1 1
`
`United States Patent and Trademark Office
`Before the Patent Trial and Appeal Board
`
`Sharp Corporation et al.,
`Petitioner
`v.
`Surpass Tech Innovation LLC,
`Patent Owner
`
`
`
`Case IPR2015-00021
`Patent No. 7,202,843
`
`Petitioner’s
` Demonstrative Exhibits
`
`SHARP EXHIBIT 1018
`Sharp Corp. et al. v. Surpass Tech Innovation LLC
`IPR2015-00021
`
`Page 1 of 45
`
`
`
`United States Patent and Trademark Office
`Before the Patent Trial and Appeal Board
`
`Sharp Corporation et al.,
`Petitioner
`v.
`Surpass Tech Innovation LLC,
`Patent Owner
`
`
`
`Case IPR2015-00021
`Patent No. 7,202,843
`
`Petitioner’s
` Demonstrative Exhibits
`
`SHARP EXHIBIT 1018
`Sharp Corp. et al. v. Surpass Tech Innovation LLC
`IPR2015-00021
`
`Page 1 of 45
`
`
`
`Overview
`
`The ’843 Patent
`
`The Prior Art Ham Reference
`
`Patent Owner’s 1st Argument: Ham’s Data Modulator
`
`Patent Owner’s 2nd Argument: The Construction Of “Generating”
`
`Patent Owner’s 3rd Argument: “Overdriving”
`
`
`
`2
`
`3
`
`8
`
`12
`
`19
`
`24
`
`Page 2 of 45
`
`
`
`3 3
`
`The ’843 Patent
`The ’843 Patent
`
`Page 3 of 45
`
`
`
`The ’843 Patent: The Problem
`
`4
`
`“A liquid crystal display (LCD) has advantages . . . . However, an LCD
`does have some disadvantages. Because of the limitations of physical
`characteristics, the liquid crystal molecules need to be twisted and
`rearranged when changing input data, which can cause the images to be
`delayed. For satisfying the rapid switching requirements of multimedia
`equipment, improving the response speed of liquid crystal is desired.”
`
`Ex. 1001, ’843 Patent, Col. 1:14-26; see also Paper 1, Petition at 12-13
`
`Page 4 of 45
`
`
`
`The First Solution: Multiple Data Impulses
`
`5
`
`“In contrast to the prior art, the present invention discloses a driving circuit
`and relating driving method to generate two pieces of pixel data in each frame
`period for every pixel on an LCD panel and then to generate two data impulses
`according to the two pieces of pixel data and to apply them to each pixel
`within a frame period in order to change the transmission rate of a pixel
`electrode. Thus, . . . liquid crystal molecules of the pixels can twist to reach a
`predetermined gray level within a frame period, and blurring will not occur.”
`
`Ex. 1001, ’843 Patent, Col. 5:45-55
`
`Page 5 of 45
`
`
`
`Claim 4 = The First Solution
`
`6
`
`4. A method for driving a liquid crystal display (LCD) panel . . . comprising:
`
`receiving continuously a plurality of frame data;
`
`generating a plurality of data impulses for each pixel within every frame
`period according to the frame data; and
`
`applying the data impulses to the liquid crystal device of one of the pixels
`within one frame period via the data line connected to the pixel in order to
`control a transmission rate of the liquid crystal device of the pixel.
`
`Ex. 1001, ’843 Patent, Claim 4, Col. 7:1-19
`
`Page 6 of 45
`
`
`
`Claim 1 (Not Under Review) = The Second Solution:
`Multiple Overdriven Impulses
`
`7
`
`1. A driving circuit for driving an LCD panel . . . comprising:
`
`a blur clear converter for receiving frame data every frame period, each
`frame data comprising a plurality of pixel data and each pixel data
`corresponding to a pixel, the blur clear converter delaying current frame data
`to generate delayed frame data and generating a plurality of overdriven pixel
`data within every frame period for each pixel;
`
`a source driver for generating a plurality of data impulses to each pixel
`according to the plurality of overdriven pixel data generated by the blur clear
`converter and applying the data impulses to the liquid crystal device of the
`pixel via the scan line connected to the pixel within one frame period in order
`to control transmission rate of the liquid crystal device; and
`
`a gate driver for applying a scan line voltage to the switch device of the pixel
`so that the data impulses can be applied to the liquid crystal device of the
`pixel.
