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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________________________________________________
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`SONY CORPORATION OF AMERICA
`Petitioner
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`Patent No. 7,612,843
`Issue Date: Nov. 3, 2009
`Title: STRUCTURE AND DRIVE SCHEME FOR LIGHT EMITTING DEVICE
`MATRIX AS DISPLAY LIGHT SOURCE
`__________________________________________________________________
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`EXPERT DECLARATION OF RICHARD A. FLASCK
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`No. IPR2014-01268
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`__________________________________________________________________
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`SONY 1004
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`No. IPR2014-01268
`Expert Declaration of Richard A. Flasck
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`I, Richard A. Flasck, do hereby make the following declaration:
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`1. I am the Founder and Chief Executive Officer (CEO) of RAF Electronics
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`Corp. and have served in that capacity since 1989. During my time at RAF
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`Electronics, I developed and patented liquid crystal on silicon (LCOS)
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`microdisplay technology and light emitting diode (LED) based solid state
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`lighting (SSL) technology. I am an expert in several technology areas related to
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`image display systems, including semiconductor integrated circuits (ICs), active
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`matrix liquid crystal displays (AMLCDs), thin films, optics, video electronics,
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`and the layout and driving of LED arrays.
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`2. I was also the Co-Founder of Diablo Optics, Inc. in 2002 and served as the
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`Chief Operating Officer (COO) from 2002-2007. During my time at Diablo
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`Optics, I developed, produced, and commercialized key optical components
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`for high-definition televisions (HDTVs).
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`3. I also served as the President and COO of Alien Technology Corp. (1997-
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`1999); the Founder and CEO of Alphasil, Inc. (1982-1989); and as a scientist
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`and manager at Energy Conversion Devices, Inc. (1970-1982).
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`4. I served as the Co-Chairman of SPIE/IS&T Symposium on Electronic
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`Imaging in 1991 and 1992.
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`No. IPR2014-01268
`Expert Declaration of Richard A. Flasck
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`5. I am a named inventor on twenty-five U.S. and foreign patents on a wide
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`variety of technologies including image display systems. I have published
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`several technical papers and made presentations in various technology areas
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`including HDTV projectors, liquid crystal light valve design, and flat panel
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`display devices.
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`6. A listing of my education, work history, and publications is in my curriculum
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`vitae. See Sony-1005.
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`7. I submit this declaration in support of the Petition for Inter Partes Review of
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`U.S. Pat. No. 7,612,843 (the “’843 Patent”), No. IPR2014-01268.
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`8. I have reviewed the ’843 Patent which was filed on May 25, 2007, and its
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`claims, as well as U.S. Provisional Application No. 60/767,534 (the “’843
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`Patent Provisional Application”), which was filed on May 25, 2006, to which
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`the ’843 Patent claims priority.
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`The ’843 Patent
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`9. The ’843 Patent generally describes image display systems that use a matrix of
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`LEDs and a matrix of light valves (e.g., liquid crystal display (LCD) pixels). The
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`LEDs emit light towards the LCD pixels, which modulate the light emitted by
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`the LEDs to form an image to be displayed. The ’843 Patent also describes
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`control circuitry to perform control operations on the LED and LCD matrices.
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`No. IPR2014-01268
`Expert Declaration of Richard A. Flasck
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`10. I understand that the focus of this Inter Partes Review is the subject matter of
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`claims 14, 18-20, and 25-26 of the ’843 Patent. In general, claim 14 describes an
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`image display device that includes a two-dimensional array of image elements
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`and a control circuit that sequentially (1) sets a section of the image elements to
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`an off or dimming state and (2) applies image data to the section of image
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`elements. Furthermore, claim 14 requires that the duration of the off state in
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`operation (1) must be less than or equal to 10 milliseconds. Claims 18 and 19
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`describe different types of image elements, such as light emitting elements and
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`light valves, respectively. Claim 20 describes that the display device includes a
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`two-dimensional array of lighting elements and a two-dimensional array of light
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`valves. Claim 25 describes that the lighting elements of claim 20 include a
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`plurality of light emitting devices. Claim 26 describes that the lighting elements
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`of claim 20 are light emitting diodes connected in a series configuration.
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`11. In the 2006-2007 time frame, a person with ordinary skill in the art with
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`respect to the technology disclosed by the ’843 patent would have a Bachelor
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`of Science degree in Physics or Electrical Engineering, and two to three years
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`of industry experience in the area of image display systems.
