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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`SHARP CORPORATION, SHARP ELECTRONICS CORPORATION, and
`SHARP ELECTRONICS MANUFACTURING
`COMPANY OF AMERICA, INC.,
`Petitioners
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`v.
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`SURPASS TECH INNOVATION LLC
`Patent Owner
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`_______________
`
`Case IPR2015-00021
`Patent 7,202,843
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`_______________
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`DECLARATION OF WILLIAM K. BOHANNON
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`I, William K. Bohannon, hereby declare as follows:
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`I have been retained by Patent Owner Surpass Tech Innovation LLC to
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`provide my opinions in support of its Response to the Petition for Inter Partes
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`Review of Patent No. 7,202,843 (the ‘843 patent). I am being compensated for my
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`time at the rate of $250 per hour. I have no interest in the outcome of this
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`proceeding.
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`I. BACKGROUND AND QUALIFICATIONS
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`1.
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`I am currently employed as an independent electronics and display
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`technologies expert and consultant. My background and qualifications are set forth
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`in my curriculum vitae, attached as Appendix A.
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`2.
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`As set forth in my curriculum vitae, I have a Bachelor of Science in
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`Mathematics, graduate work in mathematics, physics, and computer science, and
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`over thirty years of professional experience in the areas of displays and electronics.
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`3.
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`During this time, I have worked as a consultant, as an expert, as a
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`named inventor on seven patents, and as a company founder and executive.
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`Specific display technologies that I have worked with include all aspects of LCD
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`projector design, LCD control electronics including various LCD drive electronics
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`circuits, and testing equipment for LCD drive electronics and display performance.
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`I have invented and designed LCD projection systems and their associated control
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`electronics and in addition I have worked with various LC device and component
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`manufacturers to develop custom LCD components.
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`4. My experience includes decades of electronics and display product
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`development. It also includes consulting and providing expert experience in many
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`aspects of the display electronics field. I have experience as a design engineer,
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`systems architect, principal engineer, project manager, and company executive, as
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`well as experience in reverse engineering.
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`5.
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`I have many years of experience in designing, developing,
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`manufacturing and testing electronic display systems. As an independent
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`consultant and analyst, I also acquired, analyzed, tested and then published the test
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`results for over one hundred different display systems produced by major
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`electronics manufacturers. The company I helped to found, Planet ATE,
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`developed many unique electronic test technologies that were used by major,
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`worldwide electronics companies to test various electronics circuits including LCD
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`drivers.
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`6. My additional experience is listed in my curriculum vitae, attached as
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`an Appendix to this declaration.
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`II. MATERIALS CONSIDERED
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`7.
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`In forming my opinions, in addition to my knowledge and experience,
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`I have considered the following documents and things that I have obtained, or that
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`have been provided to me, as well as any other references cited herein that may not
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`be listed below:
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`U.S. Patent No. 7,202,843 to Shen et al., (Ex. 1001) along with aspects of its
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`prosecution history before the U.S. Patent & Trademark Office (Ex. 1006)
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`U.S. Patent Application Publication No. 2004/0196229 to Ham (Ex. 1005)
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`The Petition for Inter Partes Review filed by the Sharp Petitioners against
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`the ‘843 patent (IPR2015-00021)
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`III. THE PERSON OF ORDINARY SKILL IN THE ART AND
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`LEGAL STANDARD IN INTER PARTES REVIEW
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`8.
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`The ‘843 patent relates to methods and circuitry for driving an LCD
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`panel. I understand that the factors considered in determining the level of ordinary
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`skill in the art include education and experience of persons working in the art, and
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`the types of problems encountered in the art. Based on these factors, in my opinion,
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`a person of ordinary skill in the relevant art of the ‘843 patent has at least a
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`bachelor’s degree in electrical engineering, mathematics, or computer science with
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`two or more years of experience in designing electronics and displays. For
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`example, a person of ordinary skill in the art would have education and experience
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`sufficient to understand both the disclosures of Ham and the background of the
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`‘843 patent’s specification. This includes the ability to understand the overdriving
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`concept as it is discussed in the ‘843 patent. I would expect this background to
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`include experience in LCD control electronics. A person having this background
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`would understand factors associated with driving electronic impulses, and would
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`also understand the concepts of pixel voltage versus light transmission and pixel
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`response time.
