UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS, INC., LG ELECTRONICS, U.S.A., LG ELECTRONICS
`MOBILECOMM U.S.A., INC.
`Petitioners
`v.
`
`CYPRESS SEMICONDUCTOR CORP.
`Patent Owner
`
`DECLARATION OF DR. PHILLIP WRIGHT
`in Support of Inter Partes Review Petition for U.S. Pat. No. 8,059,015
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`EXHIBIT 1010
`IPR Petition for U.S. Patent No. 8,059,015
`
`

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`TABLE OF CONTENTS
`TABLE OF CONTENTS
`
`I.
`I.
`
`INTRODUCTION ......................................................................................... 1
`INTRODUCTION ....................................................................................... ..1
`
`II. QUALIFICATIONS ...................................................................................... 1
`II. QUALIFICATIONS .................................................................................... ..1
`
`III. MATERIALS CONSIDERED AND PREPARED ...................................... 6
`III. MATERIALS CONSIDERED AND PREPARED .................................... ..6
`
`IV. SUMMARY OF OPINIONS ........................................................................ 6
`IV. SUMMARY OF OPINIONS ...................................................................... ..6
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`V. LEGAL PRINCIPLES USED IN ANALYSIS ............................................. 7
`V. LEGAL PRINCIPLES USED IN ANALYSIS ........................................... ..7
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`A. Patent Claims in General ............................................................................... 7
`A. Patent Claims in General ............................................................................. ..7
`
`B. Prior Art ......................................................................................................... 8
`B. Prior Art ....................................................................................................... ..8
`
`C. Unpatentability -- Anticipation ..................................................................... 9
`C. Unpatentability —— Anticipation ................................................................... ..9
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`D. Unpatentability -- Obviousness ................................................................... 10
`D. Unpatentability —— Obviousness ................................................................. .. 10
`
`VI. BACKGROUND OF RELEVANT TECHNOLOGY ................................13
`VI. BACKGROUND OF RELEVANT TECHNOLOGY .............................. .. 13
`
`VII. THE ‘015 PATENT .................................................................................15
`VII.
`THE ‘O15 PATENT ............................................................................... ..15
`
`VIII. CLAIM CONSTRUCTION .....................................................................18
`VIII. CLAIM CONSTRUCTION ................................................................... ..18
`
`IX. OVERVIEW OF THE PRIOR ART ...........................................................18
`IX. OVERVIEW OF THE PRIOR ART ......................................................... ..18
`
`A. U.S. Patent No. 7,821,502 to Hristov (“Hristov”) ...................................... 18
`A. U.S. Patent No. 7,821,502 to Hristov (“Hristov”) .................................... ..18
`
`B. U.S. Patent No. 5,463,388 to Boie et al. (“Boie”)....................................... 22
`B. U.S. Patent No. 5,463,388 to Boie et al. (“Boie”) ..................................... ..22
`
`C. Andre (U.S. Pat. No. 7,844,914) ................................................................. 29
`C. Andre (U.S. Pat. No. 7,844,914) ............................................................... ..29
`
`X.
`X.
`
`INVALIDITY ANALYSIS .........................................................................30
`INVALIDITY ANALYSIS ....................................................................... ..30
`
`A. The Claims of the ‘015 Patent ..................................................................... 30
`A. The Claims of the ‘O15 Patent ................................................................... ..30
`
`B. Claims 1, 2, 4, and 6 are anticipated by Hristov ......................................... 35
`B. Claims 1, 2, 4, and 6 are anticipated by Hristov ....................................... ..35
`
`C. Claims 5, 7, 13, 15, 17-19, 21, and 22 are Obvious in view of Hristov ..... 48
`C. Claims 5, 7, 13, 15, 17-19, 21, and 22 are Obvious in view of Hristov .....48
`
`D. Claims 1, 2, 4-7, 13, 17-19, 21, and 22 are obvious in view of Boie
`D. Claims 1, 2, 4-7, 13, 17-19, 21, and 22 are obvious in view of Boie
`and Andre ......................................................................................................... 57
`and Andre ....................................................................................................... ..57
`
`E. Claim 15 is rendered Obvious in view of Boie, Andre, and Hristov .......... 82
`E. Claim 15 is rendered Obvious in view of Boie, Andre, and Hristov ........ ..82
`
`XI. CONCLUSION ...........................................................................................84
`XI. CONCLUSION ......................................................................................... ..84
`
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`I, Dr. Phillip (Phil) Wright, hereby declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I am currently the Founder and Managing Director of WRT
`
`Associates, LLC, which provides, among other services, engineering consulting.
