throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`LG DISPLAY CO., LTD.
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`_______________
`
`Case: IPR2014-01357
`
`Patent 6,755,547
`_______________
`
`PETITION FOR INTERPARTESREVIEW
`OF U.S. PATENT NO. 6,755,547
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`TABLE OF CONTENTS
`
`I.
`II.
`III.
`IV.
`
`V.
`
`VI.
`
`MANDATORY NOTICES .............................................................................1
`PAYMENT OF FEES .....................................................................................4
`STANDING.....................................................................................................4
`REQUEST FOR INTER PARTES REVIEW OF CLAIMS 1-4, 16, AND 26
`OF THE ’547 PATENT...................................................................................5
`Technology Background........................................................................5
`A.
`The Alleged Invention Of The ’547 Patent ...........................................6
`B.
`CLAIM CONSTRUCTION.............................................................................7
`Standards For Claim Construction ........................................................7
`A.
`“deformities” (Claims 1-4, 16, 26) .........................................................8
`B.
`SUMMARY OF PRIOR ART TO THE ’547 PATENT FORMING THE
`BASIS FOR THIS PETITION ........................................................................8
`Admitted Prior Art................................................................................8
`A.
`U.S. Patent No. 4,729,068 (“Ohe”) (Ex. 1007) ......................................8
`A.
`U.S. Patent No. 5,598,280 (“Nishio”) (Ex. 1008)...................................9
`B.
`U.S. Patent No. 5,005,108 (“Pristash”) (Ex. 1006).................................9
`C.
`U.S. Patent No. 5,408,388 (“Kobayashi”) (Ex. 1009)...........................10
`D.
`U.S. Patent No. 5,386,347 (“Matsumoto”) (Ex. 1010) .........................10
`E.
`VII. GROUNDS FOR UNPATENTABILITY OF EACH CLAIM.....................10
`A.
`Ground 1: Claims 1-4 and 26 are Unpatentable Under 35 U.S.C. §102 as
`Anticipated by Ohe .............................................................................11
`Ground 2: Claims 1, 3, 4, and 16 are Unpatentable Under 35 U.S.C.
`§102(e) as Being Anticipated by Nishio ...............................................18
`Ground 3: Claims 1-4, 16, and 26 are Unpatentable Under 35 U.S.C.
`§103(a) as Being Obvious in View of Pristash .....................................25
`Ground 4: Claims 1-4, 16, and 26 are Unpatentable Under 35 U.S.C.
`§103(a) as Obvious Over Kobayashi in View of Ohe ..........................34
`Ground 5: Claims 1-4 and 26 are Unpatentable Under 35 U.S.C. §103(a)
`as Obvious Over Pristash in View of Matsumoto................................45
`VIII. CONCLUSION .............................................................................................56
`
`B.
`
`C.
`
`D.
`
`E.
`
`i
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`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`PETITIONER’S EXHIBIT LIST
`Description
`
`U.S. Patent No. 6,755,547
`Prosecution History of U.S. Patent No. 6,755,547
`Complaints filed in Related District Court Cases
`Declaration of Michael J. Escuti, Ph.D. (“Escuti Decl.”)
`U.S. Patent No. 5,461,547 (“Ciupke”)
`U.S. Patent No. 5,005,108 (“Pristash”)
`U.S. Patent No. 4,729,068 (“Ohe”)
`U.S. Patent No. 5,598,280 (“Nishio”)
`U.S. Patent No. 5,408,388 (“Kobayashi”)
`U.S. Patent No. 5,386,347 (“Matsumoto”)
`U.S. Patent No. 5,160,195 (“Miller”)
`J. A. Castellano, Handbook of Display Technology, Academic Press Inc., San
`Diego, 1992, at pp. 9-13 and Ch. 8
`U.S. Patent No. 5,384,658 (“Ohtake”)
`U.S. Patent No. 5,303,322 (“Winston”)
`U.S. Patent No. 5,050,946 (“Hathaway”)
`EP500960 (“Ohe”)
`U.S. Patent No. 5,828,488 (“Ouderkirk”)
`3M product brochure 75-0500-0403-7, “Brightness Enhancement Film
`(BEF)”, 2 pages (1993)
`U.S. Patent No. 5,706,134 (“Konno”)
`U.S. Patent No. 5,944,405 (“Takeuchi”)
`U.S. Patent No. 5,381,309 (“Borchardt”)
`
`Exhibit #
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
`1009
`1010
`1011
`1012
`
`1013
`1014
`1015
`1016
`1017
`1018
`
`1019
`1020
`1021
`
`ii
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`Pursuant to 35 U.S.C. §311, Petitioner hereby respectfully requests inter partes
`
`review of claims 1-4, 16, and 26 of Ex. 1001, U.S. Patent No. 6,755,547 (“the ’547
`
`Patent”) which issued on June 29, 2004. The challenged claims are unpatentable
`
`under 35 U.S.C. §§102 and 103 over the prior art publications identified and applied
`
`in this Petition.
