Claim
`1.0 An electronic device
`comprising:
`1.1 a solid-state device which
`serves as a primary light source;
`
`1.2 and a population of
`photoluminescent quantum dots
`dispersed in a host matrix,
`
`BHARGAVA / Ground 1
`Bhargava is directed to devices for emitting
`light. Exh. 1004, e.g., 5:27-40.
`Bhargava includes a light source, such as
`element 23 of Figure 3. Bhargava is not
`specific to the type of light source used. For
`example, the Background section states
`“Devices which respond to shorter
`wavelength incident radiation to emit
`radiation of a longer wavelength are known.”
`Id., 1:10-13. Solar radiation is one example.
`Id., 1:23-27. Bhargava also states that the
`nanocrystal films can be used in applications
`wherever colored glass is used, including
`toys, and clocks. To enhance the effect, a
`black light (UV) can be included in the
`structure to enhance the glow. Id., 5:27-31.
`
`To the extent this limitation is not met by
`Bhargava, it would be obvious to use a solid-
`state light source, such as the LEDs taught in
`the conventional phosphor references
`(discussed below in section VII.E.), since
`Bhargava states that the films can be used
`wherever colored glass is used.
`Bhargava teaches populations of
`photoluminescent QDs dispersed in a host
`matrix. Bhargava states that the host matrix
`is a polymer with an index of reflection that
`matches that of the substrate being coated.
`Exh. 1004, 3: 47-51. Bhargava also states
`that the QDs can be coated with a
`methacrylic acid surfactant, dispersed in an
`organic binder, and applied to a substrate to
`form a thin film. Id., 5:55 – 6:2. Bhargava
`also refers to Bhargava II, which describes
`forming polymer matrices containing the
`QDs by coating the QD with methacrylic
`acid surfactant and photopolymerizing the
`surfactant. Exh. 1006, p. 2, col. 1.
`
`(cid:3)
`
`1 of 38
`
`Nanoco Technologies, Ltd
`IPR2015-00532
`EXHIBIT 1021
`
`

`
`Claim
`1.3 at least a portion of the
`quantum dots having a band gap
`energy smaller than the energy of
`at least a portion of the light
`produced by the source,
`
`1.4 and the matrix allowing light
`from the source to pass
`therethrough.
`
`2. The device of claim 1, where
`the quantum dots comprise at
`least one material selected from
`the group consisting of CdS,
`CdSe, CdTe, ZnS, and ZnSe.
`
`4. The device of claim 1, where
`the host matrix comprises at least
`one material selected from the
`group consisting of polymers,
`silica glasses, and silica gels.
`
`6. The device of claim 1, where
`the quantum dots comprise a
`coating having an affinity for the
`host matrix.
`
`BHARGAVA / Ground 1
`The QDs of Bhargava have band gap
`energies smaller than the energy of light
`from the primary light source because the
`QDs absorb light from the primary light
`source and reemit light of a lower energy.
`Exh. 1003, Hines Dec., ¶¶ 9-10. The relative
`band gap energies of the structure illustrated
`in Fig. 4 are illustrated in Fig. 5. Exh. 1004,
`Fig. 5 and 4:63-68.
`The matrix allows light from the source to
`pass through. The transmitted light 24 of
`Fig. 3 is a mixture of light emitted by the
`QDs and light from the primary light source.
`Exh. 1004, Fig. 3 and 4:5-10.
`Bhargava discloses ZnS, ZnSe, CdS, and
`CdSe QDs. Exh.1004, e.g., Fig. 4.
`
`Bhargava teaches that the surfaces of the
`QDs are coated with a methacrylic acid
`surfactant, which a POSITA would recognize
`is a polymerizable monomer. Exh. 1004, 5:
`55-58; see also Exh. 1003, Hines Decl., ¶ 17.
`Bhargava also refers to Bhargava II, which
`describes forming polymer matrices
`containing the QDs by coating the QD with
`methacrylic acid surfactant and
`photopolymerizing the surfactant. Exh.
`1006, Bhargava II, p. 2, col. 1.
`Bhargava teaches that the surfaces of the
`QDs are coated with a methacrylic acid
`surfactant, which a person of skill in the art
`would recognize is a polymerizable
`monomer. Exh.1004, 5:55-58, see also Exh.
`1003, Hines Decl., ¶ 17. Bhargava also
`references Bhargava II for additional
`information about depositing layers of QDs.
`
`(cid:3)
`
`2 of 38
`
`