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`12. Based upon my experience and education, I consider myself to be a person of
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`at least ordinary skill in the field of technology disclosed by the ’843 Patent.
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`No. IPR2014-01268
`Expert Declaration of Richard A. Flasck
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`The ’843 Patent Provisional Application
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`13. I have read and reviewed the ’843 Patent Provisional Application. The ’843
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`Patent Provisional Application does not describe, either explicitly or inherently,
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`setting a section of image elements to an off-state for 10 milliseconds or less as
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`required by claim 14 of the ’843 Patent.
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`14. In addition, the ’843 Patent Provisional Application is missing material that was
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`included in the later filed ’843 Patent. For example, figures 15 and 16 of the
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`’843 Patent (and their related description) were not included in the ’843 Patent
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`Provisional Application.
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`15. Furthermore, the only specific reference to a 10 millisecond time period in the
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`’843 Patent appears in the claims (for example, in issued claims 14 and 40). The
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`claims included in the ’843 Patent Provisional Application do not contain this
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`language and I found no other explicit references to a 10 millisecond time
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`period related to an off state of image elements.
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`16. I also did not find any description in the ’843 Patent Provisional Application
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`that inherently shows setting a section of image elements to an off-state for 10
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`milliseconds or less. In my view, one of ordinary skill in the art would not read
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`the ’843 Patent Provisional Application to describe anything that necessitates
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`that the off state be within 10 milliseconds.
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`No. IPR2014-01268
`Expert Declaration of Richard A. Flasck
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`The Prior Art
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`17. In preparing this declaration, I have reviewed the following publications which
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`I understand are prior art to the ’843 Patent:
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`a. U.S. Pat. Appl. Pub. No. 2010/0020002 to Van Woudenberg (“Van
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`Woudenberg”), which was filed on December 22, 2005.
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`b. U.S. Pat. Appl. Pub. No. 2005/0073495 to Harbers et al. (“Harbers”),
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`which published on April 7, 2005.
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`18. Van Woudenberg is related to LCD televisions with LCD display panels, LED
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`backlighting units (each with one or more LEDs), and backlight controllers
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`(Fig. 21; para. 72). Van Woudenberg states that it is beneficial to segment an
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`LED backlight into separate backlighting units because image content may be
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`segmented as well (para. 73). Separate backlighting units can be associated with
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`different segments of an image to be displayed and independent control of the
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`backlighting units is therefore desirable (paras. 72, 73). Control signals can be
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`provided to each backlighting unit separately based on the characteristics of the
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`image associated with each backlighting unit (paras. 6, 7, 24, 72, 73). Van
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`Woudenberg discloses that pulse patterns shown in Figs. 6-20 can be used as
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`the control signals for a backlighting unit including for the embodiment shown
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`in Fig. 21 that includes segmented backlighting units (paras. 37, 75, 76). Van
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`Woudenberg also describes that the backlight controllers “flash” the backlight
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`units (i.e., sequentially turn the backlight units on and off) in such a way to
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`avoid the appearance of flickering (Fig. 21; paras. 4, 53, 72).
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`19. Harbers is also directed to LED backlights for use in display systems, such as
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`LCD displays (Abstract; paras. 1, 2, 5-7, 20; Fig. 1B). Harbers describes several
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`electrical configurations and positional arrangements for LEDs in a backlight
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`that provide improved contrast, color uniformity, and spatial and temporal
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`control (Abstract; Figs. 5, 6, 8-11B; paras. 7, 24-34).
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`20. Fig. 10 of Harbers, for example, is an example of an improved LED backlight
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`structure. The backlight in Fig. 10 is formed by a two-dimensional array of
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`grouped LEDs (with each group including between three to seven LEDs). The
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`LEDs within the groups are arranged in a hexagonal structure and are
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`connected in series (paras. 25, 31, 32). This enables the LED groups to be
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`independently controlled, while improving color uniformity, contrast, and
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`spatial and temporal control of the backlight system (paras. 7, 25, 31, 32).
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`Moreover, the physical and electrical arrangement of the LED groups reduces
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`costs in the backlight system by accommodating for a simplified design of a
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`driver/inverter needed to supply drive current to groups of LEDs (para. 28).
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`Fig. 10 of Harbers
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`21. Fig. 8B of Harbers is another example of a backlight with a two-dimensional
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`array of grouped LEDs (with each of the four groups of LEDs including 31
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`LEDs) (para. 29). The LEDs within each group are connected in series, which
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`reduces costs in the backlight system by accommodating for a simplified design
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`of a driver/inverter needed to supply drive current to groups of LEDs (para.