`
`Ex. 1001, ’843 Patent, Claim 1, Col. 5:63-Col.
`6:24
`
`Page 7 of 45
`
`
`
`8 8
`
`The Prior Art Ham Reference
`
`Page 8 of 45
`
`
`
`Ham’s Problem: Blurring
`
`9
`
`“[T]he conventional LCD cannot express desired color and brightness.
`Upon implementation of a moving picture, a display brightness BL fails to
`arrive at a target brightness corresponding to a change of the video data VD
`from one level to another level due to its slow response time. Accordingly, a
`motion-blurring phenomenon appears from the moving picture and a
`display quality is deteriorated in the LCD due to a reduction in a contrast
`ratio.”
`
`Ex. 1005, Ham, ¶10
`
`Page 9 of 45
`
`
`
`Ham’s Solution: Multiple Data Impulses
`
`10
`
`“The present invention discloses a method and apparatus for driving a liquid
`crystal display device suitable for enhancing a picture quality. More
`specifically, in the method and apparatus, source data is modulated based on
`registered data that is previously provided therein. The modulated data is
`applied to a liquid crystal panel at the initial period of one frame period. A
`[“Normal”] data different from the modulated data is supplied to the liquid
`crystal panel at the later period of the frame period.”
`
`Ex. 1005, Ham, Abstract;
`see also id. ¶ 53;
`Paper 1, Petition at 45, 46, 47;
`Paper 9, Patent Owner’s Prelim.
`Response at 34; Paper 20, Patent
`Owner’s Response at 30-31
`
`Ex. 1005, Ham, Fig. 7B;
`see also Paper 1, Petition at 47
`
`Page 10 of 45
`
`
`
`Patent Owner Raises Three Arguments
`
`11
`
`“First, Petitioners’ theory of unpatentability relies on Ham’s data modulator
`52 to generate the “plurality of data impulses for each pixel within every
`frame period” as recited in claim 4.”
`
`Paper 20, Patent Owner’s Resp. at 2
`
`“Second, the Petitioners have offered no evidence on the proper
`construction of “generating” as it appears in claim 4, and therefore have
`failed to present even a de minimis showing that modulated AMdata from
`Ham’s data modulator 52 and the normal data RGB are properly
`characterized as “generat[ed].”
`
`Id. at 3-4
`
`“Third, contrary to Petitioners’ contention that “[m]ethod claims 4-9 do not
`require performing the overdrive technique,” (see Pet. at 17), claim 4
`requires overdriving.”
`
`Id. at 4
`
`Page 11 of 45
`
`
`
`12 12
`
`Patent Owner’s 1st Argument:
`Ham’s Data Modulator
`
`Page 12 of 45
`
`
`
`Patent Owner’s Expert: Figure 5 Of Ham
`
`13
`
`“The normal data RGB is also provided from the timing controller 51 to the line
`memory 59, and switch 58 sequentially supplies the modulated data AMdata
`The ’843 patent discloses that controlling a transmission rate of a
`from data modulator 52 and the normal data RGB from line memory 59 to the
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`data driver 53 within one frame interval. [Ham, paragraphs [0041], [0044],
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`[0045]].”
`
`Ex. 2005, Bohannon Decl.
`¶39;
`see also Paper 20,
`Patent Owner’s Resp. at 34
`
`The ’843 patent discloses that controlling a transmission rate of
`a
`liquid crystal device of a pixel is achieved through overdriving.
`Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data
`impulses … in
`
`Ex. 1005, Ham, Fig. 5;
`see also Paper 1, Petition at
`45
`
`Page 13 of 45
`
`
`
`The Consistent Expert Testimony
`On Figure 5 Of Ham
`
`14
`
`Patent Owner’s Expert:
`
`Q. Okay. So is it correct that the initial data coming into timing
`controller is digital?
`A. It says . . . it was from a digital video -- digital video card.
`Q. And the output into data lines is analog; correct?
