UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`JST Performance, Inc. d/b/a/ Rigid Industries
`Petitioner,
`v.
`
`KONINKLIJKE PHILIPS ELECTRONICS N.V.
`Patent Owner
`_______________________
`
`Patent No. 6,586,890 (Claims 1-13, 15-21 and 23-29)
`Issued: July 1, 2003
`Inventors: Young-Kee Min, et al.
`Title: LED Driver Circuit with PWM Output
`Inter Partes Review No. IPR2014-_____
`
`DECLARATION OF DAVID C. RAMSPERGER
`UNDER 37 C.F.R. § 1.68
`
`I, David C. Ramsperger, do hereby declare:
`
`1.
`
`I am making this declaration at the request of JST Performance, Inc.
`
`d/b/a/ Rigid Industries in the matter of the Inter Partes Review of U.S. Patent No.
`
`6,586,890 (“the ‘890 Patent”), RIGID-1001, to Young-Kee Min et al.
`
`2.
`
`I am being compensated for my work in this matter. My
`
`compensation in no way depends upon the outcome of this proceeding.
`
`3.
`
`In the preparation of this declaration, I have studied:
`
`a.
`
`The ‘890 Patent, RIGID-1001;
`
`RIGID-1006 page(cid:3)1(cid:3)
`(cid:3)
`
`
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`JST Performance, Inc. d/b/a/ Rigid Industries
`Petitioner,
`v.
`
`KONINKLIJKE PHILIPS ELECTRONICS N.V.
`Patent Owner
`_______________________
`
`Patent No. 6,586,890 (Claims 1-13, 15-21 and 23-29)
`Issued: July 1, 2003
`Inventors: Young-Kee Min, et al.
`Title: LED Driver Circuit with PWM Output
`Inter Partes Review No. IPR2014-_____
`
`DECLARATION OF DAVID C. RAMSPERGER
`UNDER 37 C.F.R. § 1.68
`
`I, David C. Ramsperger, do hereby declare:
`
`1.
`
`I am making this declaration at the request of JST Performance, Inc.
`
`d/b/a/ Rigid Industries in the matter of the Inter Partes Review of U.S. Patent No.
`
`6,586,890 (“the ‘890 Patent”), RIGID-1001, to Young-Kee Min et al.
`
`2.
`
`I am being compensated for my work in this matter. My
`
`compensation in no way depends upon the outcome of this proceeding.
`
`3.
`
`In the preparation of this declaration, I have studied:
`
`a.
`
`The ‘890 Patent, RIGID-1001;
`
`RIGID-1006 page(cid:3)1(cid:3)
`(cid:3)
`
`
`
`b.
`
`U.S. Patent No. 5,835,250 to Kanesaka et al. (“Kanesaka”),
`
`RIGID-1002;
`
`c.
`
`The printed publication entitled “Current Mode PWM
`
`Controller” for a Series UC2842 controller, published October
`
`1998 by STMicroelectronics (“the ST Publication”), RIGID-
`
`1003; and
`
`d.
`
`File history of the ‘890 Patent, RIGID-1004.
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`a.
`
`b.
`
` The documents listed above;
`
`The relevant legal standards, including the standard for
`
`obviousness provided in KSR International Co. v. Teleflex, Inc.,
`
`550 U.S. 398 (2007), and any additional authoritative
`
`documents cited in the body of this declaration; and
`
`c.
`
`My knowledge and experience based upon my work in the area
`
`as described below.
`
`Qualifications and Professional Experience
`
`5.
`
`My qualifications are set forth in my curriculum vitae, RIGID-1005.
`
`As set forth in my curriculum vitae, I have over 35 years experience in Electronics
`
`Systems Design.
`
`RIGID-1006 page(cid:3)2(cid:3)
`(cid:3)
`
`
`
`6.
`
`My 35 years of experience in Electronic Systems Design includes
`
`over 34 years of design and development of Pulse Width Modulation (PWM)
`
`techniques for illuminated light emitting diode (LED) arrays and other
`
`technologies, such as Switch-Mode Power Supplies (SMPS). I am a named
`
`inventor on 3 U.S. patents, 2 of which are related to PWM-based drive technology.
`
`7.