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`28).
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`Expert Declaration of Richard A. Flasck
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`22. Harbers also describes various other arrangements of two-dimensional arrays
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`of LEDs for backlights (Figs. 5, 6, 9, 11A-B; Abstract; paras. 7, 24-34).
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`According to Harbers, forming two-dimensional arrays of LEDs in a backlight
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`allows for segmented control of the LEDs (paras. 7, 30, 32-34). As an example,
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`Harbers describes in relation to Fig. 11A a two-dimensional array of LEDs
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`with the LEDs in each row connected together in series to form a group (Fig.
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`11A; para. 33). This arrangement allows each row to be independently
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`controlled (Fig. 11A; para. 33).
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`No. IPR2014-01268
`Expert Declaration of Richard A. Flasck
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`23. With respect to claims 14 and 18:
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`a. It would have been obvious to one of ordinary skill in the art in the
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`2006-2007 timeframe that LEDs in a backlight could be arranged in a
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`two-dimensional array. For example, as shown in figures 8B, 10, 11A,
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`and 11B of Harbers, one of ordinary skill in the art would have known
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`that arranging LEDs in a two-dimensional array would allow for
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`segmented control of the LEDs in a backlight (Harbers, para. 7, 30, 32,
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`33).
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`b. It would also have been obvious to one of ordinary skill in the art in the
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`2006-2007 time frame to combine the teachings of Van Woudenberg,
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`10
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`Expert Declaration of Richard A. Flasck
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`which describes backlights with segmented backlighting units of two or
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`more LEDs (Van Woudenberg, Fig. 21; paras. 72, 73), with the teachings
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`of Harbers, which describes various structures of two-dimensional arrays
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`of LEDs in a backlight (Harbers, Figs. 5, 6, 8-11; Abstract; paras. 7, 24-
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`34), at least because the subject matter of both references is in the same
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`field of endeavor and providing a two-dimensional array of LEDs in the
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`backlighting units of Van Woudenberg would enhance the envisioned
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`segmented control discussed by Van Woudenberg (Harbers, Fig. 8B, 10,
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`11A-B; paras. 7, 30-33; Van Woudenberg, Fig. 21; paras. 72, 73).
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`c. It would also have been obvious to one of ordinary skill in the art in the
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`2006-2007 time frame to combine the teachings of Van Woudenberg,
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`which describes backlights with segmented backlighting units of two or
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`more LEDs (Van Woudenberg, Fig. 21; paras. 72, 73), with the teachings
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`of Harbers, which describes various structures of two-dimensional arrays
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`of LEDs in a backlight (Harbers, Abstract; Figs. 5, 6, 8-11; paras. 7, 24-
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`34), at least because the subject matter of both references is in the same
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`field of endeavor and providing a two-dimensional array of LEDs in the
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`backlighting units of Van Woudenberg would allow for improved color
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`uniformity and contrast (Harbers, paras. 7, 25).
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`Expert Declaration of Richard A. Flasck
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`d. Additionally, such a combination would be obvious to one of ordinary
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`skill in the art in the 2006-2007 time frame because it would include
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`combining known structures and techniques in both the systems of Van
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`Woudenberg and Harbers without changing their functions.
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`24. With respect to claims 20 and 25:
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`a. It would have been obvious to one of ordinary skill in the art in the
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`2006-2007 timeframe that multiple LEDs could be grouped together to
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`form a lighting element. For example, as shown in figures 8B and 10 of
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`Harbers, one of ordinary skill in the art would have known that grouping
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`LEDs in certain structures (e.g., hexagonal structures) would improve
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`color uniformity, contrast, and spatial and temporal control of a
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`backlight system (Harbers, paras.7, 25, 30-33).
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`b. It would also have been obvious to one of ordinary skill in the art in the
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`2006-2007 time frame to combine the teachings of Van Woudenberg,
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`which describes backlights with segmented backlighting units of two or
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`more LEDs (Van Woudenberg, Fig. 21; paras. 72, 73), with the teachings
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`of Harbers, which describes a two-dimensional array of grouped LEDs
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`in a backlight (Harbers, Figs. 8B, 10, 11A-B; paras. 7, 29, 30-33), at least
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`because the subject matter of both references is in the same field of
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`12
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`Expert Declaration of Richard A. Flasck
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`endeavor and grouping LEDs together in the backlighting units of Van
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`Woudenberg would allow for improved color uniformity and contrast
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`(Harbers, paras. 7, 25).