`
`I.
`
`MANDATORY NOTICES
`Pursuant to 37 C.F.R. §42.8, Petitioner provides the following mandatory
`
`disclosures:
`
`A. Real Parties-In-Interest. LG Display America, Inc. is a real party-in-interest
`
`with Petitioner, LG Display Co., Ltd.
`
`B. Related Matters. Pursuant to 37 C.F.R. §42.8(b)(2), Petitioner submits that
`
`the ’547 Patent is the subject of a patent infringement lawsuit brought by the Patent
`
`Owner, Innovative Display Technologies LLC (see Ex. 1003), against Petitioner in the
`
`United States District Court for the District of Delaware: Delaware Display Group LLC
`
`and Innovative Display Technologies LLC v. LG Electronics, Inc., LG Electronics U.S.A., Inc.,
`
`LG Display Co., Ltd., and LG Display America, Inc., Case No. 1:13-cv-02109. The ’547
`
`Patent is also asserted in at least the actions listed in the chart below.
`
`Description
`Innovative Display Technologies LLC (“IDT”) v. Acer Inc.
`et al.
`IDT v. American Honda Motor Co., et. al.
`IDT v. Apple Inc.
`
`Docket Number
`2:13-cv-522, EDTX
`
`2:14-cv-00222, EDTX
`2:14-cv-00030, EDTX
`
`1
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`Description
`IDT v. Apple Inc.
`IDT v. AT&T Inc., et. al.
`IDT v. Best Buy Co., Inc., et. al.
`IDT v. BMW of North America, LLC, et. al.
`IDT v. Canon U.S.A. Inc., et. al.
`IDT v. Research in Motion Limited et al.
`IDT v. Dell Inc.
`IDT v. Ford Motor Company
`IDT v. General Motors Company
`IDT v. Google Inc., et. al.
`IDT v. Hewlett-Packard Corporation
`IDT v. Huawei Investment, et al.
`IDT v. Hyundai Motor Group, et al.
`IDT v. Mazda Motor Corporation, et al.
`IDT v. Mercedes-Benz U.S. International, et al.
`IDT v. Microsoft Corporation
`IDT v. Nikon Inc., et. al.
`IDT v. Nissan Motor, Co., Ltd., et. al.
`IDT v. Nokia Corporation and Nokia Inc.
`IDT v. Sprint Corporation, et. al.
`IDT v. T-Mobile US, Inc., et. al.
`IDT v. Toyota Motor Corporation, et. al.
`IDT v. Verizon Communications, Inc., et. al.
`IDT v. Volkswagen Ag., et. al.
`IDT v. ZTE Corporation and ZTE (USA) Inc.
`Delaware Display Group LLC (“DDG”) and IDT v.
`Amazon.com, Inc.
`DDG and IDT v. HTC Corporation et al.
`
`Docket Number
`2:14-cv-00301, EDTX
`2:14-cv-00720, EDTX
`2:14-cv-00532, EDTX
`2:14-cv-00106, EDTX
`2:14-cv-00142, EDTX
`2:13-cv-00526, EDTX
`2:13-cv-00523, EDTX
`1:14-cv-00849, D. Del
`1:14-cv-00850, D. Del.
`2:14-cv-00302, EDTX
`2:13-cv-00524, EDTX
`2:13-cv-00525, EDTX
`2:14-cv-00201, EDTX
`2:14-cv-00624, EDTX
`2:14-cv-00535, EDTX
`2:13-cv-00783, EDTX
`2:14-cv-00145, EDTX
`2:14-cv-00202, EDTX
`2:13-cv-00784, EDTX
`2:14-cv-00721, EDTX
`2:14-cv-00723, EDTX
`2:14-cv-00200, EDTX
`2:14-cv-00722, EDTX
`2:14-cv-00300, EDTX
`2:13-cv-00527, EDTX
`1:13-cv-2106, D. Del.
