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 Petition for Inter Partes Review
`of U.S. Patent No. 8,519,973
`
`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. 8,519,973
`
`

`

`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION ......................................................................................... 1
`
`II. QUALIFICATIONS ...................................................................................... 1
`
`III. MATERIALS CONSIDERED AND PREPARED ...................................... 6
`
`IV. SUMMARY OF OPINIONS ........................................................................ 6
`
`V. LEGAL PRINCIPLES USED IN ANALYSIS ............................................. 7
`
`A. Patent Claims in General ............................................................................... 7
`
`B. Prior Art ......................................................................................................... 8
`
`C. Unpatentability -- Obviousness ..................................................................... 9
`
`VI. BACKGROUND OF RELEVANT TECHNOLOGY ................................11
`
`VII. THE ‘973 PATENT .................................................................................12
`
`VIII. CLAIM CONSTRUCTION .....................................................................16
`
`IX. OVERVIEW OF THE PRIOR ART ...........................................................16
`
`A. Patent Owner’s Admitted Prior Art (APA) ................................................. 16
`
`B. U.S. Patent No. 5,463,388 to Boie et al. (“Boie”)....................................... 18
`
`C. U.S. Patent No. 7,821,502 to Hristov (“Hristov”) ...................................... 23
`
`D. U.S. Patent No. 4,242,676 to Piguet et al. (“Piguet”) ................................. 24
`
`E. U.S. Patent No. 5,543,588 to Bisset et al. (“Bisset”) .................................. 26
`
`X.
`
`INVALIDITY ANALYSIS .........................................................................31
`
`A. The Claims of the ‘973 Patent ..................................................................... 31
`
`B. Claims 1-8, 11, 12, and 14-20 are Obvious in view of Boie and Bisset ..... 37
`
`C. Claims 1-8, 11, 12, and 14-20 are Obvious in view of the APA, Hristov,
`and Piguet ......................................................................................................... 73
`
`XI. CONCLUSION ...........................................................................................97
`
`
`
`ii
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`

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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. 8,519,973 (the “‘973 patent”). I am being compensated for my work in
`
`this matter. My compensation in no way depends upon the outcome of this
`
`proceeding.
`
`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
`
`this matter. I have no financial interest in any of LG Electronics, Inc., LG
`
`Electronics U.S.A., Inc., or LG Electronics Mobilecomm U.S.A., Inc.
`
`4.
`
`I have been advised that Cypress Semiconductor Corp. owns the ‘973
`
`patent. I have no financial interest in the ‘973 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.
`
`
`
`1
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`

`

`7.
`
`I received a Doctor of Philosophy degree in Electrical Engineering
`
`from the University of Illinois at Urbana Champaign, Illinois in 1977.
`
`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
`
`industries including communications, consumer electronics, mobile handsets,
`
`displays, engineering services and defense electronics.
`
`10. As a manager, I have led project teams that were granted more than 50
`
`issued U.S. patents and related foreign filings. I have contributed as an inventor to
`
`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
`
`equipment, and medical diagnostic equipment among other products. My
`
`significant projects included research on crystal growth of semiconductor materials
`
`for light emitting diodes (LEDs) and semiconductor lasers.
`
`
`
`2
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`

`

`12. From 1979-1984, I held positions as a member of technical staff and
`
`supervisor at Bell Telephone Laboratories, a Murray Hill, NJ company that was the
`
`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
`
`Bell Communications Research (Bellcore). My significant projects included
`
`research and development of laser designs and fabrication processes for high
`
`reliability semiconductor lasers used in the first transatlantic optical
`
`communication system.
`
`13. From 1984-1987, I was a founder and manager of Lytel Incorporated,
`
`a Branchburg, NJ firm that developed, manufactured and sold optoelectronic
`
`devices and modules for optical communications systems.
`
`14. From 1987-1990, I was a manager at Ford Microelectronics, Inc., a
`
`Colorado Springs, CO company that designed electronic engine controllers for the
`
`parent Ford Motor Company and conducted independent research and development
`
`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
`
`device performance at frequencies greater than 100 GHz.
`
`
`
`3
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`

