IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`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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`CORRECTED 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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`TABLE OF CONTENTS
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`I. MANDATORY NOTICES .................................................................................. 1
`A. Real Parties-in-Interest .................................................................................... 1
`B. Related Matters ................................................................................................ 1
`C. Counsel ............................................................................................................. 1
`D. Service Information ......................................................................................... 1
`II. CERTIFICATION OF GROUNDS FOR STANDING ...................................... 1
`III. OVERVIEW OF CHALLENGE AND RELIEF REQUESTED ...................... 2
`A. Prior Art Patents and Printed Publications ...................................................... 2
`B. Grounds for Challenge ..................................................................................... 3
`IV. OVERVIEW OF THE ‘707 PATENT ............................................................... 4
`V. CLAIM CONSTRUCTION ................................................................................ 9
`A. “Light-Output” ................................................................................................. 9
`B. Broadest Reasonable Construction for Remaining Terms .............................. 9
`VI. LEVEL OF ORDINARY SKILL IN THE ART .............................................10
`VII. STATEMENT OF MATERIAL FACTS .......................................................10
`VIII. IDENTIFICATION OF HOW THE CHALLENGED CLAIMS ARE
`UNPATENABLE .....................................................................................................20
`A. Claims 68-75, 98, 99, 116, 117, 123, 124, and 125 are anticipated by
`Kamada (Ex. 1016) ...............................................................................................21
`B. Claims 66, 76 and 128 are anticipated by Nakai (Ex. 1017) .........................33
`C. Claims 66 and 128 are obvious over Nakai (Ex. 1017) in view of TSNC
`Paper (Ex. 1026) ...................................................................................................35
`D. Claims 64, 65, 80, 85-88, 91, 120, and 121 are obvious over Kamada (Ex.
`1016) in view of JP ‘252 (Ex. 1019) ....................................................................37
`E. Claim 100 is obvious over Greene (Ex. 1020) in view of Kamada (Ex. 1018)
`
`44
`F. Claim 118 is obvious over Kamada (Ex. 1016) in view of JP ‘252 (Ex. 1019),
`further in view of Mizukoshi (Ex. 1021) ..............................................................47
`G. Claim 119 is obvious over Kamada (Ex. 1016) in view of JP ‘252 (Ex.
`1019), further in view of JP ‘924 (Ex. 1023) .......................................................49
`H. Claim 122 is obvious over Kamada (Ex. 1016) in view of JP ‘252 (Ex.
`1019), further in view of Nakai (Ex. 1017) ..........................................................50
`I. Claim 126 is obvious over Kamada (Ex. 1016) in view of JP ‘924 (Ex. 1023)
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`52
`J. Claim 127 is obvious over Kamada (Ex. 1016) in view of Arai (Ex. 1024) ..53
`K. Claim 129 is obvious over Nakai (Ex. 1017) in view of Kamada (Ex. 1016)
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`56
`L. Claim 129 is obvious over Nakai (Ex. 1017) in view of JP ‘737 (Ex. 1028) 57
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`U.S. Patent RE43,707
`Petition for Inter Partes Review
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`IX. CONCLUSION ................................................................................................60
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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).....................................................10
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`St. Jude Medical, IPR2013-00041, Paper No. 12....................................................10
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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, 10
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`37 C.F.R. § 42.100 ................................................................................................ 9
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`37 C.F.R. § 42.104 ....................................................................................1, 2, 9, 20
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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 inter partes review
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`2014-00358.
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`C. Counsel
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`Lead Counsel: Marc K. Weinstein (Registration No. 43,250)
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`Backup Counsel: Joseph Milowic (Registration No. 52,034)
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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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`U.S. Patent RE43,707
`Petition for Inter Partes Review
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`the grounds identified in this Petition.
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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 64-66, 68-76, 80, 85-88, 91, 98-100 and 116-129 of U.S. Patent No.
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`RE43,707 (“the ‘707 patent,” Ex. 1015).
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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 1016 - U.S. Patent App. Pub. No. 2005/0093798 (“Kamada”), filed
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`May 11, 2004, is prior art under 35 U.S.C. § 102(e).
`
`Exhibit 1017 - U.S. Patent No. 5,359,342 (“Nakai”), issued October 25, 1994,
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`is prior art under 35 U.S.C. § 102(b). Nakai was cited, but not applied during the
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`original prosecution of the ‘707 patent.