`
`1:13-cv-02107, D. Del.
`
`2
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`Description
`DDG and IDT v. Lenovo Group Ltd., et al.
`DDG and IDT v. LG Electronics Inc., et al.
`DDG and IDT v. Pantech Co.,Ltd, et al.
`DDG and IDT v. Sony Corporation et al.
`DDG and IDT v. Vizio, Inc.
`
`Docket Number
`1:13-cv-02108, D. Del.
`1:13-cv-02109, D. Del.
`1:13-cv-02110, D. Del.
`1:13-cv-02111, D. Del.
`1:13-cv-02112, D. Del.
`
`Petitioner has previously filed petitions to review U.S. Patent Nos. 7,300,194
`
`(IPR2014-01097), 7,434,974 (IPR2014-01092), 7,404,660 (IPR2014-01094), 7,537,370
`
`(IPR2014-01096), and 8,215,816 (IPR2014-01095), which are in the same family as the
`
`’547 Patent. Petitioner is concurrently filing a petition to review U.S. Patent No.
`
`7,384,177, also in the same family, and a petition to review U.S. Patent No. 7,914,196.
`
`The ’547 Patent is a divisional of U.S. Patent No. 6,712,481, which is continuation in
`
`part of U.S. Patent No. 6,079,838, which is a divisional of U.S. Patent No. 5,613,751.
`
`C. Lead and Back-up Counsel.
`
`Petitioner provides the following designation of counsel:
`
`LEAD COUNSEL
`Robert G. Pluta
`Registration No. 50,970
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8641
`Facsimile:
`312-701-7711
`rpluta@mayerbrown.com
`
`BACK-UP COUNSEL
`Amanda K. Streff
`Registration No. 65,224
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8645
`Facsimile:
`312-701-7711
`astreff@mayerbrown.com
`
`Baldine B. Paul
`Registration No. 54,369
`
`3
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`Anita Y. Lam
`Registration No. 67,394
`MAYER BROWN LLP
`1999 K Street, N.W.
`Washington, DC 20006
`Telephone: 202-263-3000
`Facsimile:
`202-263-3300
`bpaul@mayerbrown.com
`alam@mayerbrown.com
`
`D. Service Information. Pursuant to 37 C.F.R. §42.8(b)(4), Petitioner identifies
`
`the following service information: Please direct all correspondence regarding this
`
`proceeding to lead counsel at the address identified above. Petitioner consents to
`
`electronic service by email:
`
`rpluta@mayerbrown.com, bpaul@mayerbrown.com,
`
`astreff@mayerbrown.com, and alam@mayerbrown.com, with a courtesy copy to
`
`DDGIPR@mayerbrown.com.
`
`II.
`
`PAYMENT OF FEES
`
`Pursuant to 37 C.F.R. §42.103, $23,000 is being paid at the time of filing this
`
`petition, charged to Deposit Account 130019. Should any further fees be required by
`
`the present Petition, the Patent Trial and Appeal Board (“the Board”) is hereby
`
`authorized to charge the above referenced Deposit Account.
`
`III.
`
`STANDING
`Pursuant to 37 C.F.R. §42.104(a), Petitioner certifies that the patent sought for
`
`review, the ’547 Patent, is available for inter partes review and that Petitioner is not
`
`barred or estopped from requesting an inter partes review of the patent.
`
`4
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`IV. REQUEST FOR INTERPARTESREVIEW OF CLAIMS 1-4, 16, AND
`26 OF THE ’547 PATENT
`
`Pursuant to 37 C.F.R. §42.104(b), Petitioner requests that the Board find
`
`unpatentable claims 1-4, 16, and 26 of the ’547 Patent. Such relief is justified as the
`
`alleged invention of the ’547 Patent was described by others prior to the effective
`
`filing date of the ’547 Patent.
`
`Technology Background
`A.
`Generally, light emitting panel assemblies are used in conjunction with liquid
`
`crystal displays (“LCDs”) and various applications thereof, as a backlight module to
`
`provide light to the display. Ex. 1004, Declaration of Michael J. Escuti, Ph.D. (“Escuti
`
`Decl.”), ¶38. The light emitting panel assembly is composed of all the elements of the
`
`LCD other than the liquid crystals themselves. Id. For example, the light emitting
`
`panel assembly is all but element 12 (in yellow) in the annotated figure below from
`
`Ex. 1005, U.S. Patent No. 5,461,547 (“Ciupke”).