`

`15. From 1990-1993, I was the founder, president, and general manager at
`
`Martin Kestrel Company, Inc., a Colorado Springs, Colorado company providing
`
`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
`
`Displays Division was formed to market and manufacture low power, high
`
`information content displays for portable products such as cell phone handsets and
`
`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
`
`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.
`
`My significant consulting engagements involved business development and
`
`
`
`4
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`

`

`commercialization of new products such as printed wiring boards with embedded
`
`optical waveguides, and business development for a company establishing a new
`
`high technology facility in the United Kingdom to provide leased manufacturing
`
`facilities and new business incubation. I also provided market research and
`
`international outreach services for the Optoelectronics Industry Development
`
`Association (OIDA). In 2007, I founded WRT Associates LLC to formalize and
`
`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,
`
`high brightness light emitting diodes (HBLEDs), Organic LEDs (OLEDs), solid
`
`state lighting (SSL), displays, display applications, touch sensors, wireless
`
`handsets, mobile devices, user interfaces, wireless device applications of
`
`optoelectronics, and semiconductor materials and devices.
`
`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
`
`articles. I have authored industry reports, made presentations at leading
`
`international conferences on subjects including the future of interactive displays
`
`and display technologies for mobile devices, and regularly contribute editorial
`
`
`
`5
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`

`content for Insight Media covering information displays, input output device
`
`technologies, user interface advances, and new mobile device technologies.
`
`22. My over forty years of professional experience with electrical
`
`engineering and design, as well as my educational background, are summarized in
`
`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 ‘973 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
`
`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 1–8, 11, 12, and
`
`14-20 of the ‘973 patent are disclosed in prior art references and that those claims
`
`are rendered or obvious in view of these references. In particular, I have relied on
`
`the following prior art references identified below in support of my opinions:
`
`(1) Patent Owner’s Admitted Prior Art (“APA”)
`
`(2) U.S. Patent No. 5,463,388 to Boie et al. (“Boie”)
`
`(3) U.S. Patent No. 7,821,502 to Hristov (“Hristov”)
`
`(4) U.S. Patent No. 5,543,588 to Bisset et al. (“Bisset”)
`
`
`
`6
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`

`

`(5) U.S. Patent No. 4,242,676 to Piguet et al. (“Piguet”)
`
`The basis for my opinions are set forth in greater detail below and in the
`
`claim charts attached as Appendix B.
`
`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
`
`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 1–8, 11, 12, and 14-20 of the ‘973 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 ‘973
`
`patent claims priority—May 18, 2006. From analyzing the ‘973 patent and the
`
`relevant prior art, it is my opinion that a person of ordinary skill in the relevant art
`
`for the ‘973 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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`7
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`

`the words of the claims define what a patent covers. I have also been informed that
`
`the figures and text in the rest of the patent provide a description and/or examples
`
`and help explain the scope of the claims, but that the claims define the breadth of
`
`the patent’s coverage.
`
`28.
`
`I have also been informed that an “independent claim” expressly sets
`
`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
`
`of the elements of the claim(s) from which it depends. I also have been informed
`
`that dependent claims add additional elements. I have been informed that, to
`
`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
`
`“methods” or “apparatuses/devices/systems.” That is, I have been informed that a
`
`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
`
`elements in an “apparatus,” “device,” or “system.”
`
`B.
`
`Prior Art
`
`
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`8
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`