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`Exhibit 1018 – Japanese Published Application No. 2001-134252 (“JP ‘252),
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`published May 18, 2001, is prior art under 35 U.S.C. § 102(b).
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`Exhibit 1019 – Certified Translation of JP ‘252.
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`Exhibit 1020 - U.S. Patent No. 6,271,825 (“Greene”), published August 7,
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`2001, is prior art under 35 U.S.C. § 102(b).
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`Exhibit 1021 - U.S. Patent App. Pub. No. 2005/0023986 (“Mizukoshi”), filed
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`July 29, 2003, is prior art under 35 U.S.C. § 102(e).
`
`Exhibit 1022 - Japanese Published Application No. 2003-66924 (“JP ‘924),
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`published March 5, 2003, is prior art under 35 U.S.C. § 102(b).
`
`Exhibit 1023 – Certified Translation of JP ‘924.
`
`Exhibit 1024 - U.S. Patent No. 7,345,713 (“Arai”), filed January 4, 2005, is
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`prior art under 35 U.S.C. § 102(e).
`
`Exhibit 1025 – “An Examination of Picture Quality Improvement for Liquid
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`Crystal Displays,” Nakai et al., Television Society National Convention (“TSNC
`
`paper”) published in 1989, is prior art under 35 U.S.C. § 102(b).
`
`Exhibit 1026 – Certified Translation of TSNC paper.
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`Exhibit 1027 - Japanese Published Application No. 2000-56737 (“JP ‘737),
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`published February 25, 2000, is prior art under 35 U.S.C. § 102(b).
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`Exhibit 1028 – Certified Translation of JP ‘737.
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`B. Grounds for Challenge
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`
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`Petitioner requests cancelation of the challenged claims under the following
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`statutory grounds: claims 68-75, 98, 99, 116, 117, 123, 124, 125 are anticipated by
`
`Kamada under 35 U.S.C. § 102(e); claims 66, 76, and 128 are anticipated by Nakai
`
`under 35 U.S.C. § 102(b); claims 66 and 128 are obvious over Nakai in view of
`
`TSNC paper under 35 U.S.C. § 103(a); claims 64, 65, 80, 85-88, 91, 120, and 121
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`are obvious over Kamada in view of JP ‘252 under 35 U.S.C. § 103(a); claim 100
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`U.S. Patent RE43,707
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`is obvious over Greene in view of Kamada under 35 U.S.C. § 103(a); claim 118 is
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`obvious over Kamada and JP ‘252 further in view of Mizukoshi under 35 U.S.C. §
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`103(a); claim 119 is obvious over Kamada and JP ‘252 further in view of JP ‘924
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`under 35 U.S.C. § 103(a); claim 122 is obvious over Kamada and JP ‘252 further
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`in view of Nakai under 35 U.S.C. § 103(a); claim 126 is obvious over Kamada in
`
`view of JP ‘924 under 35 U.S.C. § 103(a); claim 127 is obvious over Kamada in
`
`view of Arai under 35 U.S.C. § 103(a); claim 129 is obvious over Nakai in view of
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`Kamada under 35 U.S.C. § 103(a); and claim 129 is obvious over Nakai in view of
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`JP ‘737 under 35 U.S.C. § 103(a).
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`
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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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`
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`The application that issued as the ‘707 patent (Ex. 1015) 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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`
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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. 1015 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). In contrast, Fig. 2 below illustrates a case
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`where the pixels 4 render a different luminance response despite being driven by
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`the same signal, as can be 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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`
`
`
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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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`
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`The light-output response functions of individual pixels 4 may all be different or
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`the response functions may be reduced to a smaller number of typical or
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`representative functions, and each pixel may be assigned to one of these typical
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`functions. (9:58-62). The response function may be represented by a number of
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`suitable means for storage and retrieval, e.g. in the form of an analytical function,
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`in the form of a look-up table or 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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`
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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 shows a flow chart of a method M100 in which a task T100 obtains a
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`measure of a light-output response of at least a portion of the pixel at each of a
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`plurality of driving levels. (29:29-35). To increase a visibility of a characteristic
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`of a displayed image during a use of the display, task T200 modifies a map that is
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`based on the obtained measures. (29:35-38). Based on the modified map and an
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`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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`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
`
`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
`
`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
`
`invisible to the human eye. (22:36-39).