`
`2.
`
`I have been retained in this matter by Rothwell, Figg, Ernst &
`
`Manbeck, P.C. (“Rothwell Figg”) to provide various opinions regarding U.S.
`
`Patent No. 8,059,015 (the “‘015 patent”). I am being compensated for my work in
`
`this matter. My compensation in no way depends upon the outcome of this
`
`proceeding.
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`3.
`
`I have been advised that Rothwell Figg represents LG Electronics,
`
`Inc., LG Electronics U.S.A., Inc., and LG Electronics Mobilecomm U.S.A., Inc. in
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`this matter. I have no financial interest in any of LG Electronics, Inc., LG
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`Electronics U.S.A., Inc., or LG Electronics Mobilecomm U.S.A., Inc.
`
`4.
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`I have been advised that Cypress Semiconductor Corp. owns the ‘015
`
`patent. I have no financial interest in of the ‘015 patent.
`
`II. QUALIFICATIONS
`
`5.
`
`I received a Bachelor of Science in Engineering from Purdue
`
`University, West Lafayette, Indiana in 1972.
`
`6.
`
`I received a Master of Science in Electrical Engineering from the
`
`University of Illinois at Urbana Champaign, Illinois in 1975.
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`7.
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`I received a Doctor of Philosophy degree in Electrical Engineering
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`from the University of Illinois at Urbana Champaign, Illinois in 1977.
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`8. My Ph.D. research was supervised by Prof. Nick Holonyak. My Ph.D.
`
`dissertation was entitled Near Infrared Indium Gallium Phosphide Arsenide
`
`Heterojunction Lasers.
`
`9.
`
`Since completing my graduate studies, I have worked at Fortune 500
`
`and start-up companies on semiconductor, electronic, optical, information display
`
`and optoelectronic technology development. I have contributed to several
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`industries including communications, consumer electronics, mobile handsets,
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`displays, engineering services and defense electronics.
`
`10. As a manager, I have led project teams that were granted more than 50
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`issued U.S. patents and related foreign filings. I have contributed as an inventor to
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`16 issued U.S. patents.
`
`11. From 1977 to 1979, I was an engineer at Varian Associates, a Palo
`
`Alto, CA based company that developed, manufactured and sold semiconductor
`
`devices, high vacuum material processing equipment, semiconductor processing
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`equipment, and medical diagnostic equipment among other products. My
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`significant projects included research on crystal growth of semiconductor materials
`
`for light emitting diodes (LEDs) and semiconductor lasers.
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`
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`12. From 1979-1984, I held positions as a member of technical staff and
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`supervisor at Bell Telephone Laboratories, a Murray Hill, NJ company that was the
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`research arm of the Bell System and the American Telephone and Telegraph
`
`Company (AT&T). In 1984 I was a district research manager of the newly formed
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`Bell Communications Research (Bellcore). My significant projects included
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`research and development of laser designs and fabrication processes for high
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`reliability semiconductor lasers used in the first transatlantic optical
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`communication system.
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`13. From 1984-1987, I was a founder and manager of Lytel Incorporated,
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`a Branchburg, NJ firm that developed, manufactured and sold optoelectronic
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`devices and modules for optical communications systems.
`
`14. From 1987-1990, I was a manager at Ford Microelectronics, Inc., a
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`Colorado Springs, CO company that designed electronic engine controllers for the
`
`parent Ford Motor Company and conducted independent research and development
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`on behalf of Ford Aerospace Corporation. My significant projects included
`
`development of integrated circuit (IC) technology with performance at frequencies
`
`up to 80 GHz and analysis of the influence of transistor design parameters on
`
`device performance resulting in improved understanding and achievement of
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`device performance at frequencies greater than 100 GHz.
`
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`15. From 1990-1993, I was the founder, president, and general manager at
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`Martin Kestrel Company, Inc., a Colorado Springs, Colorado company providing
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`device-oriented semiconductor material evaluation services to the global epitaxial
`
`semiconductor material industry.
