generate a boosted-output
`in response to a control state. Ex. 1010 at 1 (“With an
`input voltage range of 1V to 10V, the LT1932
`works from a variety of input sources . . . The 36V
`rating allows output voltages as high as 35V to be
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`Declaration of Prasant Mohapatra (Ex. 1008)
`generated, easily driving up to eight white LEDs
`in series.”). In the combination of LT1932 and Kato, the
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`illumination duty signal is fed into the (cid:1845)(cid:1834)(cid:1830)(cid:1840) pin, which
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`Petition for Inter Partes Review (Paper 1)
`generated, easily driving up to eight white LEDs
`in series.”). In the combination of LT1932 and Kato, the
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`illumination duty signal is fed into the (cid:1845)(ci