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`9. My opinions contained in this declaration are given from the
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`perspective of a person of ordinary skill in the art at the time of the November 17,
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`2003 filing of the Taiwanese application No. 92132122 A upon which the ‘843
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`patent is based, unless specifically stated, even if my opinion is expressed in the
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`present tense. As of November 17, 2003, I satisfied the standard of a person of
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`ordinary skill in the art described above in ¶8.
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`10.
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`In an inter partes review (IPR) proceeding before the Patent Trial and
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`Appeal Board, I understand that a petitioner has the burden to prove patent
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`invalidity by a “preponderance of the evidence” standard. I have evaluated the
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`Sharp Petition in this case and reach my opinions below according to that burden
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`of proof. I also understand that from the Board’s perspective, attorney argument
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`does not constitute evidence for satisfying this burden.
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`IV. THE ‘843 PATENT
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`11.
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`I have reviewed Patent No. 7,202,843 (the ‘843 patent) entitled
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`“Driving Circuit of a Liquid Crystal Display Panel and Related Driving Method.”
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`The ‘843 patent describes both the background technology of blurring in a liquid
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`crystal display (LCD) panel due to slow response time of the liquid crystal (LC)
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`molecules, and a driving method developed in response to the blurring problem.
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`A. The Background of the Technology
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`12. As the ‘843 patent explains, an LCD panel includes LC molecules
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`arranged between the electrodes of the pixels. In order to display an intended
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`image on the LCD panel, a potential difference is applied across the electrodes.
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`The potential difference causes the LC molecules to twist and rearrange to allow a
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`brightness level of light, usually generated via a backlight, to pass through the LC
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`molecules. Once the potential difference is applied, the LC molecule rearranging is
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`not immediate. Time is necessary for the LC molecules in the pixel to complete
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`their rearranging and for the pixel to generate the intended brightness level of light.
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`Further, where the LC molecule rearrangement cannot be completed within a target
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`frame period, the ‘843 patent explains that “blurring” may occur. [‘843 patent, col.
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`1, lines 1-2]. This concept is explained in the Background of the ‘843 patent, and I
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`agree with the way in which that concept is explained there.
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`13. The ‘843 patent also describes the concept of overdriving.
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`Specifically, according to the ‘843 patent, a way to reduce the risk of blurring is
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`overdriving, “which means applying a higher or a lower data impulse to the pixel
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`electrode to accelerate the speed of the liquid crystal molecules,” and may allow
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`the pixel to reach a predetermined gray level in a predetermined frame period.
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`[‘843 patent, col. 2, lines 3-7]. Figure 2 of the ‘843 patent is described as “a timing
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`diagram of different transmission rates of a pixel, varying in accordance with the
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`frames.” [‘843 patent, col. 1, lines 53-55]. “The curve C1 shows the transmission
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`rate of a pixel not overdriven corresponding to the frames, and the curve C2 shows
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`the transmission rate of the pixel overdriven corresponding to the frames.” [‘843
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`patent, column 1, lines 57-60]. However, even curve C2 does not reach the target
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`transmission rate of T2 until frame N+1. Therefore, the ‘843 patent seeks a further
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`improvement on overdriving. [‘843 patent, col. 2, lines 7-12].
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`B. The ‘843 Patent’s Disclosure
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`14. The main focus of the ‘843 patent is controlling the transmission rate
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`of the LC molecules in a pixel by applying at least two data impulses based on
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`overdriven data. The ‘843 patent includes three block diagrams of driving circuits
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`or components thereof, and each performs overdriving on the pixel data. [‘843
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`patent, Figures 3, 7 and 8]. Additionally, the ‘843 patent includes two timing
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`diagrams showing two overdriven pixel data signals applied per frame. [‘843
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`patent, Figures 5 and 10].
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`15.
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`In the block diagrams of the driving circuit 10, a blur clear converter
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`14 is included and “continuously receives the controls signals C and the frame data
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`included in the frame signals G and generates processed frame signals G including
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`a plurality of overdriven data according to the frame data.” [‘843 patent, col. 3,
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`lines 24-28]. This embodiment is shown in Fig. 3 of the ‘843 patent.