`A. Yeah. So let’s be clear. Yeah, converted into analog data and applied
`to the data lines, yep.
`
`Petitioner’s Expert:
`
`Ex. 1009, Bohannon Tr. 114:3-12;
`see also Paper 24, Petitioner’s Reply at
`10
`
`“Ham’s source driver (i.e., the “data driver 53”) receives two digital
`signals (i.e., “the modulated data AMdata and the normal data RGB”)
`within one frame interval, “convert[s]” (i.e., generates) each of these
`The ’843 patent discloses that controlling a transmission rate of a
`digital signals into two corresponding analog data signals (i.e., a
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`plurality of data impulses) and “appl[ies]” these two data impulses “to
`the data lines 55 in each scanning period.” (Paper 1, Petition at 48 citing,
`inler alia, Ex. 1005, Ham ¶¶ 40, 41).”
`
`Ex. 1010, Marentic Decl. ¶ 59
`
`(Paper 24, Petitioner’s Reply at 4)
`
`Page 14 of 45
`
`
`
`Patent Owner’s Argument
`
`15
`
`“Petitioners point solely to Ham’s data modulator 52 as the element that
`allegedly ‘generates two data impulses … for each pixel within one frame
`period.’ . . . Petitioners present no other theory for Ham’s generation of the
`‘plurality of data impulses’ as required by claim 4.”
`
`Paper 20, Patent Owner’s Resp. at 9
`
`Page 15 of 45
`
`
`
`The Petition Relies On Ham’s Entire
`Driving Circuit
`
`16
`
`“The output of the circuit disclosed by Ham is shown in Figure 7B
`. . . . As can be seen, each frame period is split into two halves. During the
`first half of the frame period, overdriven data is applied to each pixel.
`During the second half of the frame period, non-overdriven data is applied.”
`
`Paper 1, Petition at 46
`
`Page 16 of 45
`
`
`
`The Petition Relies On Ham’s Entire
`Driving Circuit
`
`17
`
`Claim 4
`
`Ham
`
`the method comprising . .
`
`The method includes generating two data impulses
`
`. generating a plurality
`
`(i.e., “modulated data” and “normal data”) for each
`
`of data impulses for each
`
`pixel “within one frame period.” (E.g., ¶¶ [0040]-
`
`pixel within every frame
`
`[0041], ¶ [0053] (“[T]he LCD drive apparatus and
`
`period according to the
`
`method according to the present invention appl[ies] the
`
`frame data; and
`
`normal data to the liquid crystal panel at the initial half
`
`period of the frame after supplying of the modulated
`
`data to the liquid crystal panel during the later half
`
`period of the frame . . . . “).
`
`Paper 1, Petition at 48
`
`(Paper 24, Petitioner’s Reply at 7
`
`Page 17 of 45
`
`
`
`The Board’s Decision To Institute
`
`18
`
`“Patent Owner . . . argues that the normal RGB data is not
`disclosed as “generated” by timing controller 51. . . .
`Petitioner did not rely on the Figure 5 timing controller 51
`The ’843 patent discloses that controlling a transmission rate of a
`alone to meet the limitation. Rather, we understand
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`Petitioner to rely on the driving apparatus, for example of
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`Figure 5, which is not limited to the timing controller 51, as
`generating the two data impulses as claimed. See Pet. 48,
`citing Ex. 1005 ¶¶ 40, 41, 53.”
`
`Paper 10, Decision at 13
`
`Page 18 of 45
`
`
`
`19 19
`
`Patent Owner’s 2nd Argument:
`The Construction Of “Generating”
`
`Page 19 of 45
`
`
`
`Patent Owner’s Argument
`
`20
`
`“For the ‘generating’ term of claim 4, Petitioners purport to apply the
`broadest reasonable construction, but actually provide no analysis on that
`construction or their characterization of how Ham allegedly discloses
`these features. As a result, Petitioners cannot meet their burden of proof on
`this term.”