`
`16. From 1993-1998, I was a manager at Motorola in Tempe, AZ. I
`
`helped established the Displays Division of the Consumers Systems Group. The
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`Displays Division was formed to market and manufacture low power, high
`
`information content displays for portable products such as cell phone handsets and
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`digital cameras.
`
`17.
`
` In 1999, I was director, development engineering at AMP
`
`Incorporated in Harrisburg, PA which was acquired that year by Tyco Electronics.
`
`At AMP I managed a staff of 30 engineers and technicians at two locations
`
`responsible for product development of optoelectronic components, packaging, and
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`transceivers for optical data communications.
`
`18. From 2000-2001, I was project director, Corning Inc., Corning, NY.
`
`At Corning I directed a fast track optical switch project with an annual operating
`
`budget of $140 million working with geographically dispersed project teams at six
`
`locations in the US and Europe.
`
`19. Beginning in 2002, I commenced work as an independent consultant.
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`My significant consulting engagements involved business development and
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`commercialization of new products such as printed wiring boards with embedded
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`optical waveguides, and business development for a company establishing a new
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`high technology facility in the United Kingdom to provide leased manufacturing
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`facilities and new business incubation. I also provided market research and
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`international outreach services for the Optoelectronics Industry Development
`
`Association (OIDA). In 2007, I founded WRT Associates LLC to formalize and
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`expand my consulting practice.
`
`20. Presently I am the founder, managing director, and chief analyst of
`
`WRT Associates in Fort Collins, CO. I provide technical consulting and market
`
`analysis for new and emerging high technologies including optoelectronics, optics,
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`high brightness light emitting diodes (HBLEDs), Organic LEDs (OLEDs), solid
`
`state lighting (SSL), displays, display applications, touch sensors, wireless
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`handsets, mobile devices, user interfaces, wireless device applications of
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`optoelectronics, and semiconductor materials and devices. Engagements include
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`technical consulting, intellectual property assessment, and expert testimony in
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`litigations.
`
`21.
`
`I am a Senior Member of the Institute of Electrical and Electronic
`
`Engineers (IEEE) and the author or coauthor of numerous peer reviewed technical
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`articles. I have authored industry reports, made presentations at leading
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`international conferences on subjects including the future of interactive displays
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`and display technologies for mobile devices, and regularly contribute editorial
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`content for Insight Media covering information displays, input output device
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`technologies, user interface advances, and new mobile device technologies.
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`22. My over forty years of professional experience with electrical
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`engineering and design, as well as my educational background, are summarized in
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`more detail in my C.V., which is attached as Appendix A.
`
`III. MATERIALS CONSIDERED AND PREPARED
`
`23.
`
`In forming the opinions expressed below, I considered the ‘015 patent
`
`and its file history as well as the prior art references and related documentation
`
`discussed herein. I have also relied upon my education, background, and
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`experience.
`
`IV. SUMMARY OF OPINIONS
`
`24. Based on my investigation and analysis, and for the reasons set forth
`
`below, it is my opinion that all of the elements recited in claims 1, 2, 4-7, 13, 15,
`
`17-19, 21, and 22 of the ‘015 patent are disclosed in prior art references and that
`
`those claims are rendered or obvious in view of these references. In particular, I
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`have relied on the following prior art references identified below in support of my
`
`opinions:
`
`(1) U.S. Patent No. 5,463,388 to Boie et al. (“Boie”)
`
`(2) U.S. Patent No. 7,821,502 to Hristov (“Hristov”)
`
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`(3) U.S. Patent No. 7,844,914 to Andre (“Andre”)
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`The bases for my opinions are set forth in greater detail below and in the
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`claim charts attached as Appendix B.
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`V. LEGAL PRINCIPLES USED IN ANALYSIS
`
`25.
`
`I am not a patent attorney nor have I independently researched the law
`
`on patent validity. LGE’s attorneys have explained certain legal principles to me
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`that I have relied on in forming my opinions set forth in this declaration.
`
`26.