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`16. Figures 7 and 8 show first and second embodiments of the blur clear
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`converter 14 shown and described with respect to Figure 3. Figure 7’s
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`embodiment of the blur clear converter includes a processing circuit 42.
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`According to the ‘843 patent, the “processing circuit 42 generates a plurality of
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`overdriven pixel data GN according to the current pixel data Gm and the delayed
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`pixel data Gm-1.” [‘843 patent, col. 4, lines 53-55]. The overdriven pixel data are
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`identified as “overdriven pixel data GN, GN(2).” [‘843 patent, col. 4, lines 62-63].
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`Similar to the embodiment of Figure 7, the blur clear converter of Figure 8 also has
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`a processing circuit 74. This processing circuit 74 also “generates two pieces of
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`overdriven pixel data GN1, GN-1(2) for each pixel 36 in every frame period
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`according to the pixel data Gm-1, Gm-2.” [‘843 patent, col. 5, lines 17-19].
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`Therefore, in these disclosed embodiments of the driving circuit 10, the ‘843 patent
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`discloses circuitry for generating two overdriven pixel data per frame.
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`17. Further, in the timing diagrams of Figures 5 and 10, it is clear that the
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`‘843 patent is describing the timing of applied overdriven pixel data. When
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`describing the output of blur clear converter according to embodiments, the ‘843
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`patent uses capitalized “N”, as in “GN,” to refer to overdriven pixel data, and uses
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`lower-case “m,” as in “Gm” or “Gm-1,” to refer to original pixel data. Examples
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`of this can be found in col. 4, lines 49-63; col. 5, lines 7-22; and col. 5, lines 28-42.
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`In both Figures 5 and 10, the ‘843 patent uses labels indicating overdriven pixel
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`data. This is consistent with Figure 5 showing the overdriven pixel data impulses
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`GN, GN(2)… from driving circuit 10, which outputs overdriven data via blur clear
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`converter 14. This is also consistent with Figure 10 showing the overdriven pixel
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`data impulses GN, GN(2)… from blur clear converter 60 of Figure 8. This is
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`expressly contrasted with Figure 9’s use of lower-case “m” indicating non-
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`overdriven (or original) pixel data. [‘843 patent, col. 5, lines 28-31].
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`18. Based on my review of the ‘843 patent’s detailed description of the
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`invention and its embodiments, the ‘843 patent uniformly correlates the idea of
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`overdriving and controlling the transmission rate of the LC molecules of a pixel.
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`19. As I noted above, the ‘843 patent describes the concept of
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`overdriving. Specifically, according to the background of the ‘843patent, a way to
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`reduce the risk of blurring is overdriving, “which means applying a higher or a
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`lower data impulse to the pixel electrode to accelerate the speed of the liquid
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`crystal molecules,” and may allow the pixel to reach a predetermined gray level in
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`a predetermined frame period. [‘843 patent, col. 2, lines 3-7]. Here, the patent’s
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`explanation of what is meant by overdriving specifically ties the application of
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`higher or lower data pulses to the speed of the LC molecules.
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`20. Another example of this correlation between overdriving voltages and
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`transmission rate comes from column 3, lines 60-62, which describes the theory
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`behind overdriving: “Different data voltages cause different twisting angles and
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`show different transmission rates.”
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`21.
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`In describing Figure 5, the ‘843 patent states that the overdriven pixel
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`data impulses GN, GN(2) from driving circuit 10, which outputs overdriven data
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`via blur clear converter 14, are applied to the LCD panel “in order to control the
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`transmission rate of the liquid crystal device 39.” [‘843 patent, col. 4, lines 13-14].
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`22. Figure 6 is described consistently with this correlation as well.
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`Driving circuit 10, which outputs overdriven data via blur clear converter 14,
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`applies data impulses to the liquid crystal device 39 “in order to control the
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`transmission rate and gray level of the pixel electrode 39.” [‘843 patent, col. 4,
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`lines 24-28].
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`23. Claim 1 of the ‘843 patent also specifically correlates the overdriven
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`pixel data and controlling a transmission rate of the liquid crystal device. [‘843
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`patent, col. 6, lines 15-21].
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`24.