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`c. It would also have been obvious to one of ordinary skill in the art in the
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`2006-2007 time frame to combine the teachings of Van Woudenberg,
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`which discloses that groups of LEDs in each backlighting unit of a
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`display system are controlled based on similar image data corresponding
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`to a given backlight unit (Van Woudenberg, Fig. 21, paras. 72, 73), with
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`the teachings of Harbers, which describes a two-dimensional array of
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`grouped LEDs in a backlight (Harbers, Figs. 8B, 10, 11A-B; paras. 7, 29,
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`30-33), at least because the subject matter of both references is in the
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`same field of endeavor and grouping LEDs together in the backlighting
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`units of Van Woudenberg would allow for improved temporal and
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`spatial control of the LED groups within each backlight unit (Harbers,
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`Fig. 8B, 10, 11A-B; paras. 7, 30-33).
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`d. Additionally, such a combination would be obvious to one of ordinary
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`skill in the art in the 2006-2007 time frame because it would include
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`combining known structures and techniques in both the systems of Van
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`Woudenberg and Harbers without changing their functions.
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`Expert Declaration of Richard A. Flasck
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`25. With respect to claim 26:
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`a. In addition to grouping multiple LEDs to form a lighting element as
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`described in paragraph 24(a) above, it would have been obvious to one
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`of ordinary skill in the art in the 2006-2007 timeframe that the multiple
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`LEDs in the lighting element could be connected together in series. For
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`example, as shown in figures 8B, 10, 11A, and 11B of Harbers, one of
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`ordinary skill in the art would have known that connecting the LEDs in
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`a lighting element in series reduces costs in the backlight system by
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`allowing the use of a simplified driver/inverter to supply drive current to
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`groups of LEDs (Harbers, paras. 28-33).
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`b. It would also have been obvious to one of ordinary skill in the art in the
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`2006-2007 time frame to combine the teachings of Van Woudenberg,
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`which describes backlights with segmented backlighting units of two or
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`more LEDs (Van Woudenberg, Fig. 21; paras. 72, 73), with the teachings
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`of Harbers, which describes a two-dimensional array of grouped LEDs
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`in a backlight (Harbers, Figs. 8B, 10, 11A-B; paras. 7, 29, 30-33), at least
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`because the subject matter of both references is in the same field of
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`endeavor and grouping LEDs together in the backlighting units of Van
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`Expert Declaration of Richard A. Flasck
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`Woudenberg would allow for improved color uniformity and contrast
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`(Harbers, paras. 7, 25, 33).
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`c. It would also have been obvious to one of ordinary skill in the art in the
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`2006-2007 time frame to combine the teachings of Van Woudenberg,
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`which discloses that groups of LEDs in each backlight unit of a display
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`system are controlled based on similar image data corresponding to a
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`given backlight unit (Van Woudenberg, Fig. 21; paras. 72, 73), with the
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`teachings of Harbers, which describes a two-dimensional array of
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`grouped LEDs in a backlight (Harbers, Figs. 8B, 10, 11A-B; paras. 7, 29,
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`30-33), at least because the subject matter of both references is in the
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`same field of endeavor and grouping LEDs together in the backlighting
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`units of Van Woudenberg would allow for improved temporal and
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`spatial control of the LEDs within each backlight unit (Harbers, Fig. 8B,
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`10, 11A-B; para. 7, 30-33).
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`d. Moreover, because both Van Woudenberg and Harbers are directed to
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`LCD display systems with LED backlights, it would be obvious to one
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`of ordinary skill in the art in the 2006-2007 time frame to incorporate
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`the improvement techniques of Harbers (i.e., connecting the LEDs
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`within a group in a series configuration; Harbers, Figs. 8B, 10, 11A-B;
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`No. IPR2014—01268
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`Expert Declaration of Richard A. Flasck
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`paras. 28, 30-33) in the two—dimensional matrix of LEDs described by
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`Van Woudenberg because such a combination would predictably result
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`in a reduction of cost by allowing the use of a simplified driver/inverter
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`to supply drive current to the LEDs in Van Woudenberg’s backlight
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`(Harbers, para. 28).
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`e. Additionally, such a combination would be obvious to one of ordinary
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`skill in the art in the 2006—2007 time frame because it would include
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`combining known structures and techniques in both the systems of Van
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`Woudenberg and Harbers without changing their functions.
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`I declare under penalty of perjury that the foregoing is true and correct
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`Dated:M
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`Z/&%2/fi 7754/;
`
`Richard A. Flasck
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`16
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