`
`I was informed that my assessment and determination of whether or
`
`not claims 1, 2, 4-7, 13, 15, 17-19, 21, 22 of the ‘015 patent are patentable must be
`
`undertaken from the perspective of what would have been known or understood by
`
`someone of ordinary skill in the art as of the earliest date from which the ‘015
`
`patent claims priority—May 25, 2006. From analyzing the ‘015 patent and the
`
`relevant prior art, it is my opinion that a person of ordinary skill in the relevant art
`
`for the ‘015 patent would have at least a Bachelor of Science in electrical
`
`engineering with 1-2 years of design experience or comparable amount of
`
`combined education and equivalent industry experience in electronic and sensor
`
`design.
`
`A.
`
`Patent Claims in General
`
`27.
`
`I have been informed that patent claims are the numbered sentences at
`
`the end of each patent. I have been informed that the claims are important because
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`the words of the claims define what a patent covers. I have also been informed that
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`the figures and text in the rest of the patent provide a description and/or examples
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`and help explain the scope of the claims, but that the claims define the breadth of
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`the patent’s coverage.
`
`28.
`
`I have also been informed that an “independent claim” expressly sets
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`forth all of the elements that must be met in order for something to be covered by
`
`that claim. I have also been informed that a “dependent claim” does not itself
`
`recite all of the elements of the claim but refers to another claim for some of its
`
`elements. In this way, the claim “depends” on another claim and incorporates all
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`of the elements of the claim(s) from which it depends. I also have been informed
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`that dependent claims add additional elements. I have been informed that, to
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`determine all the elements of a dependent claim, it is necessary to look at the
`
`recitations of the dependent claim and any other claim(s) on which it depends.
`
`29.
`
`I have also been informed that patent claims may be expressed as
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`“methods” or “apparatuses/devices/systems.” That is, I have been informed that a
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`patent may claim the steps of a “method,” such as a particular way to perform a
`
`process in a series of ordered steps, or may claim a combination of various
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`elements in an “apparatus,” “device,” or “system.”
`
`B.
`
`Prior Art
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`I have been informed that the law provides categories of information (known
`
`as “prior art”) that may anticipate or render obvious patent claims. I have been
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`informed that, to be prior art with respect to a particular patent in this proceeding, a
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`reference must have been published, or patented, or be the subject of a patent
`
`application by another, before the priority date of the patent. I have also been
`
`informed that a person of ordinary skill in the art is presumed to have knowledge
`
`of all prior art. I have been asked to presume that the reference materials that I
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`opine on, i.e., Boie, Hristov, and Andre, are prior art from a technical perspective –
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`that is, all were available to a person of ordinary skill in the art on or before the
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`priority date of the patent.
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`C. Unpatentability -- Anticipation
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`30.
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`I have been informed and understand that determination of whether a
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`patent claim is “anticipated” is a two-step process. First, the language of the claim
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`is construed as it would be understood by one of ordinary skill in the art at the time
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`of the filing of the patent application. Reference is made to the intrinsic evidence
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`of record, which includes the language of the claim itself and other issued claims,
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`the patent specification, and the prosecution history. Words in a claim will be
`
`given their ordinary or accustomed meaning unless it appears that the inventor
`
`used them differently. The prosecution history may limit the interpretation of the
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`claim, especially if the applicant disavowed or disclaimed any coverage in order to
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`obtain allowance of the claim.
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`31. Second, I understand that after the patent claim has been construed,
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`determining anticipation of the patent claim requires a comparison of the properly
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`construed claim language to the prior art on an element-by-element basis.
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`32.
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`I understand that a claimed invention is “anticipated” if each and
`
`every element of the claim has been disclosed in a single prior art reference, or has
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`been embodied in a single prior art device or practice, either explicitly or
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`inherently (i.e., necessarily present or implied). I understand that prior art includes
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`various categories of information such as printed publications, patents, actual
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`commercial products, and/or other physical embodiments.
`
`33.
`
`I understand that although anticipation cannot be established by
`
`combining references, additional references may be used to interpret the
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`anticipating reference by, for example, indicating what the anticipating reference
`
`would have meant to one having ordinary skill in the art.
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`D. Unpatentability -- Obviousness
`
`34.