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`In the Sharp Petition (IPR2015-00021), Sharp states that the ‘843
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`patent discusses and claims two techniques for improving the response time and
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`resultant image quality of LCD displays. Sharp states that one technique is
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`overdriving the signal data, and the second technique is increasing the frequency of
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`the signal data (e.g., doubling the frequency of the signal from 60 frames/second to
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`120 frames/second). This discussion occurs on page 2 of the Sharp Petition.
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`25. However, based on my review of the ‘843 patent, and based on the
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`‘843 patent’s discussion of controlling transmission rates of liquid crystal devices
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`through different data voltages, a person of ordinary skill in the art would not
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`conclude that the ‘843 patent discloses these two techniques as mutually exclusive
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`techniques, as Sharp suggests. Rather, based on the ‘843 patent’s disclosure
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`discussed in paragraphs 14-23 above, a person of ordinary skill in the art would
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`understand that the disclosed embodiments in the ‘843 patent combine both
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`overdriving and applying two overdriven pulses per frame.
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`A. CLAIM CONSTRUCTION
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`26.
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`I understand that in an Inter Partes review of an unexpired patent,
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`claim terms are given their broadest reasonable interpretation that is consistent
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`with the specification, as would be understood by a person of ordinary skill in the
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`art. The following claim constructions reflect my view of the broadest reasonable
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`interpretation of the ‘843 patent terms that are consistent with the specification, as
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`would be understood by a person of ordinary skill in the art.
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`27. Claim 4 recites that a plurality of data impulses are generated and
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`applied “to control a transmission rate of the liquid crystal device of the panel.” I
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`understand that Sharp did not put forth any evidence or testimony on the meaning
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`of this term, and instead stated that this term and the other terms of claim 4 “should
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`be given their broadest reasonable construction in light of the specification of the
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`‘843 Patent.” [Sharp Petition, page 18]. However, Sharp provided no discussion
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`of what is “reasonable” in light of the specification.
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`28. As I have explained above, the ‘843 patent correlates controlling a
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`transmission rate of a liquid crystal device of a panel with overdriving, or applying
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`higher or lower voltages. A key example of this theory is column 3, lines 60-62:
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`“Different data voltages cause different twisting angles and show different
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`transmission rates.” Specifically, the ‘843 patent states that overdriven means
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`“applying a higher or a lower data impulse to the pixel electrode to accelerate the
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`speed of the liquid crystal molecules,” and this may allow the pixel to reach the
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`predetermined gray level in a predetermined frame period. [‘843 patent, col. 2,
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`lines 3-7]. In fact, Sharp does not cite to and I am not aware of any instance or
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`embodiment in the ‘843 patent where a transmission rate is described as being
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`controlled without overdriving.
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`29. Additionally, the ‘843 patent specifically does not state that the
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`transmission rate could be controlled by applying two or more non-overdriven data
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`impulses. Though Sharp does not provide a proposed construction for any term of
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`claim 4, Sharp states that claim 4 does not require overdriving. [Sharp Petition,
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`page 17]. This statement indicates that Sharp has either completely disregarded or
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`not applied the proper construction for the term: “to control a transmission rate of
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`the liquid crystal device of the panel.” Since Sharp’s construction is not supported
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`by and is inconsistent with the ‘843 specification, it cannot constitute the broadest
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`reasonable interpretation consistent with the specification.
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`30. Consistent with the ‘843 patent specification, which discloses that
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`“[d]ifferent data voltages cause different twisting angles and show different
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`transmission rates,” a person of ordinary skill in the art would have understood that
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`the broadest reasonable interpretation of controlling the transmission rate refers to
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`applying a higher or lower voltage to a liquid crystal device, or overdriving.
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`VI. CONSIDERATION OF THE PETITION AND THE PRIOR ART
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`A. The Sharp Petition (IPR2015-00021)
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`31. As I discussed above, Sharp states that the ‘843 patent discusses and
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`claims two techniques for improving the response time an resultant image quality
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`of LCD displays. The first is overdriving the signal data, and the second is
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`increasing the frequency of the signal data (e.g., doubling the frequency of the
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`signal from 60 frames/second to 120 frames/second). This discussion occurs on
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`page 2 of the Sharp Petition.