`
`In order to produce surface illumination with the target brightness and
`
`uniformity at the lowest possible electrical power, the light emitting panel assembly
`
`can include features to spatially homogenize and control the angular distribution of
`
`emitted light. Escuti Decl., ¶42. Examples of these features include light pipes, a
`
`5
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`transition area, reflectors, and various types of microstructured deformities (e.g.,
`
`microprisms, diffusers, and microlenses). Id. ¶43. The light pipe, also sometimes
`
`called a light guide or wave guide, accepts light injected from the side and distributes it
`
`across the emission area. The ’547 Patent calls the light pipe a “transparent panel
`
`member” (e.g., Ex. 1001, 1:16-17), “light emitting panel member” (e.g., id. 1:33-31), and
`
`“transparent light emitting panel” (e.g., id. 2:65). See Escuti Decl., ¶43. The transition
`
`area, which is usually between the light source and the light pipe, is used to securely
`
`position the light source relative to the light pipe, and to spread and transmit light to
`
`produce a more uniform input illumination. Id. ¶44. The ’547 Patent refers to a “light
`
`transition member or area” that enables emitted light “to make the transition from the
`
`light source 3 to the light emitting panel 2” and was “well known in the art.” See Ex.
`
`1001, 2:67-3:2. Deformities, such as microprisms, diffusers, and microlenses, are
`
`employed to control the direction and spatial uniformity of light within light emitting
`
`panel assemblies. Escuti Decl., ¶45-49.
`
`The Alleged Invention Of The ’547 Patent
`B.
`The ’547 Patent relates “to light emitting panel assemblies each including a
`
`transparent panel member for efficiently conducting light, and controlling the light
`
`conducted by the panel member to be emitted from one or more light output areas
`
`along the length thereof.” Ex. 1001, 1:15-19. As the ’547 Patent acknowledges,
`
`“[l]ight emitting panel assemblies are generally known.” Id. 1:20. The purported
`
`6
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`advantage of the alleged invention described in the ’547 Patent relates to several
`
`different light emitting panel assembly configurations which allegedly provide for
`
`better control of light output from the panel assembly and for more “efficient”
`
`utilization of light, thereby resulting in greater light output from the panel assembly.
`
`Id. 1:21-25. Yet, as shown further below, prior art such as Ex. 1006, U.S. Patent No.
`
`5,005,108 (“Pristash”) already disclosed such advantages. See, e.g., Ex. 1006, 1:10-16.
`
`The ’547 Patent discloses light emitting assemblies having a sheet, film, or plate
`
`having pattern of light extracting deformities on or in one or both sides and overlying
`
`the panel member. Ex. 1001, Abstract; see also Escuti Decl., ¶¶52-53. The pattern of
`
`light extracting deformities may vary in size, shape, density or placement for
`
`controlling the light output distribution for a particular application. Id.; see also Escuti
`
`Decl., ¶¶52-53.
`
`V.
`
`CLAIM CONSTRUCTION
`A.
`Standards For Claim Construction
`to inter partes review is given its “broadest reasonable
`
`A claim subject
`
`construction in light of the specification of the patent in which it appears.” 37 C.F.R.
`
`§42.100(b). This means that the words of the claim are given their plain meaning
`
`from the perspective of one of ordinary skill
`
`in the art unless that meaning is
`
`inconsistent with the specification.
`
`In re Zletz, 893 F.2d 319, 321 (Fed. Cir. 1989).
`
`Petitioner submits, for the purposes of inter partes review only, that the claim terms are
`
`presumed to take on their broadest reasonable interpretation in light of
`7
`
`the
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`specification of the ’547 Patent.
`
`“deformities” (Claims 1-4, 16, 26)
`B.
`The ’547 Patent expressly defines the term “deformities” as follows: “As used
`
`herein, the term deformities or disruptions are used interchangeably to mean any
`
`change in the shape or geometry of the panel surface and/or coating or surface
`
`treatment that causes a portion of the light to be emitted.” Ex. 1001, 4:42-46. Thus,
`
`based on the express definition of deformities in the specification, “deformities”
`
`(claims 1-4, 16, 26) should be construed to mean “any change in the shape or
`
`geometry of a surface and/or coating or surface treatment that causes a portion of the
`
`light to be emitted.” Escuti Decl., ¶67.
`
`VI.
`
`SUMMARY OF PRIOR ART TO THE ’547 PATENT FORMING THE
`BASIS FOR THIS PETITION
`A.