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`V. CLAIM CONSTRUCTION
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`
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`In an inter partes review, a claim term is given “the broadest reasonable
`
`construction in light of the specification.” See 37 C.F.R. § 42.100(b). Pursuant to
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`37 C.F.R. § 42.104(b)(3) and the Notice dated January 28, 2014 (Paper No. 3), the
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`showing of unpatentability in this Petition is based on the following constructions.
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`A. “Light-Output”
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`Petitioner construes this phrase to mean luminance or color. ‘707 Patent,
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`9:20-25.
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`B. Broadest Reasonable Construction for Remaining Terms
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`In the context of this proceeding and the relied upon prior art, Petitioner
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`submits that all other claim terms are limitations that may be afforded their plain
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`U.S. Patent RE43,707
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`and ordinary meanings, and that further construction of those terms is not
`
`necessary. See St. Jude Medical, IPR2013-00041, Paper No. 12 at 5–6.1
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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
`
`not err in adopting the approach that the level of skill in the art was best
`
`determined by the references of record). The prior art applied herein demonstrates
`
`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
`
`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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`
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`Pursuant to 37 C.F.R. § 42.22, Petitioner submits the following statement of
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`1 Other forums, such as the District Courts, require different standards of proof and
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`claim interpretation that are not applied by the PTO for inter partes review.
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`Accordingly, any interpretation or construction of the challenged claims in this
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`Petition, either implicitly or explicitly, should not be viewed as constituting, in
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`whole or in part, Petitioner’s own interpretation or construction, except as regards
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`the broadest reasonable construction of the claims presented.
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`U.S. Patent RE43,707
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`material facts:
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`
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`Kamada (Ex. 1016)
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`1. Kamada is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
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`2. Kamada discloses a display correction circuit for a display apparatus, such
`
`as a liquid crystal display, that corrects uneven image appearance caused by the
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`characteristics of the display apparatus. (Ex. 1018 at ¶¶ [0002, 0004]).
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`3. 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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`4. Kamada teaches that the gray levels of the image data signals are adjusted
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`to display an image with reduced uneven appearance. (¶ [0042]).
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`5. The image processing apparatus 11 includes a correction data storage unit
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`21 that stores correction data and provides the stored data to a correction
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`processing unit 22, which corrects image data signals from a FIFO 23 by adjusting
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`the gray levels of the image data signals. (¶ [0043]).
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`6. As shown in Fig. 2, Kamada teaches reducing the amount of correction
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`applied to pixels located in a surrounding border region of the display. (¶ [0045]).
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`U.S. Patent RE43,707
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`7. Within the rectangular region defined by points (x1, y1) and (x2, y2), a
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`constant correction value k is applied, but the correction value gradually decreases
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`in the surrounding region toward an outer edge of the surrounding region until it
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`becomes zero at distance w1 from the edge of the rectangular region. (¶ [0045]).
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`8. Defining gray level changes in the surrounding region in an isotropic
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`manner with respect to the x direction and the y direction has an advantage in the
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`small size of correction data. (¶ [0047]).
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`9. Kamada also teaches that uneven appearance becomes conspicuous
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`depending on halftone (i.e., gray level) such that when display data is close to
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`black (i.e., close to zero) or close to white (i.e., close to 255 in the case of 256 gray
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`levels), there is no need for uneven appearance correction. (¶ [0049]).
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`10. As shown in Fig. 4, the correction value is set to k for halftones inside a
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`range between a gray level g1 and a gray level g2, and linearly decreases from k to
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`zero in the regions having the width w2. (¶ [0049]).
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`11. In relation to Fig. 7, Kamada teaches adjusting the correction value
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`based both on the input gray level and display position. (¶ [0059])
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`
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`Nakai (Ex. 1017)
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`12. Nakai is prior art against the ‘707 patent under 35 U.S.C. § 102(b).