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`32. Following from this paragraph, the Sharp Petition also draws a
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`comparison between this second technique of doubling the frequency of the signal,
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`and the driving method of claims 4, 8 and 9 of the ‘843 patent. Sharp argues that
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`claims 4-9 “do not require performing the overdrive technique.” [Sharp Petition,
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`page 17]. Sharp provides no argument or support in favor of this reading of claims
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`4-9, and appears to reach this conclusion based solely on a portion (but not all) of
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`the relevant claim language of claim 4. Specifically, Sharp states that claims 4, 8,
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`and 9 are “only directed to ‘generating a plurality of data impulses for each pixel
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`within every frame period according to the frame data.’” [Sharp Petition, page 17].
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`In this analysis, Sharp never considers the construction of “to control a
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`transmission rate of the liquid crystal device of the pixel” and its impact on the
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`scope of claim 4.
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`33.
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`I do not agree with Sharp on this characterization. As I explained
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`above, the broadest reasonable construction, consistent with the specification, of
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`claim 4’s “to control a transmission rate” phrase requires overdriving in order to be
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`consistent with the ‘843 specification. Sharp points to no embodiment of the ‘843
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`patent in which the frame rate is doubled without overdriving. For example, Sharp
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`discusses the embodiment shown in Figure 6 of the ‘843 patent and states that the
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`original frame rate is doubled “such that two overdriven data impulses are applied
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`in each single frame period (see N+1).” [Sharp Petition, p. 3]. I am not aware of,
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`and Sharp does not clearly identify, any embodiment of the ‘843 patent in which
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`the frame rate is doubled without overdriving. Therefore, to the extent that Sharp
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`believes that claim 4 covers the technique of doubling the frame rate without
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`overdriving, that belief is not supported by the Petitioner’s discussion of the ‘843
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`patent’s embodiments, and is inconsistent with the proper claim construction of
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`claim 4 according to one of ordinary skill in the art.
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`34. Further, the proper construction of claim 4 requires that the
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`“generating” and “applying” the plurality of data impulses is performed “to control
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`a transmission rate of the liquid crystal device of the pixel” by overdriving, as
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`explained above. The Sharp Petition acknowledges that Ham does not apply
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`modulated data in both subframes of a frame period. As Sharp explains on page 6
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`of the Petition, “Ham teaches applying overdriven pixel data in only the first half
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`of the frame period, and applying non-overdriven data in the second half of the
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`frame period.” I concur that Ham applies non-overdriven data in the second half of
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`the frame period. The annotated version of Ham’s Figure 7B on page 6 of the
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`Petition shows that the Normal data is applied in the second half of the frame
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`period. Even if Ham’s modulated data could be characterized as generated (which
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`Sharp never explains in a manner sufficient to carry the burden of proof),
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`generating and applying one overdriven data impulse per frame is not sufficient to
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`disclose the features recited in claim 4, which require these steps for a plurality of
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`data impulses per frame.
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`35. Therefore, I do not agree with Sharp’s theory that Ham discloses
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`“generating” and “applying” the plurality of data impulses “to control a
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`transmission rate of the liquid crystal device of the pixel.” A person of ordinary
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`skill in the art would have reached the same conclusion for the same reasons as I
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`have explained above. My understanding of the law of anticipation is that if a
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`prior art reference does not disclose every feature of a claim, as those features are
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`arranged in the claim, the prior art reference does not anticipate that claim. Thus,
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`since a person of ordinary skill in the art would agree that Ham does not apply at
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`least two overdriven data impulses per frame to control a transmission rate of the
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`liquid crystal device of the pixel, the Petition does not successfully show
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`anticipation of the ‘843 patent’s claim 4 by Ham.
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`36. Based on my review of the Sharp Petition, Sharp also claims that the
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`data modulator 52 of Ham “generates two data impulses (i.e., ‘modulated data’
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`signal and ‘normal data’ signal) for each pixel within one frame period.” This
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`quotation comes from page 46 of the Petition. Also on page 46 of Petition, Sharp
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`explains what it means by “normal data” signal: “the ‘normal data’ signal is simply
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`the actual data received by the controller (i.e., it is not overdriven).” This informs
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`me that the “normal data” signal referred to by Sharp here is what Ham refers to as
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`“normal data RGB,” which is part of the data (“Data”) received by the timing
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`controller 51 from a digital video card. Consistent with Ham, I will refer to this
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`signal as “normal data RGB” in this report. The Sharp Petition contains no other
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`theory about how Ham allegedly generates the normal data RGB.