`Admitted Prior Art
`
`The ’547 Patent discusses the following functionality and structure of prior art
`
`light emitting assemblies:
`
`(1) a “transparent light emitting panel 2,” (2) “one or more
`
`light sources 3 which emit light in a predetermined pattern,” and (3) “a light transition
`
`member or area 4 used to make the transition from the light source 3 to the light
`
`emitting panel.”
`
`Ex. 1001, 2:62-3:2 (describing these elements and their
`
`functionalities as being “well known in the art”).
`
`U.S. Patent No. 4,729,068 (“Ohe”) (Ex. 1007)
`A.
`Ohe discloses a light diffusing device for illuminating a large display surface
`
`8
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`with a uniform brightness. Ex. 1007, 2:31-33. The objective of Ohe was to increase
`
`the uniformity of the brightness though the entire front surface of the device.
`
`Id.
`
`2:26-28. Ohe qualifies as prior art under 35 U.S.C. §102(b) because it issued as a
`
`patent on March 1, 1988, more than one year before the June 27, 1995 priority date to
`
`which the ’547 Patent may be entitled. Ohe was not cited or considered during
`
`prosecution of the application that led to the ’547 Patent.
`
`U.S. Patent No. 5,598,280 (“Nishio”) (Ex. 1008)
`B.
`Nishio discloses a film lens and a surface light source adopted for backlighting
`
`a display unit, such as a liquid crystal display. Ex. 1008, 1:7-10. Nishio qualifies as
`
`prior art under 35 U.S.C. §102(e) because Nishio was filed on March 22, 1994, before
`
`the June 27, 1995 priority date to which the ’547 Patent may be entitled. Nishio was
`
`not cited or considered during prosecution of the application that led to the ’547
`
`Patent.
`
`C.
`
`U.S. Patent No. 5,005,108 (“Pristash”) (Ex. 1006)
`
`Pristash discloses a thin panel illuminator for more efficient light transmission
`
`from the light source to the light emitting panel. Ex. 1006, Abstract. Pristash
`
`qualifies as prior art under 35 U.S.C. §102(b) because Pristash issued as a patent on
`
`April 2, 1991, more than one year before the June 27, 1995 priority date to which the
`
`’547 Patent may be entitled. Pristash was cited as a reference in an Information
`
`Disclosure Statement during prosecution, but was not relied upon as the basis to
`
`reject any claim. In fact, Pristash was not discussed on the record at all during the
`9
`
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`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`prosecution proceedings.
`
`D.
`
`U.S. Patent No. 5,408,388 (“Kobayashi”) (Ex. 1009)
`
`Kobayashi discloses a planar illuminating device having “increased illuminance”
`
`and an “increased uniformity in surface illumination.” Ex. 1009, 2:14-16, 2:59-61.
`
`Kobayashi qualifies as prior art under 35 U.S.C. §102(a) because Kobayashi was issued
`
`as a patent on April 18, 1995, before the June 27, 1995 priority date to which the ’547
`
`Patent may be entitled. Kobayashi was not cited or considered during prosecution of
`
`the application that led to the ’547 Patent.
`
`U.S. Patent No. 5,386,347 (“Matsumoto”) (Ex. 1010)
`E.
`Matsumoto discloses an illuminating apparatus within which an edge light
`
`conductor is used. Ex. 1010, Title. Matsumoto qualifies as prior art under 35 U.S.C.
`
`§ 102(a) because Matsumoto issued as a patent on January 31, 1995, before the June
`
`27, 1995 priority date to which the ’547 patent may be entitled. Mastumoto was not
`
`cited or considered during prosecution of the application that led to the ’547 Patent.
`
`VII. GROUNDS FOR UNPATENTABILITY OF EACH CLAIM
`
`In light of the disclosures detailed below, the ’547 Patent is unpatentable for at
`
`least the reasons summarized in the chart below and discussed in more detail herein.
`
`Ground # Ground
`1
`102(b)
`2
`102(e)
`3
`103(a)
`4
`103(a)
`5
`103(a)
`
`Prior art
`Ohe
`Nishio
`Pristash
`Kobayashi and Ohe
`Pristash and
`
`Exhibit(s) #
`Ex. 1007
`Ex. 1008
`Ex. 1006
`Ex. 1009 and Ex. 1007
`Ex. 1006 and Ex. 1010
`
`Claims
`1-4, 26
`1, 3, 4, 16
`1-4, 16, 26
`1-4, 16, 26
`1-4, 26
`
`10
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`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`A.