`
`I am familiar with the knowledge and capabilities of one of ordinary
`
`skill in the design of electronic systems. Specifically, my engineering work as co-
`
`founder at Computers Unlimited during the years of 1978-1983 required extensive
`
`innovation in the areas of the use of Microcontrollers and LED Displays in
`
`Automotive products, including Sunlight Viewable Automatic Dimming LED
`
`Displays using PWM dimming. Unless otherwise stated, my testimony below
`
`refers to the knowledge of one of ordinary skill in the electronic systems design
`
`arts during the relevant time period, which includes the priority date of the ‘890
`
`Patent.
`
`8.
`
`In my opinion, the level of ordinary skill in the art for the ‘890 Patent
`
`is 1) one who holds a bachelor’s degree in electrical engineering with two or more
`
`years experience; or 2) one who has at least ten years of experience researching
`
`and designing electronic systems with an emphasis on LED-based illumination
`
`systems and associated LED driver architectures.
`
`RIGID-1006 page(cid:3)3(cid:3)
`(cid:3)
`
`
`
`Relevant Legal Standards
`
`9.
`
`I have been asked to provide my opinions regarding whether the
`
`claims of the ‘890 Patent are anticipated or would have been obvious to a person
`
`having ordinary skill in the art at the time of the alleged invention, in light of the
`
`prior art. It is my understanding that, to anticipate a claim under 35 U.S.C. § 102,
`
`a reference must teach every element of the claim. Further, it is my understanding
`
`that a claimed invention is unpatentable under 35 U.S.C. § 103 if the differences
`
`between the invention and the prior art are such that the subject matter as a whole
`
`would have been obvious at the time the invention was made to a person having
`
`ordinary skill in the art to which the subject matter pertains. I also understand that
`
`the obviousness analysis takes into account factual inquiries including the level of
`
`ordinary skill in the art, the scope and content of the prior art, and the differences
`
`between the prior art and the claimed subject matter.
`
`10.
`
`It is my understanding that the Supreme Court of the United States has
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: combining prior art elements according to known methods to yield
`
`predictable results; simple substitution of one known element for another to obtain
`
`predictable results; a predictable use of prior art elements according to their
`
`established functions; applying a known technique to a known device (method or
`
`RIGID-1006 page(cid:3)4(cid:3)
`(cid:3)
`
`
`
`product) ready for improvement to yield predictable results; choosing from a finite
`
`number of identified, predictable solutions, with a reasonable expectation of
`
`success; and some teaching, suggestion, or motivation in the prior art that would
`
`have led one of ordinary skill to modify the prior art reference or to combine prior
`
`art reference teachings to arrive at the claimed invention. My analysis of the ‘890
`
`Patent is set forth below.
`
`Background of the ‘890 Patent
`
`11.
`
`The ‘890 Patent relates to an “LED Driver Circuit with PWM
`
`Output.” (‘890 Patent, Title). Specifically, the ‘890 Patent teaches an LED driver
`
`circuit comprising a power supply (52) that supplies power for LED array (54) and
`
`is controlled by PWM control IC (56) and low frequency oscillator (64). The
`
`PWM control IC (56) provides a high frequency periodic drive signal of varying
`
`pulse width to direct the power supply (52) to supply power as required by the
`
`LED array (54) in response to a feedback signal from comparator (58), the
`
`feedback signal indicating a difference between sensed current (60) in LED array
`
`(54) and reference signal (62). Low frequency oscillator (64) provides a low
`
`frequency oscillating signal to the power supply (52) and the PWM control IC
`
`(56), where the low frequency oscillating signal oscillates between a low state and
`
`a high state. In the low state, power from power supply (52) to the LED array (54)
`
`is blocked. In the high state, PWM control IC (56) provides a pulse width
`
`RIGID-1006 page(cid:3)5(cid:3)
`(cid:3)
`
`
`
`modulated (PWM) signal to control a magnitude of current supplied to LED array
`
`(54) from power supply (52) by varying a pulse width of the current provided by
`
`power supply (52). (‘890 Patent, 2:1-37). The following figure from the ‘890
`
`Patent illustrates this system:
`
`12.