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`37. Based on my review of Ham, there is no way for a person of ordinary
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`skill in the art to conclude that Ham’s data modulator 52 generates the normal data
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`RGB. According to Ham’s paragraph [0039], the normal data RGB is included in
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`the “Data” that is received by the timing controller 51. This is the case since the
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`timing controller 51 “rearranges digital video data supplied from a digital video
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`card (not shown).” From this rearranged digital video data, the timing controller 51
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`supplies the normal data RGB to the data modulator 52. Based on this disclosure
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`from Ham, a person of ordinary skill in the art would understand that the normal
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`data RGB is included within the digital video data supplied from a digital video
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`card. That digital video card is not shown in Ham, and is not part of Ham’s driving
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`circuit of Figure 5. Since the normal data RGB is provided from the timing
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`controller 51 to the data modulator 52, a person of ordinary skill in the art would
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`also understand that the data modulator 52 does not generate the normal data RGB.
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`38. Further, the normal data RGB provided to the data modulator 52 is
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`modulated and output as modulated data AMdata, as discussed in Ham’s paragraph
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`[0042]. The data modulator 52 does not output normal data RGB for applying to
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`the LCD panel. This is clear from Ham’s Figure 6.
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`39. The normal data RGB is also provided from the timing controller 51
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`to the line memory 59, and switch 58 sequentially supplies the modulated data
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`AMdata from data modulator 52 and the normal data RGB from line memory 59 to
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`the data driver 53 within one frame interval. [Ham, paragraphs [0041], [0044],
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`[0045]]. This flow of data reinforces that Ham’s data modulator 52 does not
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`generate normal data RGB to be applied to a liquid crystal device according to
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`claim 4. The normal data RGB to be applied to a liquid crystal device is provided
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`from timing controller 51 to line memory 59, to switch 58.
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`40. Therefore, I do not agree with Sharp’s theory that data modulator 52
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`generates the normal data RGB. A person of ordinary skill in the art would have
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`reached the same conclusion for the same reasons as I have explained above. My
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`understanding of the law of anticipation is that if a prior art reference does not
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`disclose every feature of a claim, as those features are arranged in the claim, the
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`prior art reference does not anticipate that claim. Thus, since a person of ordinary
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`skill in the art would agree that data modulator 52 does not generate the normal
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`data RGB contrary to Sharps’ allegation, the Petition does not successfully show
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`anticipation of the ‘843 patent’s claim 4 by Ham.
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`41.
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`I understand that the Patent Trial and Appeal Board has looked to
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`other portions of the Petition for Sharp’s theories on how Ham allegedly generates
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`the normal data RGB. Specifically, I understand that the Patent Trial and Appeal
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`Board has also looked to Ham’s paragraphs [0040], [0041], and [0053] for these
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`theories, based on the claim chart appearing on page 48 of the Petition. But just
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`like in the argument on page 46 of the Petition, the claim chart appearing on page
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`18
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`Exhibit 2005
`Page 18 of 29
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`48 again points to the normal data RGB as allegedly generated by Ham. As I have
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`explained above, a person of ordinary skill in the art would not interpret Ham as
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`generating the normal data RGB. The citations in Sharp’s claim chart do not
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`change that conclusion. For example, the only use of the term “generating” in
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`Ham’s paragraphs [0040], [0041], and [0053] appears in context of Ham’s gate
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`driver 54 generating a scanning pulse, which also does not generate the normal
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`data RGB. This discussion of the gate driver 54 occurs in Ham’s paragraph
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`[0040]. A scanning pulse in an LCD panel is applied to a switch in a pixel to turn
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`the pixel on or off (the pulse can be applied to the gate of a thin film transistor), but
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`aside from turning the pixel on or off, the scanning pulse does not carry pixel data
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`related to the image to be displayed by that pixel. Therefore, a person of ordinary
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`skill in the art would not characterize “generating a scanning pulse” as explained in
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`Ham’s paragraph [0040] as “generating a plurality of data impulses,” as stated in
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`claim 4 of the ‘843 patent.
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`42.