`
`Paper 20, Patent Owner’s Resp. at 27
`
`Page 20 of 45
`
`
`
`Petitioner Relied On The Broadest Reasonable
`Construction Of “Generating”
`
`21
`
`The Petition:
`
`“Petitioner submits that, for purposes of this Petition only, the terms of Claims
`The ’843 patent discloses that controlling a transmission rate of a
`1, 4, 8 and 9 of the ’843 Patent are generally clear on their face, and should be
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`given their broadest reasonable construction in light of the specification of the
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`’843 Patent. 37 C.F.R. § 42.100(b).”
`
`Paper 1, Petition at 18
`
`The Board:
`
`“For purposes of this decision, we need not construe any other limitations of
`the challenged claims.”
`
`Paper 10, Decision at 5
`
`Page 21 of 45
`
`
`
`The Experts: Generating Is “Clear”
`
`22
`
`Patent Owner’s Expert:
`
`Q. … [A]re you offering any -- any specific construction for “generating”?
`The ’843 patent discloses that controlling a transmission rate of a
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`A. No. I think the patent is pretty clear, in that -- and in the figures and the
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`description pretty much cover “generating.”
`
`Ex. 1009, Bohannon Tr. 89:9-15;
`see also id. at 89:17-90:8; Paper 24, Petitioner’s Reply at 5-6
`
`Petitioner’s Expert:
`
`“64. I agree that the term ‘generating’ is clear to a person of ordinary skill in
`ulses … in
`the art and requires no further construction.”
`
`Exhibit 1010, Marentic Decl. ¶ 64;
`see also Paper 24, Petitioner’s Reply at 6
`
`(Paper 24, Petitioner’s Reply at 5-6)
`
`Page 22 of 45
`
`
`
`The Law On Claim Construction
`
`23
`
`“Claim construction is a matter of resolution of disputed meanings and
`The ’843 patent discloses that controlling a transmission rate of a
`technical scope, to clarify and when necessary to explain what the patentee
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`covered by the claims, for use in the determination of infringement. It is not
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`an obligatory exercise in redundancy.”
`
`United States Surgical Corp. v. Ethicon, Inc., 103 F.3d 1554, 1568 (Fed. Cir. 1997);
`see also Paper 24, Petitioner’s Reply at 5
`
`Page 23 of 45
`
`
`
`24 24
`
`Patent Owner’s 3rd Argument:
`“Overdriving”
`
`Page 24 of 45
`
`
`
`Patent Owner Cannot Redraft Claim 4
` To Include Overdriving
`
`25
`
`Claim 4
`
`Patent Owner’s Position
`
`applying the data impulses to the liquid
`
`“applying two or more overdriven data
`
`crystal device of one of the pixels
`
`impulses in order to control a
`
`within one frame period via the data line
`
`transmission rate of the liquid crystal
`
`connected to the pixel in order to
`
`device, or overdriving.”
`
`control a transmission rate of the liquid
`
`crystal device of the pixel.
`
`Ex. 1001, ’843 Patent, Col. 7:16-19;
`Paper No. 24, Petitioner’s Reply at 12
`
`Paper No. 20,
`Patent Owner’s Response at 26
`
`Page 25 of 45
`
`
`
`Patent Owner’s Proposed “Construction” Is
`Based On The Desire To Avoid Ham
`
`26
`
`“Contrary to Petitioners’ contention that ‘[m]ethod claims 4-9 do not require
`performing the overdrive technique,” claim 4 does require overdriving
`according to the proper construction of claim 4 . . . . Ham applies normal data
`RGB and therefore applies “non-overdriven data in the second half of the
`The ’843 patent discloses that controlling a transmission rate of a
`frame period.” As such, . . . Petitioners cannot show Ham’s disclosure of
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`“generating” and “applying the [plurality of] data impulses” to a pixel “in
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`order to control a transmission rate of the liquid crystal device of the pixel”
`under the proper construction of these terms since Ham does not apply a
`plurality of overdriven signals in the frame period.”
`
`Paper 20, Patent Owner’s Response at 40;
`see also Paper 24, Petitioner’s Reply at 13
`
`Page 26 of 45
`
`
`
`Rules & Procedures For Amending Claims
`
`27
`
`§ 42.121 Amendment of the patent.
` (a) Motion to amend. A patent owner may file one motion to amend a
`The ’843 patent discloses that controlling a transmission rate of a
`patent, but only after conferring with the Board.