`

`30.
`
`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 informed that, to be prior art with respect to a particular patent in this
`
`proceeding, a 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 opine on, i.e., APA, Boie, Bisset, Piguet, and Hristov, are prior art
`
`from a technical perspective – that is, all were available to a person of ordinary
`
`skill in the art on or before the priority date of the patent.
`
`C. Unpatentability -- Obviousness
`
`31.
`
`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
`
`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
`
`one or more prior art references. I have been informed that a patent is obvious
`
`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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`9
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`known methods to obtain predictable results. I have been informed that the
`
`following four factors are considered when determining whether a patent claim is
`
`obvious: (1) the scope and content of the prior art; (2) the differences between the
`
`prior art and the claim; (3) the level of ordinary skill in the art; and (4) secondary
`
`considerations tending to prove obviousness or nonobviousness. I have also been
`
`informed that the courts have established a collection of secondary factors of
`
`nonobviousness, which include: unexpected, surprising, or unusual results; prior
`
`art that teaches away from the alleged invention; substantially superior results;
`
`synergistic results; long-standing need; commercial success; and copying by
`
`others. I have also been informed that there must be a connection, or nexus,
`
`between these secondary factors and the scope of the claim language.
`
`32.
`
`I have also been informed that some examples of rationales that may
`
`support a conclusion of obviousness include:
`
`a) Combining prior art elements according to known methods to yield
`
`predictable results;
`
`b) Simply substituting one known element for another to obtain
`
`predictable results;
`
`c) Using known techniques to improve similar devices (or product) in
`
`the same way (e.g. obvious design choices);
`
`
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`10
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`d) Applying a known technique to a known device (or product) ready
`
`for improvement to yield predictable results;
`
`e) Choosing from a finite number of identified, predictable solutions,
`
`with a reasonable expectation of success—in other words, whether
`
`something is “obvious to try”;
`
`f) Using work in one field of endeavor to prompt variations of that
`
`work for use in either the same field or a different one based on
`
`design incentives or other market forces if the variations are
`
`predictable to one of ordinary skill in the art; and
`
`g) Arriving at a claimed invention as a result of some teaching,
`
`suggestion, or motivation in the prior art that would have led one
`
`of ordinary skill to modify the prior art reference or to combine
`
`prior art reference teachings.
`
`I have also been informed that other rationales to support a conclusion of
`
`obviousness may be relied upon, for instance, that common sense (where
`
`substantiated) may be a reason to combine or modify prior art to achieve the
`
`claimed invention.
`
`VI. BACKGROUND OF RELEVANT TECHNOLOGY
`
`33. Computing devices, such as notebook computers, personal data
`
`assistants (PDAs) and mobile handsets have user interface devices such as a touch-
`
`
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`11
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`

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`sensor button. Ex. 1001 at 1:20-24. Touch-sensor buttons may be embedded into
`
`different types of operational panels of electronic devices such as on an operational
`
`or control panel of household appliances, consumer electronics, mechanical
`
`devices, etc. Id. at 1:25-32.
`
`34. Conventionally, capacitance sensors are coupled to the touch-sensor
`
`buttons in a one-to-one configuration, where the processing device scans the touch-
`
`sensor buttons using the capacitance sensors, and measures the capacitance on the
`
`touch sensor buttons. Id. at 1:46-52. Other conventional configurations may use
`
`less capacitance sensors to measure the capacitance of the touch-sensor buttons.
`
`However, this configuration may still use a one-to-one configuration of pins to
`
`touch-sensor buttons. Id. at 1:63-67.
`
`35. By adding more buttons, the processing device needs to have more
`
`pins to correspond to the one-to-one configuration of pins to touch-sensor buttons.
`
`Similarly, by increasing the pin count, the scan time to scan the sensor elements
`
`increases. Furthermore, the memory of the processing device increases by
`
`increasing the pin count. Id. at 2:1-8.
`
`VII. THE ‘973 PATENT
`
`36. The ‘973 patent includes 20 claims. Independent claim 1 is directed
`
`to a method directed to determining capacitance variations of a first number of two
`
`or more sense elements of a touch screen by using a processing device to detect a
`
`
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`12
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`

