EXHIBIT 2169
`EXHIBIT 2169
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`EXHIBIT 2169
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MasterImage 3D, Inc.
`and
`MasterImage 3D Asia, LLC,
`Petitioners,
`
`V.
`
`RealD Inc.,
`Patent Owner.
`
`Patent No. 8,220,934
`
`Issue Date: July 17, 2012
`
`Title: Polarization Conversion Systems For Stereoscopic Projection
`
`DECLARATION UNDER 37 C.F.R. § 1.132 OF MATTHEW
`S. BRENNESHOLTZ IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,959,934
`
`EXHIBIT
`
`ke/mes44/fa 3.7/,?s
`
`MasterImage 3D, Inc. and MasterImage 3D Asia, LLC - Exhibit 1009
`
`REALD INC.
`Exhibit 2169-1
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`INTRODUCTION
`My name is Matthew S. Brennesholtz. I have been asked by Petitioner to
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`provide my expert opinions in support of the above-captioned petition for inter partes
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`review of Patent No. 8,220,934 ("the '934 patent"), challenging the validity of claims
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`1-20 of the '934 patent.
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`BACKGROUND AND QUALIFICATIONS
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`I was awarded a Master of Engineering degree in Optics and Plasma
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`Physics from Cornell University in 1978, and a Bachelor of Science degree in
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`Engineering Physics, also from Cornell University, in 1969.
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`The primary focus throughout my career has been display systems and
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`the optical components for use in those systems.
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`I am an inventor and co-inventor on 23 issued U.S. patents related to
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`display systems and components. I am also the author of Projection Diiplays 2nd Ed.
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`with Ed Stupp, John Wiley & Sons Ltd., 2008, 432pp.
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`Presently, I am an independent consultant with a specialty in optics and
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`display systems. I have been in the display system industry for 36 years and have been
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`an independent consultant for 3 years. My professional industry experience includes
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`11 years at Philips Display Components Company where I was responsible for the
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`optical aspects of cathode ray tubes for consumer, data and projection applications.
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`During my tenure at General Electric/ Projection Display Products Operation, my
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`principal responsibility was to maximize the amount of light delivered to the
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`2
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`REALD INC.
`Exhibit 2169-2
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`customer's projection screen. I continued to work on the optics and emerging
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`technologies of display systems at Philips Research, Philips LCoS Microdisplay
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`Systems, and Insight Media.
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`A detailed curriculum vitae showing more of my credentials is included
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`as Exhibit 1010.
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`COMPENSATION
`I am being compensated for my time at the rate of $300 per hour. This
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`compensation is not contingent upon my performance, the outcome of this matter, or
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`any issues involved in or related to this matter.
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`DOCUMENTS AND OTHER MATERIALS RELIED UPON
`In forming the opinions set forth in this declaration, I have reviewed
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`the '934 patent, its prosecution history, the prosecution histories of its patent family,
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`and the prior art references described below. Additionally, I have considered my own
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`experience and expertise of the knowledge of the person of ordinary skill in the
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`relevant art in the timeframe of the claimed priority date of the '934 patent. In doing
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`so, I have reviewed information generally available to, and relied upon, by a person of
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`ordinary skill at the time of the invention. I was told to assume the time of the
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`invendon is the date of the filing of the original application on September 29, 2006.
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`I anticipate using some of the below referenced documents and
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`information, or other information and material that may be made available during the
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`course of this proceeding (such as by deposition testimony), as well as representative
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
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`3
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`REALD INC.
`Exhibit 2169-3
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`charts, graphs, schematics, and diagrams, animations, and models that w-ill be based
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`on those documents, information, and material, to support and to explain my
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`testimony before the PTAB panel regarding the invalidity of the '934 patent.
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`PERSON OF ORDINARY SKILL IN THE ART FOR THE '934 PATENT
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`A person of ordinary skill in the art in the field of the '934 patent would
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`be someone with a good working knowledge of optics and display systems in general,
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`and stereoscopic (stereographic1) projection systems in particular. The person would
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`have gained this knowledge through an undergaduate or graduate education in
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`physics, optics, or a comparable field, in combination with further training and several
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`years of practical worldng experience.