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
` (1) Due date. Unless a due date is provided in a Board order, a motion to
`amend must be filed no later than the filing of a patent owner response. . . .
`
`37 C.F.R. §
`42.121(a)(1)
`
`“For a patent owner’s motion to amend, 37 C.F.R. § 42.20(c) places the
`The ’843 patent discloses that controlling a transmission rate of a
`burden on the patent owner to show a patentable distinction of each
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`proposed substitute claim over the prior art.”
`
`Idle Free Systems, Inc. v. Bergstrom, Inc., IPR2012-00027,
`Paper 26 at 7 (PTAB June 11, 2013)
`
`“Patent Owner failed to take these steps and now seeks to introduce this
`amendment for the first time under the guise of claim construction.”
`
`Paper 24, Petitioner’s Reply at 12-13
`
`Page 27 of 45
`
`
`
`Patent Owner Cannot Show That Overdriving Is
`Patentably Distinct Over The Prior Art
`
`28
`
`The ’843 patent discloses that controlling a transmission rate of a
`“(Adachi) . . . teaches applying two or more overdriven data impulses in a
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`single frame, which is exactly what Patent Owner now seeks to add to Claim 4.”
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`
`Paper 24, Petitioner’s Reply at 12-13, n.
`2
`
`“Note that, in the case where a
`The ’843 patent discloses that controlling a
`single frame is divided into a
`transmission rate of a
`plurality of fields for driving, it is
`liquid crystal device of a pixel is achieved
`preferable that the first field or all
`through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying
`the fields are subjected to the
`the [plurality of] data
`overshoot driving.”
`
`Ex. 1004, Adachi ¶ 112;
`see also Paper 1, Petition at 38;
`Paper 27, Petitioner’s Motion to
`Exclude at 2-4
`
`The ’843 patent discloses that controlling a
`transmission rate of a
`liquid crystal device of a pixel is achieved
`through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the
`[plurality of] data impulses … in
`
`Paper 1, Petition at 5
`
`Page 28 of 45
`
`
`
`The Broadest Reasonable Construction
`
`29
`
`“In an inter partes review, a claim in an unexpired patent shall be given its
`broadest reasonable construction in light of the specification of the patent in
`which it appears. See 37 C.F.R. § 42.100(b). Under the broadest reasonable
`construction standard, claim terms are given their ordinary and customary
`meaning, as would be understood by one of ordinary skill in the art in the
`context of the entire disclosure. See In re Translogic Tech., Inc., 504 F.3d
`1249, 1257 (Fed. Cir. 2007).”
`
`Paper 24, Petitioner’s Reply at 14
`
`Page 29 of 45
`
`
`
`Overdriving Is In Claim 1, Not Claim 4
`
`30
`
`Claim 1
`
`Claim 4
`
`a blur clear converter for receiving frame data
`
`receiving continuously a
`
`every frame period, each frame data comprising a
`
`plurality of frame data;
`
`plurality of pixel data and each pixel data
`
`corresponding to a pixel, the blur clear converter
`
`delaying current frame data to generate delayed
`
`frame data and generating a plurality of
`
`overdriven pixel data within every frame period
`
`for each pixel;
`
`a source driver for generating a plurality of data
`
`generating a plurality of data
`
`impulses to each pixel according to the plurality
`
`impulses for each pixel within
`
`of overdriven pixel data generated by the blur
`
`every frame period according to
`
`clear converter . . .
`
`the frame data; . . .
`
`Paper 24, Petitioner’s Reply at 15
`
`(Paper 1, Petition at 17)
`
`Page 30 of 45
`
`
`
`Patent Owner’s Expert: Claim 1 v. Claim 4
`
`31
`
`A. . . . Anyways, . . . if I read Column 6, line 15 [Claim 1], and they’re
`paraphrased a little bit, it says (as read): Generating a plurality of data
`impulses according to a plurality of overdriven pixel data.
`
`Q. Right. And that’s in Claim 1?
`The ’843 patent discloses that controlling a transmission rate of a
`A. That’s in Claim 1. . . .