`
`The ‘890 Patent has 31 claims total, which are reproduced below:
`
`1. A system for supplying power for an LED array, said system
`
`comprising: an oscillator generating an oscillating signal, the
`
`oscillating signal having a first state and a second state; and a power
`
`supply operatively coupled to the oscillator, the power supply
`
`providing output power and being responsive to the oscillating signal;
`
`wherein said power supply supplies the output power to the LED
`
`array when the oscillating signal is in the first state and does not
`
`RIGID-1006 page(cid:3)6(cid:3)
`(cid:3)
`
`
`
`supply the output power to the LED array when the oscillating signal
`
`is in the second state.
`
`2. The system of claim 1, wherein the output power is pulse width
`
`modulated power.
`
`3. The system of claim 1, wherein the frequency of the power supply
`
`is about 20 kHz.
`
`4. The system of claim 1, wherein the frequency of the oscillating
`
`signal is much lower than the frequency of the power supply.
`
`5. The system of claim 1, wherein the duty cycle of the oscillating
`
`signal is about 10 per cent.
`
`6. The system of claim 1, wherein the frequency of the oscillating
`
`signal is about 200 to 300 Hertz.
`
`7. A system for supplying power for an LED array, said system
`
`comprising: means for sensing current to the LED array, said current
`
`sensing means generating a sensed current signal; means for
`
`generating a reference signal; means for comparing the sensed current
`
`signal to the reference signal, said comparing means generating a
`
`feedback signal; means for modulating pulse width responsive to the
`
`RIGID-1006 page(cid:3)7(cid:3)
`(cid:3)
`
`
`
`feedback signal, said pulse width modulating means generating a
`
`drive signal; and means for supplying power responsive to the drive
`
`signal, said power supplying means supplying current to the LED
`
`array.
`
`8. The system of claim 7, further comprising: means for low
`
`frequency oscillating, said low frequency oscillating means generating
`
`an oscillating signal having a first state and a second state; and said
`
`power supplying means being responsive to the oscillating signal, said
`
`power supplying means supplying current to the LED array during the
`
`first state and blocking current to the LED array during the second
`
`state.
`
`9. The system of claim 8, wherein the frequency of the oscillating
`
`signal is much lower than the frequency of the drive signal.
`
`10. The system of claim 8, wherein the duty cycle of the oscillating
`
`signal is about 10 per cent.
`
`11. The system of claim 8, wherein the frequency of the oscillating
`
`signal is about 200 to 300 Hertz.
`
`RIGID-1006 page(cid:3)8(cid:3)
`(cid:3)
`
`
`
`12. The system of claim 8, wherein said pulse width modulating
`
`means is responsive to the oscillating signal from the low frequency
`
`oscillating means; and wherein said pulse width modulating means
`
`supplies the drive signal to said power supplying means during the
`
`first state and blocks the drive signal to said power supplying means
`
`during the second state.
`
`13. The system of claim 12, wherein said pulse width modulating
`
`means synchronizes the drive signal from said pulse width modulating
`
`means with the oscillating signal from said low frequency oscillating
`
`means.
`
`14. The system of claim 7, further comprising: means for indicating
`
`the LED array is inoperable.
`
`15. A method of supplying power to an LED array, said method
`
`comprising: sensing current to the LED array and generating a sensed
`
`current signal; generating a reference signal; comparing the sensed
`
`current signal to the reference signal; generating a feedback signal
`
`based on the difference between the sensed current signal and the
`
`reference signal; generating a pulse width modulated drive signal
`
`RIGID-1006 page(cid:3)9(cid:3)
`(cid:3)
`
`
`
`based on the feedback signal; and supplying current to the LED array
`
`in response to the pulse width modulated drive signal.
`
`16. The method of claim 15, further comprising: generating an
`
`oscillating signal having a first state and a second state; and supplying
`
`current to the LED array when the oscillating signal is in the first state
`
`and blocking current to the LED array when the oscillating signal is in
`
`the second state.
`
`17. The method of claim 16, wherein the frequency of the oscillating
`
`signal is much lower than the frequency of the pulse width modulated
`
`drive signal.
`
`18. The method of claim 16, wherein the duty cycle of the oscillating
`
`signal is about 10 per cent.
`
`19. The method of claim 16, wherein the frequency of the oscillating
`
`signal is about 200 to 300 Hertz.