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`TECHNOLOGICAL BACKGROUND
`One method used to display images, e.g., motion pictures, with a
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`stereoscopic three-dimensional ("3D") effect utili es the projecdon of two images
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`which are superimposed onto a screen. The two images are of the same scene, but are
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`depicted from slightly different perspectives, e.g., the left and tight lenses of a
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`stereoscopic camera. The left and right stereoscopic images have a visible light
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`1 While "stereoscopic" is currently the preferred term for these systems,
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`"Stereographic" is used in some of the references. The two terms will be used
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`interchangeably in this Declaration.
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`4
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`REALD INC.
`Exhibit 2169-4
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`characteristic such that when they are viewed through special eyeglasses, each of the
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`-viewer's eyes sees only one of the images, providing the 3D effect.
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`Visible light characteristic used to achieve a 3D effect includes color and
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`polarization. Polarization is a property of an electromagnetic wave, such as light, used
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`to describe the direction in which the wave's electric field is oscillating. The distance
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`a wave travels in one cycle of oscillation is called its wavelength. The color of light is
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`a function of wavelength. When viewed as a sinusoidal, single wavelength plane wave
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`travelling in one direction, light may be characterized as being unpolarized (or
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`randomly polarized) or its state of polarization ("SOP") may be linear, circular or
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`elliptical.
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`For light impinging on a tilted surface, the "plane of incidence" is
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`defined as the plane that contains both the direction of propagation of the light and
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`the normal to the tilted surface. For linearly polarized light, the direction of the plane
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`in which the electric field oscillates, relative to the plane of incidence of the light, is
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`used to describe the light as being p-polarized (parallel to the plane of incidence), s-
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`polarized (perpendicular to the plane of incidence) or at some angle relative to one of
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`the planes. Light which is p-polarized is orthogonal to s-polarized light. For
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`circularly polarized light, the rotation of the electric field vector may be right-handed
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`or left-handed, which are also considered orthogonal to each other.
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`5
`
`REALD INC.
`Exhibit 2169-5
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`Various opdcal devices can be used to alter light's state of polarization.
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`A linear polarizer is a device that transmits only one polarization, such as a p-polarizer
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`which by its design and orientation passes only linearly p-polarized light. An eyeglass
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`lens used to view polarized stereographic images is a polarizer and is sometimes called
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`an analyzer because it analyzes all of the light in its view and blocks out all but one
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`SOP. If the light incident upon a polarizer is predominately of the same orientation
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`as the polarizer, the polarizer is sometimes called a clean-up polarizer
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`A polarized beam splitter ("PBS") is used to separate unpolarized light
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`into independent paths of p-polarized and s-polarized light. Some PBSs pass p-
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`polarized light through the device and reflect the s-polarized light. After the PBS, the
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`two different polarizations of light may be traveling perpendicularly to each other or
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`may be at some other angle. Commonly the designations "P" and "S" are used for
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`primary and secondary beams. In many polarizing beamsplitters, p-polarized light is
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`transmitted and becomes the primary (P) beam and s-polarized light is reflected and
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`becomes the secondary (S) beam.
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`A wave plate or retarder alters the polarization state of light passing
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`through it. A half-wave retarder with the correct orientation is used to rotate the
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`polarization direction of linearly polarized light by 900; thus p-polarized light entering
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`a half-wave retarder e)dts as s-polarized light. A quarter wave retarder with the
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`correct orientation is used to convert linearly polarized light to circularly polarized
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
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`6
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`REALD INC.
`Exhibit 2169-6
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`light. Retarders are often called by short-hand names, such as half-wave or quarter-
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`wave, without expressly specifying the orientation of their axes or of the input light.