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`Q. Right. And -- and am I correct that those same words -- that is,
`“generating a plurality of overdriven pixel data” -- do not appear in
`Claim 4?
`A. Yes, those words do not appear in Claim 4.
`
`Ex. 1009, Bohannon Tr. 81:5-82:18; see
`also Paper 24, Petitioner’s Reply at 15-16
`
`“It is settled law that when a patent claim does not contain a certain
`limitation and another claim does, that limitation cannot be read into the
`former claim . . . .”
`
`SRI Int’l v. Matsushita Elec. Corp. of Am., 775 F.2d 1107, 1122 (Fed. Cir. 1985);
`see also Paper 24, Petitioner’s Reply at 15
`
`Page 31 of 45
`
`
`
`Patent Owner Is Importing A Limitation Into
`Claim 4 From The ’843 Specification
`
`32
`
`“The ’843 patent discloses that controlling a transmission rate of a liquid crystal device of a
`pixel is achieved through overdriving. Thus, the proper construction of claim 4’s phrase
`The ’843 patent discloses that controlling a transmission rate of a
`‘applying the [plurality of] data impulses … in order to control a transmission rate of the
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`liquid crystal device of the pixel’ incorporates overdriving into the scope of claim 4.”
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`
`Paper 20, Patent Owner’s Response at 4-5; see also Ex. 2005, Bohannon Decl. ¶18
`
`“The term at issue in claim 4 is ‘applying the data impulses to the liquid crystal device of one
`of the pixels ... to control a transmission rate of the liquid crystal device of the pixel.’ This
`The ’843 patent discloses that controlling a transmission rate of a
`claim language recalls the discussion of ‘overdriven’ according to the ’843 specification,
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`wherein the reaction speed of the liquid crystal molecules is controlled to be faster through the
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`application of a higher or lower data impulse.”
`
`Paper 20, Patent Owner’s Response at 21; see also Ex. 2005, Bohannon Decl. ¶25
`
`(Paper 24, Petitioner’s Reply at 16)
`
`Page 32 of 45
`
`
`
`Patent Owner Asks The Board to Commit The
`“Cardinal Sin” of Claim Construction
`
`33
`
`Patent Owner’s Preliminary Response:
`
`“The Board will not read a particular embodiment appearing in the written
`description into the claim, if the claim language is broader than the
`embodiment. In re Van Geuns, 988 F.2d 1181, 1184 (Fed. Cir. 1993).”
`
`Paper No. 9, Patent Owner’s Preliminary Resp. at 10
`
`Patent Owner’s Expert:
`
`Q. . . .[I]s it your testimony that if a specification describes a certain
`The ’843 patent discloses that controlling a transmission rate of a
`concept, that that concept should be incorporated into the claims? . . .
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`A. That’s -- that’s -- that’s my understanding . . .
`
`Ex. 1009, Bohannon Tr. 88:4-14; see also id. at 86:8-21
`
`(Paper 24, Reply at 16)
`
`Page 33 of 45
`
`
`
`The ’843 Patent Provides Multiple
`Solutions to the Blurring Problem
`
`34
`
`“As explained in the Petition, the ’843 Patent provides multiple solutions to the problem of the
`blurring of video images in an LCD panel. (Paper 1, Petition at 12-13; Ex. 1010, Marentic Decl.
`¶84). One solution is applying two or more data impulses to a pixel within a given frame, which
`helps smooth out fast motion video and improves the image sequence the eye perceives. (Id. ¶37).
`This concept is described numerous times in the ’843 Patent without any reference to
`overdriving. (Id. ¶¶84-86).”
`
`Paper 24, Petitioner’s Reply at 17
`
`Page 34 of 45
`
`
`
`The Abstract & Field Of The Invention:
`Multiple Data Impulses
`
`35
`
`“A method for driving a liquid crystal display (LCD) panel includes
`receiving continuously a plurality of frame data, generating a plurality of
`data impulses for each pixel every frame period according to the frame
`data, and applying the data impulses to a liquid crystal device of a pixel
`within a frame period via the data line connected to the pixel in order to
`control a transmission rate of the liquid crystal device. ”
`
`Ex. 1001, ’843 Patent, Abstract
`
`“The invention relates to a driving circuit of a liquid crystal display (LCD)
`panel and its related driving method, and more particularly, to a driving
`circuit for applying over two data impulses to a pixel electrode within one
`frame period, and its related driving method.”