`presence of a conductive object on a second number of three or more button areas.
`
`More specifically, claim 1 requires that the first number of sense elements is less
`
`than the second number of button areas.
`
`37. Fig. 6B of the ‘973 patent (reproduced below) illustrates a
`
`configuration of one more button than a number of sensors as described and
`
`claimed in the ‘973 patent:
`
`
`
`38. According to the ‘973 patent, a processing device 210 detects whether
`
`a conductive object is present on one of the touch-sensor buttons 601-603. The
`
`processing device 210 includes capacitance sensors 201(1) and 201(2) coupled to
`
`buttons 601-603. In this regard, button 601 is coupled to capacitance sensor
`
`
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`13
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`201(1), button 603 is coupled to capacitance sensor 201(2), and button 602 is
`
`coupled to both capacitance sensor 201(1) and 201(2). Ex. 1001 at 17:30-40.
`
`39. Buttons 601-603 are conventional touch-sensor buttons made of a
`
`sensor element of conductive material. The conductive material may be formed in
`
`a circular shape, in a rectangular shape, or in a square shape. The touch-sensor
`
`buttons may be capacitance sensor buttons used as non-contact switches. Id. at
`
`17:41-47.
`
`40. The processing device 210 includes two sensing areas 613 and 614,
`
`which are used to make up the three buttons 601-603. Particularly, button 601
`
`includes a sensor element having a surface area of one conductive material (i.e.,
`
`white surface), and button 603 includes a sensor element having a surface area of
`
`another conductive material. Button 601 is coupled to a first pin 609, and button
`
`603 is coupled to a second pin 610. Id. at 17:50-57, 61-62.
`
`41. Button 602 includes a sensor element having a surface area of two
`
`conductive materials in which a first portion 604 is coupled to the conductive
`
`material of button 601, and a second portion 605 is coupled to the conductive
`
`material of button 603. Id. at 17:58-65. Furthermore, the first portion 604 is
`
`coupled to the sensor element of button 601 using a conductive line 606, and the
`
`second portion 605 is coupled to the sensor element of button 603 using a
`
`conductive line 607. Id. at 18:3-6.
`
`
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`14
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`

`

`42. The conductive lines 606 and 607 may be conductive traces printed on
`
`the surface of a printed circuit board (PCB). The conductive lines may also be
`
`conductive paths of conductive material that couple the conductive material of the
`
`sensor elements to the pins. Id. at 18:6-11.
`
`43. Capacitance variation δ1and δ2 are measured on pins 609 and 610,
`
`respectively. If the capacitance variation δ1, measured on the first pin 609, is
`
`greater than zero, and the capacitance variation δ2, measured on the second pin
`
`610 is equal to approximately zero, then it is determined that the first button 601
`
`has been pressed. Similarly, if the capacitance variation δ1, measured on the first
`
`pin 609, is equal to the capacitance variation δ2 measured on the second pin 610,
`
`then it is determined that the second button 602 has been pressed. If the
`
`capacitance variation δ1, measured on the first pin 609 is equal to approximately
`
`zero, and the capacitance variation δ2, measured on the second pin 610 is greater
`
`than zero, then it is determined that the third button 603 has been pressed. Id. at
`
`18:38-48.
`
`44.
`
`In operation, the processing device 210 scans the touch-sensor buttons
`
`601-603 using the capacitance sensors 201(1) and 201(2), and measures the
`
`capacitance on the two sensing areas of conductive material to recognize activation
`
`of the one of the touch-sensor buttons 601-603. Id. at 18:12-15. For example, the
`
`operation of recognizing the three or more button operations includes recognizing a
`
`
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`15
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`first button operation when the presence of the conductive object is detected on a
`
`first sensing area 613, recognizing a second button operation when the presence of
`
`the conductive object is detected on a second sensing area 614, and recognizing
`
`one or more button operations when the presence of the conductive object is
`
`detected on the first and second sensing areas 613 and 614. Id. at 18:62-19:4.
`
`VIII. CLAIM CONSTRUCTION
`
`45.
`
`In the present proceeding, I have been advised that the claims are to
`
`be given their broadest reasonable interpretation in view of the specification. It is
`
`my further understanding that claim terms are given their ordinary and accustomed
`
`meaning as would be understood by one of ordinary skill in the art, unless the
`
`inventor, as a lexicographer, has set forth a special meaning for a term. Based on
`
`my review of the ‘973 patent specification and file history, in my opinion, each of
`
`the terms recited in claims 1-8, 11, 12, and 14-20 of the ‘973 patent should be
`
`afforded their ordinary and accustomed meaning as understood by one of ordinary
`
`skill in the art.
`
`IX. OVERVIEW OF THE PRIOR ART
`
`A.
`
`Patent Owner’s Admitted Prior Art (APA)
`
`46. Fig. 1B of the ‘973 patent (reproduced below) illustrates a
`
`conventional sensing device:
`
`
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`16
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`