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`I have been informed that, even if every element of a claim is not
`
`found explicitly or implicitly in a single prior art reference, the claim may still be
`
`unpatentable if the differences between the claimed elements and the prior art are
`
`such that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person of ordinary skill in the art. That is, the invention
`
`may be obvious to a person having ordinary skill in the art when seen in light of
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`one or more prior art references. I have been informed that a patent is obvious
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`when it is only a combination of old and known elements, with no change in their
`
`respective functions, and that these familiar elements are combined according to
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`known methods to obtain predictable results. I have been informed that the
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`following four factors are considered when determining whether a patent claim is
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`obvious: (1) the scope and content of the prior art; (2) the differences between the
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`prior art and the claim; (3) the level of ordinary skill in the art; and (4) secondary
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`considerations tending to prove obviousness or nonobviousness. I have also been
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`informed that the courts have established a collection of secondary factors of
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`nonobviousness, which include: unexpected, surprising, or unusual results; prior
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`art that teaches away from the alleged invention; substantially superior results;
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`synergistic results; long-standing need; commercial success; and copying by
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`others. I have also been informed that there must be a connection, or nexus,
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`between these secondary factors and the scope of the claim language.
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`35.
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`I have also been informed that some examples of rationales that may
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`support a conclusion of obviousness include:
`
`a) Combining prior art elements according to known methods to yield
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`predictable results;
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`b) Simply substituting one known element for another to obtain
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`predictable results;
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`c) Using known techniques to improve similar devices (or product) in
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`the same way (e.g. obvious design choices);
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`d) Applying a known technique to a known device (or product) ready
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`for improvement to yield predictable results;
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`e) Choosing from a finite number of identified, predictable solutions,
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`with a reasonable expectation of success—in other words, whether
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`something is “obvious to try”;
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`f) Using work in one field of endeavor to prompt variations of that
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`work for use in either the same field or a different one based on
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`design incentives or other market forces if the variations are
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`predictable to one of ordinary skill in the art; and
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`g) Arriving at a claimed invention as a result of some teaching,
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`suggestion, or motivation in the prior art that would have led one
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`of ordinary skill to modify the prior art reference or to combine
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`prior art reference teachings.
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`I have also been informed that other rationales to support a conclusion of
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`obviousness may be relied upon, for instance, that common sense (where
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`substantiated) may be a reason to combine or modify prior art to achieve the
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`claimed invention.
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`VI. BACKGROUND OF RELEVANT TECHNOLOGY
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`36. The ‘015 patent teaches that devices “such as notebook computers,
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`personal data assistants (PDAs), and mobile handsets [that] have user interface
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`devices” such as a keyboard. Ex. 1001 at 1:11-15.1
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`37. Fig. 1A of the ‘015 patent (reproduced below) illustrates a
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`conventional keyboard device, which is admitted prior art.
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`
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`1 Citations to Exhibits (e.g., Exhibits 1001-1005, 1011, and 1012) refer to Exhibits
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`listed in (and filed with) Petitioners’ Petition for Inter Partes Review of U.S.
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`Patent No. 8,059,015.
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`38. This conventional keyboard 100 includes a keyboard architecture
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`using a resistance matrix that includes multiple rows (X0-X2), and multiple
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`columns (Y0-Y2). All the rows are each connected to a pull-up resistor (e.g.,
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`103(0)-103(2)), and all the columns 102(0)-102(2) are each connected to a pull-
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`down transistor (e.g., 104(0)-104(2)). Above the resistance matrix, there are
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`multiple buttons 105(0)-105(8) (e.g., keyboard keys). Upon pressing a button, the
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`corresponding row and column (X, Y) will be shorted together. For example, the
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`row X will read “0,” otherwise the row X is “1.” Ex. 1001at 1:20-32.
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`39. As an example, the ‘015 patent teaches that when a keyboard key 108
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`is pressed, the two contacts 106 and 107 are shorted together, and the row and
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`column of the keyboard key 108 are electrically connected. Id. at 1:41-44.
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`40. The resistance matrix of the conventional keyboard 100 “have large
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`pin counts because every row and every column is connected to a pin.” Id. at 1:62-
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`64. The large pin count “may increase the die area of the circuit.” Id. at 2:1-3.
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`41.
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`“Another conventional keyboard may include a virtual keyboard,”
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`which is “a representation of a keyboard displayed on a touch screen.” Id. at 2:12-
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`14. Furthermore, another “conventional virtual keyboard is a representation of a
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`keyboard projected onto a flat surface such as a desktop. Id. at 2:22-24.