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`I have reviewed the Petition and see no explanation from Sharp on
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`which element of Ham, other than the data modulator 52, allegedly generates the
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`normal data RGB. Sharp must prove invalidity by a preponderance of the
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`evidence, but I see no theory from Sharp on the “generating” step that satisfies this
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`burden. In fact, as I have explained above, Sharp agrees that the normal data RGB
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`in Ham is included in the “Data” that is received by the timing controller 51. This
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`19
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`Exhibit 2005
`Page 19 of 29
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`is the case since according to Ham’s paragraph [0039] the timing controller 51
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`“rearranges digital video data supplied from a digital video card (not shown),” and
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`the normal data RGB is described as “rearranged by the timing controller 51” and
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`supplied to the data modulator 52. Thus, a person of ordinary skill in the art would
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`understand from this disclosure that the normal data RGB is included in the digital
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`video data provided by the digital video card and rearranged by the timing
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`controller 51. The Sharp Petition includes no argument that the timing controller
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`51’s rearranging of the normal data RGB constitutes “generating” the normal data
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`RGB. From the view of a person of ordinary skill in the art, the fact that the timing
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`controller 51 rearranges the normal data RGB means that the normal data RGB
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`exists prior to receipt by the timing controller 51. A person of ordinary skill in the
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`art would not interpret Ham’s rearranging of digital video data as “generating”
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`according to claim 4. In whole, Ham is silent on the generation of the normal data
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`RGB, and Sharp’s theory cannot be correct. Therefore, Sharp’s theory on why
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`Ham anticipates claim 4 of the ‘843 patent fails to meet the necessary burden of
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`proof as required in an inter partes review, and should not be the basis for
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`invalidating claim 4.
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`43. Since claims 8 and 9 depend from claim 4, I understand that these
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`claims incorporate all features from claim 4. Since the Sharp Petition fails to
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`20
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`Exhibit 2005
`Page 20 of 29
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`establish anticipation of claim 4 by Ham, the Sharp Petition also fails to establish
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`anticipation of claims 8 and 9 by Ham.
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`21
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`Exhibit 2005
`Page 21 of 29
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`I declare under penalty of peljury under the laws of the United States that
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`my foregoing testimony is true and correct.
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`Executed this 10th day ofJune, 2015 in ”E
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`fZé‘W/Vz ’4 E .
`
`DflfllflL—v
`
`William K. Bohannon
`
`22
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`Exhibit 2005
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`Page 22 of 29
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`Exhibit 2005
`Page 22 of 29
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`Appendix A
`Appendix A
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`Exhibit 2005
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`Page 23 of 29
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`Exhibit 2005
`Page 23 of 29
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`Page 2.
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`
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`William K. Bohannon
`Resume
`
`
`
`
`
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`WILLIAM K. BOHANNON
`
`
`SUMMARY
`
`
`Worked in the commercial-industrial electronics and professional audio-visual industry
`for the last twenty-five years. Prior to work in commercial industry, worked in the
`aerospace industry for another approximately 10 years. Responsibilities included a
`number of highly sophisticated, government classified sensor and imaging projects. Prior
`to government and aerospace work, was involved with analytical, scientific research
`regarding spectroscopy for a number of years.
`
`
`
`Has been involved with electronic systems, detectors, measurements, sensors, projectors,
`displays and imaging apparatus for close to twenty-five years. Has been involved with
`all phases of the development of various kinds of electronic systems, including
`conception, invention, development, marketing and sales. Prepared specifications,
`negotiated with various customers over system or component requirements and
`specifications, and prepared or negotiated over tests and measurements of these systems
`or their separate components to insure that the specifications or requirements have been
`or will be meet. Also, prepared and negotiated development contracts and subcontracts
`for such systems or for their electronic components.
`
`
`SPECIFIC AREAS OF EXPERTISE
`
`Automated Test Equipment (ATE) and Electronics for IC test: Drivers, Comparators, Loads,
`DUT Power Supplies, Buffers, Amplifiers, Precision Measurement Unit (PMU) for F/M of I/V,
`ADC, DAC, Clocks, FPGA and other related electronics. (see: Semtech, Intersil, Edge, Planet
`ATE etc.)
`
`LCD, Plasma, CRT and Large Screen Display Equipment: LCD manufacturing, substrates,
`drivers and other related components for rear screen displays including Avionics and cockpit
`d
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