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`Half-wave and quarter-wave refer to a retarder whose retardance value is 1/2 or 1/4 the
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`wavelength of the incident light. Simple, single layer retarders are typically ch_romatic,
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`that is the value of the retardance varies with the wavelength of the light and the
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`retarder is a 1/2 or 1/4 wave retarder for a single wavelength. Achromatic retarders are
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`also known. An achromatic half-wave or quarter wave retarder (sometimes called a
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`retarder stack) has a value of 1/2 or 1/4 the wavelength of all light within the achromatic
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`retarder's wavelength bandwidth.
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`Half-wave and quarter-wave retarders are examples of static devices in
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`that the polarization conversion which they perform does not change over time. On
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`the other hand, a polarization modulator provides different output states of
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`polarization over time based on control sig-nal(s) applied to the modulator. For
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`example, a polarization modulator could alternately output p/s/p/s-polarized light in
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`synchronization with a control signal ±V,/0/±V/0. Alternatively, two LC cells could
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`be used, with ±V applied alternately with OV to each of the two cells out of phase.
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`Some stereoscopic systems display the left-perspective and right-
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`perspective images simultaneously, while others display the left and right images
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`sequentially, e.g., L/R/L/R. Simultaneously display of left and right images is most
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`easily accomplished using two display devices, e.g., projectors. Sequential display of
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`7
`
`REALD INC.
`Exhibit 2169-7
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`left and right images allows use of a single display system which employs a
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`polarization modulator providing alternating output states of polarization in
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`synchronism with the switching rate between the left and right images.
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`A ZScreen is an example of a polarization modulator, in which so-called
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`pi-cells are utilized. For the pi-cells of a ZScreen to properly perform their
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`modulation function, the light applied to them is required to be linearly polarized.
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`That is why a linear absorptive polarizer precedes the pi-cells. '934 patent, 1:43-45.
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`By aligning the linear polarization direction of both the first and second paths of the
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`image light with the axis of the linear polarizer in a ZScreen, the '934 patent
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`projection system avoids the 50% loss in image brightness which occurs in prior art
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`systems as a result of randomly polarized light being applied to the ZScreen input
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`linear absorptive polarizer
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`Many optical elements do not intentionally change the state of
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`polarization of light passing through or reflected off of them. Examples of these
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`types of elements include mirrors lenses, prisms and the DLP image modulator from
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`Texas Instruments. However, these elements often unintentionally affect the
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`polarization of the light. For example, if a beam of light that is 100% p-polarized is
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`reflected off of a perfect mirror, after the reflection the beam should, in theory, still
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`be 100% p-polarized. No optical element is perfect, however, and commonly there is
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`a slight degradation of the polarization quality of the optical beam. Improving the
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
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`8
`
`REALD INC.
`Exhibit 2169-8
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`quality of the optical component used ('934 patent, 4:43-50) can reduce but not
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`completely eliminate this problem. For this reason, it is sound optical practice to put
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`polarization elements as late as feasible in the optical path, especially when dealing
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`with image modulators such as the DLP that do not require polarized light.
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`Significant depolarization can occur at the DLP or the attendant optical elements that
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`allow the DLP to generate a modulated image.
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`Polarizing elements exhibit this same problem. If a polarizing element is
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`intended to convert an input SOP into an output SOP, this output SOP normally
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`would be slightly contaminated with the input SOP. This issue is particularly
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`common in LC-based light modulators and the light modulator is normally designed
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`to minimize this contamination.
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`All absorptive polarizers intending to transmit one linear polarization
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`and block the orthogonal linear polarization absorb some of the intended polarization
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`and transmit some of the undesired polarization. This is always a trade-off: when a
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`polarizer is designed so less of the undesired polarization transmitted, more of the
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`desired polarization is absorbed. The trade off made by an optical designer often
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`depends on the input state of polarization. If unpolarized light is input, it is critical
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`that the polarizer absorb the maximum amount of the undesired polarization. If
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`polarized light is input, as in a clean-up polarizer, the requirement is normally the
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`polarizer transmit the maximum amount of the desired polarization.
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`9
`
`REALD INC.