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`VII. THE ‘015 PATENT
`
`42. The ‘015 patent is directed to “an apparatus and method for selecting
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`a keyboard key based on a position of a presence of a conductive object on a
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`sensing device and a pre-defined area of the keyboard key.” Ex. 1001 at 3:34-37.
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`43. The ‘015 patent includes claims 1-26. Independent claim 1 is directed
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`to a method of assigning a plurality of keyboard keys to pre-defined areas of a
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`sensing surface of a sensing device having a plurality of sensor elements, detecting
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`a position of a presence of the conductive object on the sensing device, and
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`selecting a keyboard key. Furthermore, claim 1 requires that “at least one of the
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`plurality of sensor elements corresponds to multiple pre-defined areas.”
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`44.
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`In this regard, the ‘015 patent teaches that “multiple keyboard keys
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`can be assigned to pre-determined areas on a single sensor element.” Id. at 4:14-
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`16. For example, the ‘015 patent teaches that a first keyboard key A “is assigned
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`between 1 and 3 in the x-direction, and between 5 and 7 in the y-direction (e.g.,
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`{1<X<3 & 5<Y<7}).” Id. at 4:18-21.
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`45. Fig. 6A of the ‘015 patent (reproduced below), illustrates a single
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`sensor element having three keyboard keys assigned to the sensor element. Id. at
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`18:25-26.
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`46. Fig. 6C of the ‘015 patent (reproduced below) illustrates an
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`embodiment of a processing device coupled to a sensing device.
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`16
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`47. The ‘015 patent teaches that “a processing device 210 coupled to a
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`sensing device that has a capacitance sensor matrix 650 and keyboard keys A-Z
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`606(0)-606(25) assigned to pre-defined areas of the sensing device.” Ex. 1001 at
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`19:63-66. The “[c]apacitance sensor matrix 600 includes eight rows 504(1)-504(8)
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`and eight columns 505(1)-505(8).” Id. at 19:66-20:1. The “[c]olumns 505(1)-
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`505(8) are coupled to processing device 210 using capacitance sensing pins,
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`conductive traces 502.” Id. at 20:5-6. The ‘015 patent teaches that since “sensor
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`matrix 650 is an 8x8 matrix, there are 16 total capacitance sensing pins that couple
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`the sensor matrix 650 to the processing device 210.” Id. at 20:6-9. Additionally,
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`“[k]eyboard keys 606(0)-606(25), which represent the letters A to Z of the
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`alphabet, are assigned to pre-defined areas of the sensing device.” Id. at 20:9-13.
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`VIII. CLAIM CONSTRUCTION
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`48.
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`In the present proceeding, I have been advised that the claims are to
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`be given their broadest reasonable interpretation in view of the specification. It is
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`my further understanding that claim terms are given their ordinary and accustomed
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`meaning as would be understood by one of ordinary skill in the art, unless the
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`inventor, as a lexicographer, has set forth a special meaning for a term. Based on
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`my review of the ‘015 patent specification and file history, in my opinion, each of
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`the terms recited in claims 1, 2, 4-7, 13, 15, 17-19, 21, and 22 of the ‘015 patent
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`should be afforded its ordinary and accustomed meaning as understood by one of
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`ordinary skill in the art.
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`IX. OVERVIEW OF THE PRIOR ART
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`A. U.S. Patent No. 7,821,502 to Hristov (“Hristov”)
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`49. Fig. 3 of Hristov (reproduced below) illustrates a position sensor 22.
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`50. Hristov teaches that the position sensor 22 “is operable to determine
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`the position of an object along a first (x) and second (y) direction.” Ex. 1004 at
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`5:36-47. The sensor 22 includes a substrate 24 having an arrangement of sensing
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`electrodes 26 that define a sensing area within which the position of an object is
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`determined. Id. The “pattern of the sensing electrodes on the substrate 24 is such
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`as to divide the sensing area into an array (grid) of sensing cells 28 arranged into
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`rows and columns.” Id. at 5:58-62.
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`51. The position sensor 22 includes “a series of capacitance measurement
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`channels 42 coupled to respective ones of” sensing electrodes. Id. at 7:59-62.