`
`Matsumoto
`Ground 1: Claims 1-4 and 26 are Unpatentable Under 35 U.S.C.
`§102 as Anticipated by Ohe
`Ohe discloses a light diffusing device for illuminating a large display surface
`
`with a uniform brightness. Ex. 1007, 2:31-33. According to Ohe, a problem existed in
`
`that a brightness at a location close to the light source edge was different from another
`
`location far from the light source edge. Id. 2:20-26. The objective of Ohe was to
`
`increase the uniformity of the brightness though the entire front surface of the device.
`
`Id. 2:26-28. To solve this problem, Ohe discloses an overlying light reflecting film 7
`
`consisting of a transparent substrate film and a number of light reflecting spots or
`
`small places formed on the substrate in a pattern for evenly distributing the quantity of
`
`transmitted light from base plate 1 to the light diffusing plate 6 (shown in purple in
`
`annotated Fig. 2 below).
`
`Id. 3:47-52; see also 5:51-55. Figure 4 below depicts light
`
`reflecting spots 7b, having a decreasing density with an increased distance from light
`
`sources B and C. Id. 6:16-19. The pattern of light reflecting spots is not limited to that
`
`shown in Figure 4 and may vary in size and density. Id. 6:54-61.
`
`11
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`Ohe discloses a light reflecting film 7 overlying a light emitting surface with
`
`small, varying deformities, as required by claim 1. Ex. 1007, 3:47-52. Ohe also
`
`discloses deformities varying in size, shape, and placement, or have random or varying
`
`changes in shape or geometry, as required by claims 2-4 and 26. See Escuti Decl.,
`
`¶¶80-83. According to Ohe, deformities on overlying film, light reflecting film 7, may
`
`vary in “size, configuration, and distribution density.” Ex. 1007, 6:3-9.
`
`In light of the above, the table below demonstrates how each limitation of
`
`claims 1-4 and 26 of the ’547 Patent is disclosed by Ohe. For all these reasons, claims
`
`1-4 and 26 are unpatentable over Ohe and thus, Petitioner has a reasonable likelihood
`
`of prevailing with respect to at least one claim.
`
`’547 Claim Element
`1. A backlight assembly
`comprising
`
`emitting
`light
`a
`[1.a]
`member having at least
`one light emitting area
`that emits light
`that
`is
`internally
`reflected
`within the light emitting
`member,
`
`Ohe (Ex. 1007)
`“The present invention relates to a light diffusing device.
`Particularly, the present invention relates to an improved
`light diffusing device useful
`for every illuminating a
`relatively large area at a significantly reduced optical loss.”
`Ex. 1007, 1:6-10.
`See Escuti Decl., ¶75
`“Referring to FIG. 1, the base plate 1 has a pair of light
`incident edge faces facing and exposed to light sources
`(for instance, fluorescent
`lamps) B and C which are
`provided with reflectors D and E, respectively.” Ex. 1007,
`4:4-8.
`“In the embodiment of the light diffusing device indicated
`in FIG. 1, the base plate 1 the light reflecting film 7, and
`the
`light diffusing plate 6 have
`rectangular plane
`configurations similar in shape and dimensions to each
`other.” Id. 3:66-4:2; see also Fig. 1 below.
`
`12
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`’547 Claim Element
`
`Ohe (Ex. 1007)
`
`separate
`a
`[1.b]
`transparent sheet or film
`overlying
`the
`light
`emitting area with an air
`gap therebetween,
`
`“Referring to FIGS. 1, 2 and 4, when the light sources
`(fluorescent lamp) B and C are lit, the irradiated light is
`introduced into the transparent light transmitting layer 2
`through the light incident edge face thereof facing the light
`sources. The introduced light, portions of which are
`reflected by the light reflecting surface layer 5 and by the
`light reflecting edge face layer 8 and returned into the
`transparent light transmitting layer 2, are transmitted to
`the light diffusing layer 3 through the intermediate layer 4.
`The light is diffused by the light diffusing layer 3 and is
`irradiated to the light diffusing plate 6 through the light
`reflecting film 7.” Id. 8:4-15.
`See Escuti Decl., ¶¶76-78.
`“In the embodiment of the light diffusing device indicated
`in FIG. 1, the base plate 1 the light reflecting film 7, and
`the
`light diffusing plate 6 have
`rectangular plane
`configurations similar in shape and dimensions to each
`other.” Ex. 1007, 3:66-4:2; see also Fig. 1 above.