`Exhibit 2169-9
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`CLAIM CONSTRUCTION
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`In my review of the '934 patent, its patent family, and from my
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`knowledge of the field, one of ordinary skill in the art would understand the term
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`"polarization beam splitter" to mean a device that creates primary path and
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`secondary path beams of light energy by directing light of one polarization
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`state along the primary path and light of another polarization state along a
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`secondary path. Ex. 1001, '934 patent, 3:24-29.
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`In my review of the '934 patent, its patent family, and from my
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`knowledge of the field, one of ordinary skill in the art would understand the term
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`"rotator" to mean an optical device that receives light energy and rotates the
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`polarization characteristics of light passing through it to another polarization
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`state. Ex. 1001, '934 patent, 3:30-47.
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`In my review of the '934 patent, its patent family, and from my
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`knowledge of the field, one of ordinary skill in the art would understand the terms
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`"polarization switch panel" and "switch subsystem" to mean a device that receives
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`light energy and outputs the light energy in at least two alternating states of
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`polarization, wherein the alternating states, include, but are not limited to, p-
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`polarized and s-polarized linearly polarized light, and left- and right-handed
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`circularly polarized light. Ex. 1001, '934 patent, 2:14-18.
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`In my review of the '934 patent, its patent family, and from my
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`knowledge of the field, one of ordinary skill in the art would understand the term
`10
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`REALD INC.
`Exhibit 2169-10
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`"telephoto lens pair" to mean a lens pair consisting of an air-spaced positive
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`element with a negative element which allows control of magnification,
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`distortion, and imaging properties of light. Ex. 1001, '934 patent, 5:62-67.
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`In my review of the '934 patent, its patent family, and from my
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`knowledge of the field, one of ordinary skill in the art would understand the term
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`"cleanup polarizer" to mean an optical device which removes undesired
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`polarization characteristics from a beam of polarized light having a known
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`state of polarization. Ex. 1001, '934 patent, 6:33-45.
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`SILVERSTEIN, U.S. PATENT NO. 7,559,653
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`Set forth below is a composite figure which combines FIGs. 3, 16 and 2
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`from Silverstein. The composite figure is constructed according to Silverstein's FIG.
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`2 block diagram, wherein the block-form illumination source 210 is implemented by
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`the FIG. 3 illumination source 110, and the block-form modulation apparatus 2201,
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`220r is implemented by the FIG. 16 imaging apparatus. Identification of the various
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`optical elements has been added to the composite figure based on Silverstein's
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`disclosure, including the parts list in columns 17 and 18 of Silverstein. In the figure,
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`the projection lens 62 is shown in two separate locations only because each of FIGs.
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`16 and 2 illustrates it.
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`11
`
`REALD INC.
`Exhibit 2169-11
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`projection
`lens
`62
`
`intermediate
`image
`64
`
`shutter
`(optional')
`116
`
`mirror
`98
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`half-wave
`plate
`72
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`light source
`20
`
`tudformizing
`element
`2
`
`IF`1465/
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`polarized
`illumination beam
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`len'
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`polarize(
`(wiregrid or
`MacNeille prism)
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`110
`polarized light
`providing apparatus
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`38
`condensing
`lens
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`modulator
`panel
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`140
`color scrolling
`element
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`70
`switcttable polarization
`rotating element
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`display
`surface
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`230
`polarizing
`glasses
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`FIG. 3
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`FIG. 16
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`FIG. 2
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`29.
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`Based on Silverstein's disclosure, one of ordinary skill in projection
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`devices would have recognized that the FIGs. 3/16/2 embodiment depicts two
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`subsystems which are conceptually separable. The first subsystem is for modulation
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`of the image. The second subsystem is for providing stereographic viewing of the
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`modulated image. The light source 20, polarizer 96, mirror 98 and half-wave 72 plate
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`are common to both the image modulation and the stereographic viewing subsystems.
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`One of ordinary skill in the art would recognize half-wave plate 72 may be an
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`achromatic retarder stack. The color scrolling element 140 and the modulator panel
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`60 are for image modulation. The switchable polarization rotating element 70 is for
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`alternating polarization states of the left and right images for stereographic viewing.