`
`20. The method of claim 16, wherein a generation of a pulse width
`
`modulated power signal based on the feedback signal includes:
`
`generating a pulse width modulated power signal when the oscillating
`
`RIGID-1006 page(cid:3)10(cid:3)
`(cid:3)
`
`
`
`signal is in the first state; and blocking the pulse width modulated
`
`power signal when the oscillating signal is in the second state.
`
`21. The method of claim 20, further comprising: synchronizing the
`
`pulse width modulated drive signal with the oscillating signal.
`
`22. The method of claim 15, further comprising: monitoring the LED
`
`array; and indicating when the LED array is inoperable.
`
`23. A circuit for supplying power to an LED array comprising: a
`
`power supply 52, the power supply 52 supplying current to the LED
`
`array 54 and being responsive to a drive signal; a current sensor 60 for
`
`sensing current to the LED array 54, the current sensor 60 generating
`
`a sensed current signal; a reference current source 62 for generating a
`
`reference signal; a comparator 58 for comparing the sensed current
`
`signal to the reference signal, the comparator 58 generating a
`
`feedback signal; and a PWM control IC 56 responsive to the feedback
`
`signal, the PWM control IC 56 generating the drive signal.
`
`24. The circuit of claim 23, further comprising: a low frequency
`
`oscillator, the low frequency oscillator generating an oscillating signal
`
`having a first state and a second state; and wherein said power supply
`
`is responsive to the oscillating signal, said power supply supplying
`RIGID-1006 page(cid:3)11(cid:3)
`(cid:3)
`
`
`
`current to the LED array during the first state and blocking current to
`
`the LED array during the second state.
`
`25. The circuit of claim 24, wherein the frequency of the oscillating
`
`signal is much lower than the frequency of the drive signal.
`
`26. The circuit of claim 24, wherein the duty cycle of the oscillating
`
`signal is about 10 per cent.
`
`27. The circuit of claim 24, wherein the frequency of the oscillating
`
`signal is about 200 to 300 Hertz.
`
`28. The circuit of claim 24, wherein said PWM control IC is
`
`responsive to the oscillating signal from the low frequency oscillator;
`
`and wherein said PWM control IC supplies the drive signal to said
`
`power supply during the first state and blocks the power signal to said
`
`power supply during the second state.
`
`29. The circuit of claim 28, wherein said PWM control IC
`
`synchronizes the power signal from said PWM control IC with the
`
`oscillating signal from the low frequency oscillator.
`
`RIGID-1006 page(cid:3)12(cid:3)
`(cid:3)
`
`
`
`30. The circuit of claim 23, further comprising: an LED monitor, said
`
`LED monitor generating an LED array inoperable signal when said
`
`LED array is inoperable.
`
`31. The circuit of claim 23, wherein said power supply is selected
`
`from a group consisting of a buck-boost power supply, a boost power
`
`supply, a buck power supply, and a flyback converter.
`
`13.
`
`The application leading to the ‘890 Patent was filed on December 5,
`
`2001 (“Time of the Invention”). The Examiner issued a first office action on
`
`November 6, 2002, in which claims 1-31 were examined and rejected as being
`
`obvious under 35 U.S.C. § 103 over U.S. Patent No. 6,362,578 to Swanson et al.
`
`(RIGID-1004 at page 31). In the response filed February 6, 2003, claims 1-31
`
`were amended. (RIGID-1004 at page 309). A notice of allowance was mailed on
`
`April 15, 2003. (RIGID-1004 at page 528). The ‘890 Patent issued on July 1,
`
`2003, as a result of payment of the issue fee on April 18, 2003.
`
`Summary of Opinions
`
`14.
`
`In my opinion, the claims of the ‘890 Patent would have been
`
`anticipated and/or obvious to a person of ordinary skill in the art at the time of the
`
`invention of the ‘890 Patent.