`
`Ex. 1001, ’843 Patent, Field of the Invention, Col. 1:8-12
`
`Page 35 of 45
`
`
`
`Summary of Invention: Multiple Data Impulses
`
`36
`
`“Briefly, the present invention provides a method for driving an LCD panel.
`The LCD panel includes a plurality of scan lines, a plurality of data lines, and
`a plurality of pixels. Each pixel is connected to a corresponding scan line and
`a corresponding data line, and each pixel includes a liquid crystal device and
`a switching device connected to the corresponding scan line, the
`corresponding data line, and the liquid crystal device. The method includes
`receiving continuously a plurality of frame data, generating a plurality of
`data impulses for each pixel in every frame period according to the frame
`data and applying the data impulses to the liquid crystal device of one of the
`pixels within one frame period via the data line connected to the pixel in
`order to control the transmission rate of the liquid crystal device of the
`pixel.”
`
`Ex. 1001, ’843 Patent, Summary of the Invention, Col. 2:19-32;
`see also Paper 24, Reply at 16; Ex. 1010, Marentic Decl. ¶ 82
`
`Page 36 of 45
`
`
`
`Detailed Description: Multiple Data Impulses
`
`37
`
`“In contrast to the prior art, the present invention discloses a driving circuit
`and relating driving method to generate two pieces of pixel data in each
`frame period for every pixel on an LCD panel and then to generate two data
`impulses according to the two pieces of pixel data and to apply them to each
`pixel within a frame period in order to change the transmission rate of a pixel
`electrode. Thus, each of the pixels of the LCD panel is applied of a plurality
`of data impulses within a frame period, so that liquid crystal molecules of the
`pixels can twist to reach a predetermined gray level within a frame period,
`and blurring will not occur.”
`
`Ex. 1001, ’843 Patent, Detailed Description, Col. 5:45-55;
`see also Paper 24, Reply at 17-18; Ex. 1010, Marentic Decl. ¶ 85
`
`Page 37 of 45
`
`
`
`Claim 4: Multiple Data Impulses
`
`38
`
`4. A method for driving a liquid crystal display (LCD) panel . . . comprising:
`
`receiving continuously a plurality of frame data;
`
`generating a plurality of data impulses for each pixel within every frame
`period according to the frame data; and
`
`applying the data impulses to the liquid crystal device of one of the pixels
`within one frame period via the data line connected to the pixel in order to
`control a transmission rate of the liquid crystal device of the pixel.
`
`Ex. 1001, ’843 Patent, Claim 4, Col. 7:1-19
`
`“Claim 4 is an original claim and, as such, is part of the specification. See
`Ariad Pharms., Inc. v. Eli Lilly & Co., 598 F.3d 1336, 1349 (Fed. Cir. 2010)
`(en banc).”
`
`Paper 24, Petitioner’s Reply at 18
`
`
`
`Page 38 of 45
`
`
`
`Claims Need Not Be Limited
`To A Single Embodiment
`
`39
`
`“[W]here the specification describes only a single embodiment, . . . we do not
`construe necessarily the claims as being limited to that embodiment.”
`
`K-40 Electronics, LLC v. Escort, Inc., IPR2013-00240, Paper
`37 at 9 (PTAB Sept. 29, 2014)
`
` “[E]ven where a patent describes only a single embodiment, claims will not
`be ‘read restrictively unless the patentee has demonstrated a clear intention to
`limit the claim . . . .”
`
`Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc.,
`381 F.3d 1111, 1117 (Fed. Cir. 2004) (quotations omitted)
`
`(Paper 24, Reply at 16)
`
`Page 39 of 45
`
`
`
`Patent Owner Contends That
`“Control a Transmission Rate” Requires Overdriving
`
`40
`
`“Petitioners’ argument that claim 4 does not require overdriving is
`tantamount to doing violence to the claim by deleting the phrase “to control
`a transmission rate of the liquid crystal device of the pixel” entirely. Such a
`result is unsupported by any expert testimony, runs contrary to Shen’s express
`… in
`and uncontested disclosure of what is meant by controlling a transmission
`rate, and further fails to give effect to all terms in the claim, according
`to the well-accepted law of claim construction.”