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`Silverstein also points out that polarizer 96 could be several different types of
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`polarizers, including a MacNeille polarizer, which one of ordinary skill in the art
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
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`12
`
`REALD INC.
`Exhibit 2169-12
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`would understand is comprised of multiple different dielectric layers. See Ex. 1014,
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`U.S. Patent No. 2,403,731.
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`Once arranged in the manner of the composite Figs. 3/16/2, half wave
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`plate 72, is clearly designed to rotate the light reflected from mirror 98, and rotate it to
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`the polarization state of the light that passed through polarized beam splitter. This is
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`further made apparent by the system using a single switchable polarization rotating
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`element 70, meaning that the light of the two paths created by the splitter arrives at
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`switch 70 with the same polarization.
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`However, Silverstein also discloses that the polarization rotating element
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`70 can be used in the embodiment shown in Fig 4, below, between the lens 61 and the
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`image 64. Ex. 1002, Silverstein, 16:35-40. Accordingly, since Fig. 4 is just channel
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`modulation apparatus for the left channel, and "220r for the right eye would be
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`similarly constructed," it would be obvious to a one of ordinary skill in the art that
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`switchable polarization rotating element 70 could be two panels, one for the left
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`channel and one for the right channel based on the embodiment shown in Fig. 4.
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`13
`
`REALD INC.
`Exhibit 2169-13
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`FIG. 4
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`32.
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`Projections systems need to provide adjustable lensing that allows the
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`output light path to be focused and enlarged for proper projection on screens at a
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`varying distances from the projector, and for screens of varying sizes. The system of
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`Silverstein uses a "projecdon lens 62 so that image 64 "can be magnified to the large
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`screen size by a single projecdon lens 62." Ex. 1002, Silverstein, 13:38-41. One of
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`ordinary skill in the art would have understood that "projecdon lens" does not mean a
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`single optical element (lens) in isoladon. "A projection lens" is typically an
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`arrangement of lenses specifically designed to accomplish the needed task. As
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`Edward Stupp and I describe in our text Projection Displays, "single-lens projectors"
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`commonly use a reversed telephoto lens design, although telephoto lenses are also
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`common. Edward H. Stupp and Mathew S. Brennesholtz, "Projection Displays,"
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`14
`
`REALD INC.
`Exhibit 2169-14
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
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`John Wiley & Sons Ltd. (1999)("Stupp") , pp. 143-145. An example of such an
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`arrangement is depicted in Figure 7.51 of Stupp:
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`40111,1%
`
`1-11.1.401111111MOMPAIA
`1V
`y
`4"11
`
`Combining
`Diehroies
`
`LCD
`
`Projection
`creen
`S
`
`--11"
`
`Figure 7.51
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`Typical three-panel LCD projection lens.
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`Ex. 1006, Stupp, p. 144, Fig. 7.51.
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`33.
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`A telephoto or reverse telephoto design always contains two lenses or
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`lens groups. For example, U.S. Patent No. 5,822,129 to Sekine illustrates a telephoto
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`lens pair and Stupp illustrates a reverse telephoto lens pair. Ex. 1006, Stupp, p. 144,
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`Fig. 7.51 (annotated); Ex. 1015, Sekine, Fig. 1 (annotated), 4:1-4, 7:27-31.
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`Reverse telephoto
`lens air
`
`-eeanoto Len Pee
`
`Base Lers
`
`U
`
`I ri"1"41MIIIIIMAIIIMI
`1
`
`COmbining
`Dichroics
`
`GI
`
`Figure 7.51
`
`TypIcal three-panel LCD projection lens. Stupp 1999
`
`To Proiecten Screen
`
`FIGURE 1 US 5 822.129 to Setune
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`One lens (or group) will have positive power and the other will have negative power
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`separated by air. This lens type takes its name from the last two elements on the right,
`15
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`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`REALD INC.