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`13. Nakai recognizes that display non-uniformity characteristics differ at
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`individual screen positions in liquid crystal displays and addresses this problem by
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`U.S. Patent RE43,707
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`teaching the use of a look-up-table memory that stores correction data for each of a
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`plurality screen split regions. (Ex. 1019 at 1:61-64; 2:37-40)
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`14. Nakai discloses that a liquid crystal display device includes a video
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`signal compensation apparatus 10, a correction processor 11, and a look-up-table
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`memory 11b in which video input signals inputted to the address of the look-up-
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`table memory 11b and subjected to correction based on the data in the table are
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`converted to analog signals for display on the liquid crystal panel. (4:1-20).
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`15. To determine the correction data, Nakai teaches detecting brightness
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`levels at measured points A, B and C denoting representative points of the screen
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`split region and determining correction data to store in the look-up-table memory
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`by calculating inverse curves as shown in Fig. 4. (4:49-66).
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`16. As shown in Fig. 5, a normalization level can be set to the minimum
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`output level for the maximum screen brightness output level of the screen split
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`regions, which is the value c at the measuring point C. (5:9-18).
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`17. Using the value c as the normalization level, the correction data stored in
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`the look-up-table memory by screen split region is calculated by using the portion
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`of the screen brightness from zero level to the normalization level c, which limits
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`the maximum screen brightness output to the normalization level c, as shown by
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`the solid line in Fig. 6. (5:18-35).
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`18. Nakai alternatively teaches normalizing by color within each screen split
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`region, as shown in Figs. 8 and 9, which results in the maximum screen brightness
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`output shown in Fig. 10. (5:44 – 6:10).
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`19. Calculating the correction data as explained with respect to Figs. 7-10
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`prevents the deterioration of screen contrast when performing a linearity correction
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`while improving the uniformity of the whole screen. (6:13-17).
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`JP ‘252 (Ex. 1019)
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`
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`20. JP ‘252 is prior art against the ‘707 patent under 35 U.S.C. § 102(b).
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`21. JP ‘252 discloses that in a projection type display device, spectral
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`characteristics change according to the difference in the angle of incidence, which
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`causes brightness and color unevenness occurs on the projected screen. (¶ [0004]).
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`22. JP ‘252 discloses using digital correction that applies correction values
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`read from lookup tables in memory to correct for this unevenness (¶ 0005).
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`23. In Fig. 1, JP ‘252 discloses an image display device 51 can be a
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`projection-type liquid crystal projector having a projection lens that projects
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`images on a screen 53 detected by an image pickup device 52. (¶ [0011]).
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`24. To calibrate it, device 51 projects a test pattern on the screen 53 at
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`different gradation values, and image pickup device 52 detects the projected image,
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`which is used to sample data from the detected image. (¶¶ [0025, 0026]).
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`25. A CPU 84 uses a correction formula to generate correction values from
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`the sampled data to correct for brightness and color unevenness. (¶ [0028]).
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`26. Correction values calculated for one area can be shared as correction
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`values for other areas, which makes it possible to reduce memory capacity required
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`for storing the correction values. (¶ [0039]).
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`27. Correction values for some areas are calculated by interpolating the
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`correction values from other areas, and the correction values for all areas are stored
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`in lookup tables 77, 78, and 79. (¶¶ [0040 – 0043]).
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`28. This correction makes it possible to suppress brightness and color
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`unevenness and improve the quality of the displayed image (¶ [0070]).
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`29. JP ‘252 recognizes that characteristic changes within the space of the
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`display screen can be expressed as a spatial frequency, i.e., the degree of change of
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`the display unevenness characteristics. (¶¶ [0047, 0048]).
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`
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`Greene (Ex. 1020)
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`30. Greene is prior art against the ‘707 patent under 35 U.S.C. § 102(b).
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`31. Greene discloses an apparatus for correcting spatial non-uniformities in
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`brightness in flat-panel displays, both for gradual non-uniformities in monolithic
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`displays and for abrupt variations in tiled displays. (Ex. 1022 at Abstract).
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`32. Greene teaches acquiring correction parameters via brightness
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`measurements over selected pixels, storing them after suitable transformations, and
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`performing corrections for selected pixels or all pixels of the display such that any
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`remaining gradual and abrupt brightness non-uniformities over the selected display
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`pixels fall below a detectable threshold under the intended viewing conditions.
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`(Abstract; 4:35-36; 4:50-58).