`
`RIGID-1006 page(cid:3)13(cid:3)
`(cid:3)
`
`
`
`15. By at least mid-1995, engineers already knew how to create a light
`
`emitting diode (LED) driver with pulse width modulation (PWM) output. For
`
`example, the “Kanesaka” reference, U.S. Patent No. 5,835,250, RIGID-1002,
`
`describes a device for driving a laser diode (LD), or a light emitting diode (LED),
`
`by varying the pulse width of the drive signal. FIG. 1 of the Kanesaka reference
`
`illustrates this system:
`
`As shown above, the current signal provided to LD 11 by power supply 19 is
`
`controlled by an oscillator signal “DATA IN,” pulse width controlling unit 20 and
`
`high-speed pulse controlling unit 21. A feedback mechanism detects the current
`
`conducted by LD 11, compares the detected current to a reference signal and
`
`generates a pulse-width-controlled current signal from power supply 19 in
`
`response to the comparison. Driving signal unit 13 either enables or disables the
`
`RIGID-1006 page(cid:3)14(cid:3)
`(cid:3)
`
`
`
`pulse-width-controlled current signal from power supply 19 depending upon the
`
`binary logic value of oscillator signal “DATA IN.” I discuss Kanesaka in more
`
`detail below and explain why it anticipates and/or renders obvious the claims of the
`
`‘890 Patent.
`
`Anticipation and Obviousness of the ‘890 Patent in View of Kanesaka
`
`16.
`
`The Kanesaka reference is entitled “Device for Driving Light
`
`Emitting Element.” Kanesaka was filed on February 26, 1996 with a priority date
`
`of August 23, 1995, and issued on November 10, 1998. It is my opinion, claims 1-
`
`13, 15-21 and 23-29 of the ‘890 Patent are anticipated and/or rendered obvious in
`
`view of Kanesaka for the reasons set forth below.
`
`Claim 1: A system for supplying power for an LED array, said system
`
`comprising
`
`17.
`
` Kanesaka teaches a system suitable for supplying power for an LED
`
`array. In the Background of the Invention, Kanesaka notes “a light emitting
`
`element such as a laser diode (referred to as "LD" hereinafter) is driven on the
`
`basis of an electric signal to generate an optical signal ….” (Kanesaka, 1:14-17).
`
`Kanesaka’s disclosure and invention were directed to laser diodes, which function
`
`as a light emitting element driven by current. (Kanesaka, 6:31-32). Kanesaka
`
`further acknowledges that other types of light emitting elements, such as light
`
`RIGID-1006 page(cid:3)15(cid:3)
`(cid:3)
`
`
`
`emitting diodes, may be used instead of laser diodes in substantially the same way.
`
`(Kanesaka, 15:54-57). A person of ordinary skill in the art at the Time of the
`
`Invention would have been motivated to drive more than a single LED in order to
`
`generate a wider range of optical power, thereby being adaptable over a wider
`
`range of applications. (See, for example, Kanesaka, 2:22-25). Power provisioning
`
`for an LED is very similar to power provisioning for an LD because both diode
`
`types exhibit an exponential relationship between the forward voltage applied
`
`across the diode junction and the forward current conducted through the diode
`
`junction, where minute variations in forward voltage may yield large variations in
`
`forward current. Accordingly, both diode types require a power control
`
`methodology, such as a PWM methodology, that is able to regulate the diode’s
`
`forward current between minimum and maximum forward current limits.
`
`Furthermore, the Kanesaka driver can be used to drive either a single LED, or
`
`multiple LEDs, as a matter of design choice. One of ordinary skill in the art, for
`
`example, knows that a string of LEDs connected in series to form an LED array
`
`increases the minimum drive voltage required to illuminate the LED array and,
`
`therefore, knows to increase the minimum drive voltage of the LED driver
`
`accordingly. Thus, the system described throughout in Kanesaka and as
`
`specifically illustrated in FIG. 1 is a system suitable for supplying power for one
`
`LED or a multiple LED array.
`
`RIGID-1006 page(cid:3)16(cid:3)
`(cid:3)
`
`
`
`an oscillator generating an oscillating signal, the oscillating signal having
`
`a first state and a second state
`
`18.
`
`This limitation is inherent in Kanesaka because Kanesaka’s “DATA
`
`IN” signal (see analysis portion of Claim Chart [1.1], Challenge #1 page 54) must
`
`be supplied from a component capable of supplying binary data having first and
`
`second values, which is an oscillating signal that oscillates between first and
`
`second states. Kanesaka teaches that the signal data input (DATA IN) is supplied
`
`from the outside and that the signal data is binary data, which oscillates between
`
`high and low logic levels. (Kanesaka, 6:37-42). Accordingly, in order for signal
`
`DATA IN to exist and to perform its function, a device such as an oscillator, must
`
`necessarily be present to generate the signal DATA IN.