`Exhibit 2169-15
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`which form a reversed telephoto lens pair. One of ordinary skill in the art would have
`
`recognized that "projection lens 62" was actually an arrangement such as the one
`
`above, and would have referred to the entire arrangement as a "projection lens" (as
`
`Stupp does). Stupp, p. 143. If they mistook "projection lens 62" for a single optical
`
`element, one of ordinary skill in the art would have known that projection systems
`
`typically use such arrangements for a projection lens and found it obvious to replace
`
`"projection lens 62" with a more typical arrangement. They would have been
`
`motivated to do so because a single optical element projection lens produces a poor
`
`quality image. Further, while the placement of a pro jector lens at the end of the light
`
`paths (such that it is the last element light passes through before it leave the system) is
`
`the most typical arrangement. One of ordinary skill in the art would recognize that it
`
`does not have to be placed there. For example, the '934 patent cites and incorporates
`
`by reference U.S. Pat. No. 4,792,850, which places its projection lens (projection lens
`
`19 in Lipton Fig. 6 below) before the Z-screen it uses as a polarization modulatot(20
`
`in the figure below). One of ordinary skill in the art would understand that it may be
`
`preferable to place the projection lens before the modulator, if, for example, the
`
`modulator was intended to be removable.
`
`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`16
`
`REALD INC.
`Exhibit 2169-16
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`-
`
`Ex. 1004, Lipton, Fig. 6.
`
`34.
`
`Silverstein teaches that "this same type of polarization switching could
`
`provide alternating left- and right-eye images for stereographic viewing when used
`
`with other light modulation arrangements." Ex. 1001, Silverstein, 16:31-34. Based on
`
`this disclosure and recognizing the separability of the FIGs. 3/16/2 image modulation
`
`and stereographic viewing subsystems, one of ordinary skill in projection devices
`
`would have found it obvious to employ the stereographic viewing subsystem with a
`
`type of light modulation system in which the light energy is modulated by the image
`
`and then projected to the polarizer 96. This is especially apparent to one of ordinary
`
`skill since in such a system, the primary and secondary paths of image light
`
`transmitted by the polarizer 96 would be directed by further optical elements (bottom
`
`lens 34 and condensing les 38 for the primary path, and mirror 98, top lens 34, half-
`
`wave plate 72 and condensing lens 38 for the secondary path) so as to be
`
`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`17
`
`REALD INC.
`Exhibit 2169-17
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`superirnposed as a single image upon arrival at the switchable polarization rotating
`
`element 70. In such a system, the color scrolling element 140 and LC modulator
`
`panel 60 would not be present in their FIG. 16 location since their function of
`
`modulating the light with an image would be repositioned to the vicinity of the light
`
`source 20.
`
`Silverstein's disclosure primarily concerns use of polarized light by a LC
`
`panel. Nevertheless, he discusses a competing technology, digital micromirror devices
`
`(DMD), in comparison to motion picture image formation based on the use of print
`
`film. Ex. 1001, Silverstein, 3:3-18. At the time of Silverstein's disclosure, one of
`
`ordinary skill would have known that both DMD and print film modulate an image
`
`onto randomly polarized light. In Silverstein, the light source 20 also provides
`
`randomly polarized light. Such commonality in light source type would have pointed
`
`one of ordinary skill to the potential use of either DMD or print film as "other light
`
`modulation arrangements" to which the FIG. 16 polarization switching system is
`
`applicable. Implementation of DMD or print film modulation would have been most
`
`easily accomplished by moving image formation "up-front" so that irnage light is
`
`projected to the Silverstein FIG. 3 polatizer 96.
`
`In Silverstein, the alternating left- and right- eye polarization
`
`characteristics imparted onto the images by the switchable polarization rotating
`
`element 70 are linear s-polarization and p-polarization. The switchable polarization
`
`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`18
`
`REALD INC.
`Exhibit 2169-18
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`element 70 is disclosed as an electrically controlled liquid crystal retarder. In such a
`
`retarder, a control signal acts to "push" an axis of the liquid crystal and then "let go".