`

`
`
`47.
`
` The ‘973 patent teaches that a conventional processing device 110
`
`includes three touch-sensor buttons 101-103 coupled to the processing device 110.
`
`Processing device 110 is used to detect whether a conductive object is present on
`
`either, or none, of the touch-sensor buttons 101-103. Id. at 1:39-43.
`
`48. To detect the presence of the conductive object, the processing device
`
`110 includes capacitance sensors 104-106 coupled to buttons 101-103,
`
`respectively. The capacitance sensors of the processing device are coupled to the
`
`touch-sensor buttons in a one-to-one configuration. Accordingly, the processing
`
`device 110 scans the touch-sensor buttons 101-103 using the capacitance sensors
`
`104-106, and measures the capacitance on the touch-sensor buttons 101-103. Id. at
`
`17:43-51.
`
`
`
`17
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`

`

`49. Each of the conventional touch-sensor buttons 101-103 may be made
`
`of a sensor element of conductive material, such as copper-clad. The touch-sensor
`
`buttons may be capacitance sensor buttons, which may be used as non-contact
`
`switches. Id. at 1:52-60.
`
`50. Thus, the APA generally teaches every element of claims 1-8, 11, 12,
`
`and 14-20 except for the first number of sense elements is less than the second
`
`number of button areas. However, this feature was well known by one of ordinary
`
`skill in the art and is not novel.
`
`B. U.S. Patent No. 5,463,388 to Boie et al. (“Boie”)
`
`51. Boie teaches a computer input device that includes an insulating
`
`surface covering an array of electrodes. Such electrodes are arranged in a grid
`
`pattern and can be connected in columns and row connected to circuitry for
`
`measuring the capacitance seen by each column and row. The position of an object,
`
`such as a finger or handheld stylus, with respect to the array is determined from the
`
`centroid of such capacitance values. Ex. 1002 at Abstract.
`
`52. Fig. 1 of Boie (reproduced below) illustrates a capacitive position
`
`sensor:
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`18
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`53. As illustrated in Fig. 1, an “[e]lectrode array 100 is a square or
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`rectangular array of electrodes 101 arranged in a grid pattern of rows and columns,
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`as in an array of tiles.” Id. at 2:50-52. The “[h]istogram 110 shows the
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`capacitances for electrodes 101 in array 100 with respect to finger 102.” Id. at
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`2:61-62. A centroid 111 corresponds to the position of finger 102. Id. at 2:64-66.
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`Based on the position of finger 102, the “x and y coordinates of the centroid can be
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`determined by directly measuring the capacitance at each electrode 101 and
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`19
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`calculating such x and y coordinates from such measured capacitances.” Id. at 3:5-
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`8.
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`54. Fig. 4 of Boie illustrates that the electrode array 100 is connected to a
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`capacitive sensor 400.
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`55. Boie teaches that to “measure capacitances separately, a circuit 401 is
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`provided for each electrode,” where a multiplexer 402 accommodates the outputs
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`from all circuits 401. Id. at 4:18-20. In this regard, “[e]ach of the outputs from
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`circuits 401 can be selected by multiplexer 402 under control of microcontroller
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`406.” Id. at 3:60-61. A “selected output is then forwarded to [a] summing circuit
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`403, where such output is combined with a signal from trimmer resistor 409.” Id.
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`at 3:62-64. The “[s]ynchronous detector and filter 404 … [converts] the output
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`20
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`from summing circuit 403 to a signal related to the capacitance of the row or
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`column selected by multiplexer 402.” Id. at 3:64-67. Furthermore, the “output of
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`synchronous detector filter 404 is converted to digital form by analog-to-digital
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`converter 405,” where the microcontroller 406 obtains “a digital value representing
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`the capacitance seen by any row or column … selected by multiplexer 402.” Id. at
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`4:24-27. Although Fig. 4 of Boie does not include the numeral 400, I understand
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`that elements 401-411 and 420 are part of the capacitance sensor 400.
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`56. Fig. 6 of Boie illustrates a process for measuring capacitance values
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`and computing the x and y values of a centroid, which is described as follows:
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`Referring to FIG. 6, microcomputer 406 reads the initial
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`capacitance values for all the elements in array 100 and
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`stores such values (step 601). Such initial values should reflect
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`the state of array 100 without a finger or other object being
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`nearby, accordingly, it may be desirable to repeat step 601 a
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`number of times and then to select the minimum
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`capacitance values read as the initial values, thereby
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`compensating for the effect of any objects moving close to