`
`19.
`
`This limitation is implicit within Kanesaka because one of ordinary
`
`skill in the art would be reasonably expected to take into account the fact that an
`
`oscillating signal, such as DATA IN, would need to be emitted by an oscillating
`
`device, such as an oscillator. (See analysis portion of Claim Chart [1.1], Challenge
`
`#2 page 93). Furthermore, due to the disclosure of Kanesaka (see, for example,
`
`6:37-42) , one of ordinary skill in the art would be reasonably expected to infer that
`
`the oscillating signal generated by the oscillating device would be a binary signal
`
`having first and second states.
`
`RIGID-1006 page(cid:3)17(cid:3)
`(cid:3)
`
`
`
`a power supply operatively coupled to the oscillator, the power supply
`
`providing output power and being responsive to the oscillating signal
`
`20. Kanesaka teaches a power supply 19 (see analysis portion of Claim
`
`Chart [1.2], Challenge #1 page 56) operatively coupled to the oscillator and
`
`providing output power and being responsive to the oscillating signal. As taught
`
`by Kanesaka, “[t]he signal driving unit 13 drives, in an on-off manner, the current
`
`which is supplied from the DC power source 19 so as to drive the LD 11 in
`
`accordance with the signal data input (DATA IN) supplied from the outside.”
`
`(Kanesaka, 6:35-38).
`
`wherein said power supply supplies the output power to the LED array
`
`when the oscillating signal is in the first state and does not supply the output
`
`power to the LED array when the oscillating signal is in the second state
`
`21. Kanesaka teaches that power supply 19 supplies power according to
`
`the logic state of oscillating signal DATA IN. (See analysis portion of Claim Chart
`
`[1.3], Challenge #1 page 56). “The signal driving unit 13 drives, in an on-off
`
`manner, the current which is supplied from the DC power source 19 so as to drive
`
`the LD 11 in accordance with the signal data input (DATA IN) supplied from the
`
`outside. The signal data is binary data to be transmitted. It also can be thought that
`
`the signal driving unit 13 multiplies the current which is supplied to the LD 11
`
`RIGID-1006 page(cid:3)18(cid:3)
`(cid:3)
`
`
`
`from the DC power source 19 by the signal data of "1"/"0", namely, "H"/"L".”
`
`(Kanesaka, 6:35-42). Accordingly, when signal DATA IN is at a logic “0”, the
`
`signal driving unit 13 turns the current being supplied by DC power source 19 off
`
`and when signal DATA IN is at a logic “1”, the signal driving unit 13 turns the
`
`current being supplied by DC power source 19 on.
`
`Claim 2. The system of claim 1, wherein the output power is pulse width
`
`modulated power.
`
`22. Kanesaka teaches the output power is pulse width modulated power,
`
`where the current pulse width is increased or decreased by pulse width controlling
`
`unit 20. (See analysis portion of Claim Chart [2.0], Challenge #1 page 57). “In
`
`the high-speed pulse controlling unit 21, the pulse width duty ratio of the pulse line
`
`is controlled variably by the pulse width controlling unit 20.” (Kanesaka, 7:8-10).
`
`Furthermore, Kanesaka teaches “when the mean value output of the mean value
`
`detection unit 15 is larger than the output reference voltage of the reference voltage
`
`generation unit 16, the pulse width controlling unit 20 controls the high-speed
`
`pulse controlling unit 21 so that an on-duty of the pulse width is decreased, in
`
`order to decrease the mean value of the current supplied to the LD 11 to reduce the
`
`mean value output. As shown in FIG. 3, when the mean value output is smaller
`
`than the output reference voltage, the pulse width controlling unit 20 controls the
`
`RIGID-1006 page(cid:3)19(cid:3)
`(cid:3)
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`
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`high-speed pulse controlling unit 21 so that the on-duty of the pulse width is
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`enlarged, in order to increase the mean value of the current supplied to the LD 11
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`to enlarge the mean value output.” (Kanesaka, 7:34-46).
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`Claim 3. The system of claim 1, wherein the frequency of the power supply
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`is about 20 kHz.