`“This light reflecting film 7 consists of a transparent
`substrate film and a number of light reflecting small spots
`or small places formed on the transparent substrate film in
`a pattern effective for evenly distributing the quantity of
`light
`transmitted from the base plate 1 to the light
`diffusing plate 6. The light reflecting film 7 is not forced
`into close contact or adhesion with the light diffusing plate
`6 and the light diffusing layer 3 in the base plate 1. That is,
`the light reflecting film 7 is spaced from the light diffusing
`plate 6 by a very thin gap and from the light diffusing layer
`3 also by a very thin gap. These very thin gaps form very
`
`13
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`’547 Claim Element
`
`of
`pattern
`a
`[1.c]
`deformities on one side
`of
`the
`sheet or
`film
`having
`a width
`and
`length that is quite small
`in relation to the width
`and length of the sheet
`or film,
`
`Ohe (Ex. 1007)
`thin air layers.” Id. 3:47-59.
`See Escuti Decl., ¶79.
`“A light reflecting film 7 is interposed between the light
`diffusing plate 6 and the light diffusing layer 3. This light
`reflecting film 7 consists of a transparent substrate film
`and a number of light reflecting small spots or small places
`formed on the transparent substrate film in a pattern
`effective for evenly distributing the quantity of
`light
`transmitted from the base plate 1 to the light diffusing
`plate 6. ” Ex. 1007, 3:45-52.
`“Usually, the light reflecting film comprises a transparent
`film substrate and a number of light reflecting small spots
`or small places formed on the film substrate. The size,
`configuration,
`and distribution density of
`the light
`reflecting spots are designed so that
`they cause the
`distribution of light transmitted through the light reflecting
`film to be uniform.” Id. 6:3-9.
`
`the
`
`deformities
`[1.d]
`different
`at
`varying
`locations on the sheet or
`film to direct
`the light
`that
`is emitted by the,
`light emitting member in
`different directions
`to
`produce a desired light
`output distribution such
`that
`the light will pass
`
`Id. Fig. 4.
`See Escuti Decl., ¶¶80-82.
`“A light reflecting film 7 is interposed between the light
`diffusing plate 6 and the light diffusing layer 3. This light
`reflecting film 7 consists of a transparent substrate film
`and a number of light reflecting small spots or small places
`formed on the transparent substrate film in a pattern
`effective for evenly distributing the quantity of
`light
`transmitted from the base plate 1 to the light diffusing
`plate 6. ” Ex. 1007, 3:45-52.
`“Referring to FIG. 4, the size (area) and the distribution
`
`14
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`’547 Claim Element
`through a liquid crystal
`display with low loss.
`
`Ohe (Ex. 1007)
`density of the light reflecting spots 7b decreases with an
`increase in the distance from the light source B or C. A
`total area of the spots in the light reflecting film 7 in the
`above-mentioned end portions thereof
`increases with
`decrease in the distance from the light source B or C. In
`the middle portion of the light reflecting film, the light
`reflecting spots are not arranged on the transparent film
`substrate.” Id. 6:15-23.
`“Usually, the light reflecting film comprises a transparent
`film substrate and a number of light reflecting small spots
`or small places formed on the film substrate. The size,
`configuration,
`and distribution density of
`the light
`reflecting spots are designed so that
`they cause the
`distribution of light transmitted through the light reflecting
`film to be uniform.” Id. 6:3-9.
`
`Id., Fig. 4.
`“Referring to FIGS. 1, 2 and 4, when the light sources
`(fluorescent lamp) B and C are lit, the irradiated light is
`introduced into the transparent light transmitting layer 2
`through the light incident edge face thereof facing the light
`sources. The introduced light, portions of which are
`reflected by the light reflecting surface layer 5 and by the
`light reflecting edge face layer 8 and returned into the
`transparent light transmitting layer 2, are transmitted to
`the light diffusing layer 3 through the intermediate layer 4.
`The light is diffused by the light diffusing layer 3 and is
`irradiated to the light diffusing plate 6 through the light
`reflecting film 7.” Id. 8:4-15.
`“The light diffusing device of
`
`the present
`
`invention
`
`15
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`’547 Claim Element
`
`The assembly of
`2.
`claim 1 wherein the
`deformities vary in size
`at different locations on
`the
`sheet or
`film to
`direct
`the
`light
`in
`different directions.