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`33. Greene recognizes that human factors are significant in the perception of
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`displayed colors, and that perception tests show that gradual color non-uniformities
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`occurring continuously over many pixels are less perceptible such that gradual
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`color coordinate changes as large as 10 to 20% over the size of the display screen
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`may not be disturbing to an average viewer. (6:4-5; 6:56-64).
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`34. Greene describes brightness as the appearance of the radiant flux of an
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`object, and the psychophysical equivalent to brightness is luminance. (7:43-47).
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`35. Greene teaches that luminance is quantified as luminous flux per
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`projected area of the source of light, and that Weber’s fraction measures the ability
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`of the human eye to discriminate between two luminances. (7:49-54).
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`36. To make an electronic color display uniform in terms of luminance, the
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`resultant luminance must be controlled within the luminance threshold given by
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`Weber's fraction, where the luminance threshold applies only to adjacent pixels or
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`to adjacent groups of pixels with a sharp boundary. (8:38-41; 8:45-49).
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`37. If defective pixels are partially active, Greene teaches setting these pixels
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`in real time into states closest to the brightness of adjacent pixels and thus make
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`them least disturbing to the observer for the displayed image. (9:12-16).
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` Mizukoshi (Ex. 1021)
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`38. Mizukoshi is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
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`39. Mizukoshi teaches an efficient use of a lookup table for adjusting
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`luminance through gamma compensation of a display device. (Ex. 1020 at ¶
`
`[0014]).
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`40. Mizukoshi discloses generating data for the table according to a stored
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`equation, making it unnecessary to store all the table data or to have a large
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`capacity storage. (¶ [0019]).
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`41. The stored equation is obtained by making the panel emit light at
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`different input signal levels, detecting the luminous amount, determining a
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`relationship between the input image signal level and the luminous amount, and
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`calculating an approximate expression or a prescribed coefficient of the
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`approximate expression indicating their relationship. (¶ [0021]).
`
`42. More specifically, Mizukoshi teaches measuring L-V (luminance-input
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`voltage) characteristics of several points for RGB, creating an expression of the
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`curve passing through the obtained points and the origin point, and obtaining an
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`expression of the reverse characteristic to determine coefficients a, b, c, d of this
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`expression. (¶¶ [0050, 0051]).
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`JP ‘924 (Ex. 1023)
`
`
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`43. JP ‘924 is prior art against the ‘707 patent under 35 U.S.C. § 102(b).
`
`44. JP ‘924 is directed to making defects of a liquid crystal panel less visible
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`by correcting pixels adjacent to the defect. (Abstract, [Claim 2]).
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`45. JP ‘924 discloses that a defect is a pixel having a fixed brightness that
`
`can be bright or dark, which can make it difficult to see a displayed image if the
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`liquid crystal panel has such a defect. (¶¶ [0003 - 0005]).
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`46. To address this problem, JP ‘924 teaches that defect information
`
`including defect position and status is stored in memory. (¶ [0022]).
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`47. When a pixel defect has occurred, pixel data of pixels adjacent to the
`
`defect are corrected, such as by averaging the values of the adjacent pixels
`
`including the defect pixel. (¶¶ [0028 – 0034]).
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`48. Correction can be done in any manner as long as pixel data supplied to
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`pixels surrounding the defect is corrected so that the surrounding pixels approach
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`the defect data and the defect data does not stand out. (¶ [0065]).
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`49. By lowering the difference in luminance between the defect and the
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`corrected pixels adjacent to the defect, it is possible to make the defect of the liquid
`
`crystal panel less visible. (¶ [0008]).
`
`Arai (Ex. 1024)
`
`
`
`50. Arai is prior art against the ‘707 patent under 35 U.S.C. § 102(e).
`
`51. Arai is directed to correcting irregularities in luminance of a display
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`while suppressing as much as possible a reduction in performance, such as a
`
`reduction in luminance or contrast. (2:1-4).
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`52. To do the correction, irregularities in luminance of respective display
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`pixels in a display 17, such as a liquid crystal display, are previously measured by
`
`using an imaging device, and correction data to correct the irregularities in
`
`luminance in a correction value memory 14a. (2:65-67; 3:24-29).
`
`53. Fig. 2 shows a luminance distribution of the display 17 when a video
`
`signal has the same gradation value of R, G and B, i.e., raster white, which
`
`produces an average luminance of all pixels of 1.0. (4:15-22).
`
`54. To correct irregularities in luminance, the v