`
`23.
`
`This limitation is a matter of design choice. (See analysis portion of
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`Claim Chart [3.0], Challenge #2 page 93). The ‘890 Patent teaches, for example,
`
`that an STMicroelectronics PWM controller having part number UC2842 may be
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`used. (‘890 Patent, 3:19-20). Per FIG. 4 of the ST Publication (see analysis
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`portion of Claim Chart [3.0] of Challenge #2 page 93), the designer is free to
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`choose the frequency of operation of the UC2842 device through selection of RT
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`and CT. Selecting RT = 10K, for example, yields a value of CT = 8600 pF for a
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`power supply frequency of 20 kHz. Such resister and capacitor values would have
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`been readily available in mid-1995.
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`Claim 4. The system of claim 1, wherein the frequency of the oscillating
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`signal is much lower than the frequency of the power supply.
`
`24. Kanesaka teaches that the power source 19 is controlled by the high-
`
`speed pulse controlling unit 21 at a period that is much shorter than the period of
`
`the signal data. (See analysis portion of Claim Chart [4.0], Challenge #1 page 58).
`RIGID-1006 page(cid:3)20(cid:3)
`(cid:3)
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`“The current which is supplied to the LD 11 from the DC power source 19 is
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`controlled in an on-off manner to be pulsed by the high-speed pulse controlling
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`unit 21 at the sufficiently short period in comparison with the signal data of the
`
`binary data to be transmitted. At the same time, the signal driving unit 13 in an on-
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`off manner, multiply-controls the DC current which is supplied to the LD 11
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`through the high-speed pulse controlling unit [21] and makes it function as a signal
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`pulse current.” (Kanesaka, 7:25-33).
`
`25.
`
`The oscillating signal exhibits a waveform whose period is much
`
`longer than the period of the power supply signal. Since the period of a signal
`
`exhibits an inverse relationship to its frequency, the frequency of the oscillating
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`signal is much lower than the frequency of the power supply signal.
`
`Claim 5. The system of claim 1, wherein the duty cycle of the oscillating
`
`signal is about 10 per cent.
`
`26.
`
`This limitation is a matter of design choice. (See analysis portion of
`
`Claim Chart [5.0], Challenge #2 page 94). For example, Kanesaka teaches that
`
`“the signal driving unit 13 drives, in an on-off manner, the current which is
`
`supplied from the DC power source 19 so as to drive the LD 11 in accordance with
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`the signal data input (DATA IN) supplied from the outside. The signal data is
`
`binary data to be transmitted.” (Kanesaka, 6:35-39). A data scheme could, for
`
`RIGID-1006 page(cid:3)21(cid:3)
`(cid:3)
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`
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`example, be selected by the designer such that a particular data stream may be
`
`represented by an oscillating signal having a 10 percent duty cycle.
`
`Claim 6. The system of claim 1, wherein the frequency of the oscillating
`
`signal is about 200 to 300 Hertz.
`
`27.
`
`This limitation is a matter of design choice. (See analysis portion of
`
`Claim Chart [6.0], Challenge #2 page 94). For example, Kanesaka teaches that
`
`“[t]he high-speed pulse controlling unit 21 controls, in an on-off manner, the
`
`current which is supplied to the LD 11 from the DC power source 19 at the
`
`sufficiently short period in comparison with the signal data so as to pulse the
`
`current.” (Kanesaka, 7:4-7). Since a signal’s period is inversely related to its
`
`frequency, Kanesaka teaches that the frequency of the high-speed pulse controlling
`
`unit (such as 20 kHz as taught in the ‘890 Patent) is much higher than the
`
`frequency of the signal data (such as 200-300 Hz as taught in the ‘890 Patent).
`
`Such a frequency difference represents two frequency decades of separation, which
`
`would conform to sound engineering design principles.
`
`Claim 7. A system for supplying power for an LED array,
`
`said system comprising.
`
`28. Kanesaka teaches a system suitable for supplying power for an LED
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`array. In the Background of the Invention, Kanesaka notes “a light emitting
`RIGID-1006 page(cid:3)22(cid:3)
`(cid:3)
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`
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`element such as a laser diode (referred to as "LD" hereinafter) is driven on the
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`basis of an electric signal to generate an optical signal ….” (Kanesaka, 1:14-17).