`
`The assembly of
`3.
`claim 1 wherein the
`deformities vary in shape
`at different locations on
`the
`sheet or
`film to
`direct
`the
`light
`in
`different directions.
`
`Ohe (Ex. 1007)
`provides a highly uniform illumination with evenly
`scattered light at a reduced optical loss. That is, the light
`diffusing device of the present invention is extremely
`useful for a large size display system.” Id. 8:31-35.
`“Another object of the present invention is to provide a
`light diffusing device having a significantly decreased
`optical loss.” Id. 2:34-36.
`See Escuti Decl., ¶¶83-85.
`“A light reflecting film 7 is interposed between the light
`diffusing plate 6 and the light diffusing layer 3. This light
`reflecting film 7 consists of a transparent substrate film
`and a number of light reflecting small spots or small places
`formed on the transparent substrate film in a pattern
`effective for evenly distributing the quantity of
`light
`transmitted from the base plate 1 to the light diffusing
`plate 6. ” Ex. 1007, 3:45-52.
`“Usually, the light reflecting film comprises a transparent
`film substrate and a number of light reflecting small spots
`or small places formed on the film substrate. The size,
`configuration,
`and distribution density of
`the light
`reflecting spots are designed so that
`they cause the
`distribution of light transmitted through the light reflecting
`film to be uniform.” Id. 6:3-9; see also Fig. 4 above.
`“The size of the light reflecting spots may vary with the
`distance from the light source, as shown in FIG. 5. Also,
`the light reflecting spots having the same size may be
`distributed at a different distribution density on the
`transparent film substrate.” Id. 4:56-61.
`See Escuti Decl., ¶¶87-90.
`“A light reflecting film 7 is interposed between the light
`diffusing plate 6 and the light diffusing layer 3. This light
`reflecting film 7 consists of a transparent substrate film
`and a number of light reflecting small spots or small places
`formed on the transparent substrate film in a pattern
`effective for evenly distributing the quantity of
`light
`transmitted from the base plate 1 to the light diffusing
`
`16
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`’547 Claim Element
`
`The assembly of
`4.
`claim 1 wherein the
`deformities
`vary
`in
`placement
`at different
`locations on the sheet or
`film to direct the light in
`different directions.
`
`The assembly of
`26.
`claim 1 wherein at least
`
`Ohe (Ex. 1007)
`plate 6. ” Ex. 1007, 3:45-52.
`“Usually, the light reflecting film comprises a transparent
`film substrate and a number of light reflecting small spots
`or small places formed on the film substrate. The size,
`configuration,
`and distribution density of
`the light
`reflecting spots are designed so that
`they cause the
`distribution of light transmitted through the light reflecting
`film to be uniform.” Id. 6:3-9; see also Fig. 4 above.
`See Escuti Decl., ¶¶92-94.
`“Usually, the light reflecting film comprises a transparent
`film substrate and a number of light reflecting small spots
`or small places formed on the film substrate. The size,
`configuration,
`and distribution density of
`the light
`reflecting spots are designed so that
`they cause the
`distribution of light transmitted through the light reflecting
`film to be uniform.” Ex. 1007, 6:3-9.
`“Referring to FIG. 4, the size (area) and the distribution
`density of the light reflecting spots 7b decreases with an
`increase in the distance from the light source B or C. A
`total area of the spots in the light reflecting film 7 in the
`above-mentioned end portions thereof
`increases with
`decrease in the distance from the light source B or C. In
`the middle portion of the light reflecting film, the light
`reflecting spots are not arranged on the transparent film
`substrate.” Id. 6:15-23; see also Fig. 4 above.
`“In this case, the density of the light reflecting spots
`decreases with an increase in the distance from the single
`light source.” Id. 6:38-40.
`“The size of the light reflecting spots may vary with the
`distance from the light source, as shown in FIG. 5. Also,
`the light reflecting spots having the same size may be
`distributed at a different distribution density on the
`transparent film substrate.” Id. 4:56-61.
`See Escuti Decl., ¶¶96-100.
`“A light reflecting film 7 is interposed between the light
`diffusing plate 6 and the light diffusing layer 3. This light
`17
`
`

`

`Patent No. 6,755,547
`Petition for Inter Partes Review
`
`’547 Claim Element
`some of the deformities
`have random or varying
`changes
`in shape or
`geometry on the sheet or
`film to direct the light

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