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`Each “measurement channel is operable to generate a signal indicative of a value
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`of capacitance between the associated column or row of sensing electrodes. Id. at
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`7:62-64.
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`52. Hristov teaches the structure of the measurement channels as follows:
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`The capacitance measurement channels 42 are shown in
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`FIG. 3 as two separate banks with one bank coupled to the rows
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`of row sensing electrodes (measurement channels labeled y1 to
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`y5) and one bank coupled to the columns of column sensing
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`electrodes (measurement channels labeled x1 to x4). However,
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`it will be appreciated that in practice all of the measurement
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`channel circuitry will most likely be provided in a single unit
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`such as a programmable or application specific integrated
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`circuit. Furthermore, although nine separate measurement
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`channels are shown in FIG. 3, the capacitance measurement
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`channels could equally be provided by a single capacitance
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`measurement channel with appropriate multiplexing although
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`this is not a preferred mode of operation. Equally the circuitry
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`of the kind described in U.S. Pat. No. 5,463,388 or similar can
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`be used, which while using a scanning multiplexer does drive
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`all the rows and columns with a single oscillator simultaneously
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`in order to propagate a laminar set of sensing fields through the
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`overlying substrate. Preferably, the sensing channels 42 are
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`multiple in-phase charge-transfer sensors of the type described
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`in U.S. Pat. No. 5,730,165 or U.S. Pat. No. 6,466,036. Driving
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`multiple ones of such sensing circuits in a phase synchronous
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`manner provides for a desirable laminar field flow.
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`Ex. 1004 at 7:65-8:20.
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`53.
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` Hristov teaches that “signals indicative of the capacitance values
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`measured by the measurement channels 42 are provided to processing circuitry
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`44,” where the “processing circuitry is configured to determine the interpolated
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`position of a capacitive load applied to the sensing area by an object adjacent [to]
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`the position sensor.” Ex. 1004 at 8:30-34. Hristov further teaches that “[t]he
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`interpolated position of the capacitive load along the x-direction is determined
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`from the signals from the capacitance measurement channels associated with the
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`columns of column sensing electrodes and the interpolated position of the
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`capacitive load along the y-direction is determined from the signals from the
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`capacitance measurement channels associated with the rows of row sensing
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`electrodes,” where “[o]nce the position of the object along the x- and y-directions
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`has been determined, the position is reported to a host controller 46 so that it can
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`take appropriate action.” Id. at 8:35-44.
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`54. Fig. 6 of Hristov (reproduced below) illustrates a display screen 54
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`overlaid on a pattern of sensing electrodes 28. Ex. 1004 at 10:15-17.
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`55. Hristov teaches that the display screen 54 includes a “menu of
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`commands displayed to a user … [including] a series of box outlines in which the
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`numbers 0 to 9 are displayed, a box outline containing the word ‘Enter’, and a box
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`outline of a box partially filled with shading and having gradations marked next to
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`it representing the volume of music being played….” Id. at 10:17-23.
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`B. U.S. Patent No. 5,463,388 to Boie et al. (“Boie”)
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`56. Boie teaches a computer input device that includes an insulating
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`surface covering an array of electrodes. Such electrodes are arranged in a grid
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`pattern and can be connected in columns and row connected to circuitry for
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`measuring the capacitance seen by each column and row. The position of an object,
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`such as a finger or handheld stylus, with respect to the array is determined from the
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`centroid of such capacitance values. Id. at Abstract.
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`57. Fig. 1 of Boie (reproduced below) illustrates a capacitive position
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`sensor:
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`As illustrated in Fig. 1, an “[e]lectrode array 100 is a square or rectangular array of
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`electrodes 101 arranged in a grid pattern of rows and columns, as in an array of
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`tiles.” Id. at 2:50-52. The “[h]istogram 110 shows the capacitances for electrodes
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`101 in array 100 with respect to finger 102.” Id. at 2:61-62. A centroid 111
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`corresponds to the position of finger 102. Id. at 2:64-66. Based on the position of
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`finger 102, the “x and y coordinates of the centroid can be determined by directly
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`measuring the capacitance at each electrode 101 and calculating such x and y
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`coordinates from such measured capacitan