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`Kanesaka’s disclosure and invention were directed to laser diodes, which function
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`as a light emitting element driven by current. (Kanesaka, 6:31-32). Kanesaka
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`further acknowledges that other types of light emitting elements, such as light
`
`emitting diodes, may be used instead of laser diodes in substantially the same way.
`
`(Kanesaka, 15:54-57). (See analysis portion of Claim Chart [7.0], Challenge #1
`
`page 59). A person of ordinary skill in the art at the Time of the Invention would
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`have been motivated to drive more than a single LED in order to generate a wider
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`range of optical power, thereby being adaptable over a wider range of applications.
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`(See, for example, Kanesaka, 2:22-25). Power provisioning for an LED is very
`
`similar to power provisioning for an LD because both diode types exhibit an
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`exponential relationship between the forward voltage applied across the diode
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`junction and the forward current conducted through the diode junction, where
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`minute variations in forward voltage may yield large variations in forward current.
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`Accordingly, both diode types require a power control methodology, such as a
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`PWM methodology, that is able to regulate the diode’s forward current between
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`minimum and maximum forward current limits. Furthermore, the Kanesaka driver
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`can be used to drive either a single LED, or multiple LEDs, as a matter of design
`
`choice. One of ordinary skill in the art, for example, knows that a string of LEDs
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`RIGID-1006 page(cid:3)23(cid:3)
`(cid:3)
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`
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`connected in series to form an LED array increases the minimum drive voltage
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`required to illuminate the LED array and, therefore, knows to increase the
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`minimum drive voltage of the LED driver accordingly. Thus, the system described
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`throughout in Kanesaka and as specifically illustrated in FIG. 1 is a system suitable
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`for supplying power for one LED or a multiple LED array.
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`means for sensing current to the LED array
`
`29. Kanesaka teaches a means (12, 18) for sensing current to LED 11 (see
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`analysis portion of Claim Chart [7.1], Challenge #1 page 59). “When the LD 11
`
`emits light, the light of the LD 11 is detected by the PD 12 for monitoring, and the
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`optical voltage corresponding to the optical intensity of the LD 11 occurs between
`
`the terminals of the resistance 18. The mean value of the optical voltage is
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`calculated in the mean value detection unit 15.” (Kanesaka, 7:12-17).
`
`Accordingly, LD 11 of Kanesaka generates a light intensity that is directly
`
`proportional to the average magnitude of current flowing through LD 11. Since
`
`the intensity of light generated by LD11 is detected by PD 12 and since that
`
`intensity is directly proportional to the current flowing through LD 11, the average
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`magnitude of current flowing through LD 11 is sensed as a voltage across sense
`
`resistor 18.
`
`said current sensing means generating a sensed current signal
`
`RIGID-1006 page(cid:3)24(cid:3)
`(cid:3)
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`
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`30. Kanesaka teaches a means (15) for generating a sensed current signal
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`(see analysis portion of Claim Chart [7.2], Challenge #1 page 60). “When the LD
`
`11 emits light, the light of the LD 11 is detected by the PD 12 for monitoring, and
`
`the optical voltage corresponding to the optical intensity of the LD 11 occurs
`
`between the terminals of the resistance 18. The mean value of the optical voltage is
`
`calculated in the mean value detection unit 15.” (Kanesaka, 7:12-17).
`
`Accordingly, LD 11 of Kanesaka generates a light intensity that is directly
`
`proportional to the average magnitude of current flowing through LD 11. Since
`
`the intensity of light generated by LD11 is detected by PD 12 and since that
`
`intensity is directly proportional to the current flowing through LD 11, the average
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`magnitude of current flowing through LD 11 is sensed as a voltage across sense
`
`resistor 18, which is then provided to mean value detection unit 15 as the sensed
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`current signal.
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`means for generating a reference signal
`
`31. Kanesaka teaches a means (16) for generating a reference signal (see
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`analysis portion of Claim Chart [7.3], Challenge #1 page 61). “The reference
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`voltage generation unit 16 generates a reference voltage corresponding to the
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`desired mean value.” (Kanesaka, 6:60-61).
`
`RIGID-1006 page(cid:3)25(cid:3)
`(cid:3)
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