`
`Paper No. 20, Patent Owner’s Response at 26-27
`
`(Paper No. 24, Paper 24, Petitioner’s Reply at 12-14)
`
`Page 40 of 45
`
`
`
`Patent Owner’s “Definition” v. The Claim Language
`
`41
`
`Shen has explained that “overdriven” means “applying a higher or a lower
`data impulse to the pixel electrode to accelerate the reaction speed of the
`liquid crystal molecules.” . . . But Shen’s explanation is not a one-way street.
`Specifically, if “overdriven” means “applying a higher or a lower data impulse
`… in
`to the pixel electrode to accelerate the reaction speed of the liquid crystal
`molecules,” then the contrary is also true: “applying a higher or a lower data
`impulse to the pixel electrode to accelerate the reaction speed of the liquid
`crystal molecules” means “overdriving.”
`
`Paper No. 20, Patent Owner’s Response at 20-21
`
`applying the data impulses to the liquid crystal device of one of the pixels
`within one frame period via the data line connected to the pixel in order to
`… in
`control a transmission rate of the liquid crystal device of the pixel.
`
`Ex. 1001, ’843 Patent, Claim 4
`
`Page 41 of 45
`
`
`
`Patent Owner’s Expert Does Not Offer A
`Construction of Transmission Rate
`
`42
`
`Q. Okay. Is it fair to say the transmission rate of a pixel is the percentage
`of light that it allows to pass through? . . .
`The ’843 patent discloses that controlling a transmission rate of a
`A. I’m -- I don’t think I can answer that. I don't think I can say whether
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`it’s fair or not fair. I mean, it’s -- this is the terminology that [the
`inventors] described here.
`
`Ex. 1009, Bohannon Tr. 27:4-11
`
`Q. And before you--you encountered the Shen ’843 Patent, had you heard
`The ’843 patent discloses that controlling a transmission rate of a
`that term [i.e., transmission rate] used before?
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`A. No.
`
`Id. at 22:13-15
`
`Q. . . . Are you offering an opinion on transmission rate? . . .
`… in
`A. I’m not offering an opinion on transmission rate. . . .
`
`Id. at 28:13-19
`
`Paper No. 24, Petitioner’s Reply at 23
`
`Page 42 of 45
`
`
`
`Petitioner’s Expert Explained
`“Transmission Rate”
`
`43
`
`“In any event, based upon a correct understanding of ‘transmission rate,’
`‘control[ling] a transmission rate’ merely refers to applying a particular
`voltage (or potential difference) to a pixel's electrodes. As discussed above, this
`is part of the basic operation of every LCD drive circuit, irrespective of the
`type of display or whether or not ‘overdriving’ is used.”
`
`Ex. 1010, Marentic Decl. ¶ 93; see also Paper 24, Petitioner’s Reply at 24
`
`Page 43 of 45
`
`
`
`Multiple Prior Art References Teach Controlling A
`Transmission Rate Without Overdriving
`
`44
`
`Ex. 1012, U.S. 5,402,143, Col. 4:15-22 (explaining that, in a “simple matrix type conventional
`The ’843 patent discloses that controlling a transmission rate of a
`LCD” display, “the scanning and data signals together control the transmission rate of each
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`pixel of light passing therethrough”)
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`
`Ex. 1010, Marentic Decl. ¶ 93
`
`The ’843 patent discloses that controlling a transmission rate of a
`Ex. 1013, U.S. 6,538,647, Col. 4:64-68 (explaining that, in a normally black LCD display,
`liquid crystal device of a pixel is achieved through overdriving. Thus, the proper
`“driving voltage” is directly related to the “optical transmission rate”)
`construction of claim 4’s phrase “applying the [plurality of] data impulses … in
`
`Id. at ¶ 90
`
`Ex. 1014, U.S. 5,608,556, Col. 2:30-33 (“In each opening 201, the transmission rate of light is
`… in
`controlled to provide the desired display . . .”
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