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`array 100 during the initialization step. After initialization, all
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`capacitance values are periodically read and the initial
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`values subtracted to yield a remainder value for each
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`element (step 602). If one or more of the remainders exceeds a
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`preset threshold (step 603), indicating that an object is close
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`to or touching array 100, then the x and y coordinates of the
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`centroid of capacitance for such object can be calculated
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`21
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`from such remainders (step 604). Id. at 5:10-24 (emphasis
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`added).
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`57. Fig. 7 of Boie is a diagram illustrating how the array 100 is used as a
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`keyboard.
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`58. As illustrated in Fig. 7, “array 100 is shown as a 4X4 matrix of
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`electrodes, but with a keyboard pattern overlay superimposed on the matrix.” Id.
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`at 6:62-64. Boie teaches the “identity of a key touched is determined from the x
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`and y values computed for the centroid of capacitance resulting from the touch.”
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`Id. at 7:6-8. In this regard, using the x and y coordinates shown in Fig. 7:
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`a “5” can be defined as a touch with [l.7 < x < 2.3, 2.3 < y <
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`2.7]; a “0” can be defined as a touch with [l < x < 2.3, 1 < y <
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`1.3]; and a “+” can be defined as a touch with [3.7 < x < 4, 2.4
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`< y < 3.5]. These ranges are chosen to leave guard bands
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`22
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`between adjacent keys. Such a range for each key on the
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`keyboard is stored in microprocessor 406. Id. at 7:9-14.
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`59. Fig. 8 of Boie illustrates a process performed by microcomputer 406
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`when the capacitance position sensor is used as a keyboard. The process is
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`described as follows:
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`Steps 801, 802, 803 and 805 are similar to steps 601, 602, 603
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`and 604, respectively, in FIG. 6. In step 805, the identity of the
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`key touched is determined from the stored ranges and the values
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`of x and y calculated in step 806. In step 807, the identity of the
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`key touched is sent to utilizing means. The "T" flag is set in
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`step 808, cleared in step 809 and tested in step 804. Such flag
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`assures that the key identity is sent to utilizing means only
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`once. Id. at 17:17-25.
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`C. U.S. Patent No. 7,821,502 to Hristov (“Hristov”)
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`60.
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`I have reviewed U.S. Provisional App. No. 60/697,613 (i.e., the
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`provisional application from which Hristov claims priority), and submit that the
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`subject matter of Hristov is supported by U.S. Provisional App. No. 60/697,613.
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`Figs. 4 and 6 of Hristov, which are reproduced below, illustrate a display screen 54
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`overlaid on a pattern of sensing electrodes. The display screen 54 includes pre-
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`defined areas corresponding to a plurality of keys numbered 0-9 and an “ENTER”
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`key. Ex. 1004 at 10:15-19.
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`23
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`61. Hristov further teaches that the position sensor 22 “is operable to
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`determine the position of an object along a first (x) and second (y) direction.” Id.
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`at 5:36-47. The sensor 22 includes a substrate 24 having an arrangement of
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`sensing electrodes 26 that define a sensing area within which the position of an
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`object is determined. Id.
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`62. Hristov also teaches that “the position of buttons is arbitrary,” “any
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`known interface schema can be deployed over the face of the screen, such as menu
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`buttons, sliders, wheels, gesture recognition, and the like,” and “these schemes do
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`not need to be aligned with the cells, and can be placed arbitrarily over the
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`surface.” Id. at 10:31-36 (emphasis added).
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`D. U.S. Patent No. 4,242,676 to Piguet et al. (“Piguet”)
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`63.
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` Piguet teaches “a sensor formed by a plurality of capacitive …
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`electrodes.” Ex. 1003 at Abstract. Fig. 1 of Piguet