`
`If alternating left- and right- handed circularly polarized light would have been desired
`
`in Silverstein, one of ordinary skill would have known to utilize two layers of liquid
`
`crystal having their axes crossed and electrically driven out of phase in a "push-pull"
`
`manner.
`
`SILVERSTEIN
`Based on the '934 patent admitted prior art, including FIG. 1, and its
`
`corresponding description, one of ordinary skill in the art of image projection, and
`
`particularly one of ordinary skill in the art of stereographic image projection, would
`
`have understood the value of applying the Silverstein FIGs. 3/16/2 stereoscopic
`
`modulation technique for increasing image brightness to other image generation
`
`methods used in motion picture projectors. Many such projectors (e.g., DMD)
`
`produce an image in which the image light is not polarized, and the projector provides
`
`a synchronization signal which can be used to drive a polarization modulator.
`
`Accordingly, in view of Silverstein and the admitted prior art, one of ordinary skill
`
`would have found it obvious, and would have been motivated, to generate the image
`
`"up-front" (as in the case of DMD projectors) and provide the image light to the
`
`Silverstein FIG. 3 polarizer 96.
`
`In the '934 patent, the ZScreen polarization modulator produces
`
`alternating left-handed and right-handed circularly polarized light, and the eyewear
`19
`
`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`REALD INC.
`Exhibit 2169-19
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`105 worn by the viewer analyzes the orthogonal circularly polarized images. In
`
`Silverstein, the alternating left
`
`and right
`
`eye polarization characteristics imparted
`
`onto the images are s-polarization and p-polarization, and the polarizing glasses 230
`
`utilize linear polarizers as analyzers. If one of ordinary skill desired to use instead
`
`alternating left
`
`and right
`
`handed circularly polarized light, he would have known
`
`to utilize a "push-pull" modulator comprised of pi-cells as in the prior art ZScreen, in
`
`place of the "push-let go" switchable polarizadon rotating element 70 used in FIG. 16
`
`of Silverstein.
`
`39.
`
`Another patent to Silverstein, U.S. Patent No. 7,198,373
`
`("Silverstein '373 patent") (Ex. 1013) succinctly explains the benefit of using a
`
`polarizer, mirror and half-wave plate arrangement, as shown in the Silverstein FIGs.
`
`3/16/2 embodiment, before a modulation component which operates on a particular
`
`SOP, specifically linear p-polarization. The portion of the Silverstein '373 patent
`
`quoted below explains the benefit of using these components with regard to an image
`
`modulator which inputs p-polarized light. Nevertheless, the same benefit is applicable
`
`to switchable polarization rotating element 70 in FIG. 16 of Silverstein and to the pi-
`
`cells in prior art ZScreen 103 in admitted prior art FIG. 1A of the '455 patent since
`
`both element 70 and the pi-cells also require the input of p-polarized light. FIG. 5 of
`
`the Silverstein '373 patent is reproduced below followed by portions of its description.
`
`Masterlmage 3D, Inc. and Masterlmage 3D Asia, LLC - Exhibit 1009
`
`20
`
`REALD INC.
`Exhibit 2169-20
`MASTERIMAGE 3D, et al. v REALD INC.
`IPR2015-00035
`
`
`
`Inter Partes Review of U.S. Patent No. 8,220,934
`Expert Declaration of Matthew S. Brennesholtz
`
`98
`
`94
`
`66
`
`110
`
`FIG. 5
`
`"Referring to FIG. 5. .
`polarizer 96 -transmits light having p-
`polarization and reflects light having s-polarization. A mirror 98, or
`reflective polarization sensitive coating, then directs the light having s-
`polarization through a half wave plate 94. Half wave plate 94 converts
`this incident light to p-polarization. In this way, polarized illumination
`beam 66 at lens 34 has the same polarization state. Thus, substantially all
`of the light output from light source 20 is converted to light having the
`same polarization state for modulation."
`Ex. 1013, Silver
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