`
`Claim
`
`7. The device of claim 6, where
`the host matrix comprises a
`polymer and the coating
`comprises a related monomer.
`
`8. The device of claim 1, where
`the primary light source is
`selected from the group
`consisting of a light-emitting
`diode, a solid-state laser, and a
`solid-state ultraviolet source.
`
`BHARGAVA / Ground 1
`Bhargava II teaches polymerizing the
`surfactant that is coated onto the QDs. Exh.
`1006, Bhargava II, p. 2, col. 1. The surface-
`bound methacrylic acid becomes
`incorporated into the poly(methacrylic acid)
`polymer matrix that results from
`polymerization of the surfactant and becomes
`part of the host matrix. Exh.1003, Hines
`Decl., ¶ 19.
`See Claim 6. Bhargava/Bhargava II teaches
`coating the QDs with methacrylic acid
`surfactant and photopolymerizing the
`surfactant to form a polymer matrix. The
`surface bound surfactant is the same type of
`monomer that ultimately forms the resulting
`polymer matrix, and is thus a “related
`monomer.”
`See discussion above regarding claim
`element 1.1. In Bhargava, any type of light
`source can be used. Bhargava also states that
`the nanocrystal films can be used in
`applications wherever colored glass is used,
`including toys, and clocks. To enhance the
`effect, a black light (UV) can be included in
`the structure to enhance the glow. Exh. 1004,
`5: 27-31. Whether the primary light source is
`solid-state is not significant; it is the energy
`of the primary light that causes the
`photoluminescence. Exh. 1003, Hines Dec. ¶
`10-14. To the extent this claim is not met by
`Bhargava, it would be obvious to use a solid-
`state light source, such as the LEDs taught in
`the conventional phosphor references. Exh.
`1003, Hines Dec., ¶ 26. The selection of a
`known material based on its suitability for its
`intended use supports a prima
`
`(cid:3)
`
`3 of 38
`
`

`
`Claim
`
`
`
`BHARGAVA / Ground 1
`facie obviousness determination. See MPEP
`2144.07 Bhargava and the conventional
`phosphor references are all directed to down-
`converting light. See discussion at VII.E.
`
`4 of 38
`
`
`
`(cid:3)
`
`

`
`Claim
`1 An electronic device
`comprising:
`
`a solid-state device which
`serves as a primary light
`source;
`
`and a population of
`photoluminescent quantum
`dots dispersed in a host
`matrix,
`
`at least a portion of the
`quantum dots having a band
`gap energy smaller than the
`energy of at least a portion of
`the light produced by the
`source,
`
`and the matrix allowing light
`from the source to pass
`therethrough.
`
`
`
`(cid:3)
`
`BURT / Ground 2
`Burt is directed to a system having a primary
`light source, such as a laser, integrated with an
`optical fiber containing QDs. Exh. 1007,
`abstract. The QDs produce luminescence in
`response to optical radiation from the primary
`light source. Id.
`The system described in Burt includes a
`semiconductor laser which is a solid-state
`device. The laser is used to excite the quantum
`dots contained in the colloidal material within
`the optical fiber. Exh.1007, p. 8, ll. 8-11.
`The system described in Burt includes an optical
`fiber containing a colloidal matrix within which
`QDs are dispersed. Burt describes embodiments
`wherein the matrix is a liquid, such as toluene,
`benzene, or nitrobenzene. Exh. 1007, p. 6, l. 31
`– p. 7, l. 1. Burt also describes using solids as a
`matrix material. Id., p. 11, ll. 4-6.
`Burt states that the QDs used therein have a
`band gap of 0.8–1.0 eV. Exh. 1007, p. 9, ll. 25
`– 30. Burt further states that the primary light
`source has a wavelength of 1.06 (cid:80)m. Id. Light
`having a wavelength of 1.06 corresponds to an
`energy of 1.17 eV, which is greater than the
`band gap of the QDs. Exh. 1003, Hines Dec. ¶
`21.
`
`The QDs described in Burt must have a band
`gap energy smaller than the energy of the light
`from the primary light source because the QDs
`absorb light from the primary light source and
`emit light at a lower wavelength. Exh. 1003,
`Hines Decl., ¶ 10.
`Burt states that incident light is propagated
`along the length of the core through the matrix.
`Exh. 1007, p. 8, ll. 14-19. The matrix must
`
`5 of 38
`
`

`
`Claim
`
`2. The device of claim 1,
`where the quantum dots
`comprise at least one material
`selected from the group
`consisting of CdS, CdSe,
`CdTe, ZnS, and ZnSe.
`
`3. The device of claim 2,
`where the quantum dots
`further comprise an overcoat
`of at least one material
`selected from the group
`consisting of ZnS, ZnSe, CdS,
`CdSe, CdTe, and MgSe.
`
`8. The device of claim 1,
`where the primary light source
`is selected from the group
`consisting of a light-emitting
`diode, a solid-state laser, and a
`solid-state ultraviolet source.
`
`10. The device of claim 1,
`wherein the quantum dots
`comprise an undoped
`semiconductor material.
`
`11. The device of claim 1,
`wherein the quantum dots
`photoluminensce light of a
`color characteristic of their
`sizes in response to light from
`the light source.
`
`BURT / Ground 2
`therefore allow light from the source to pass
`through.
`Burt teaches CdS, CdSe, CdTe, ZnS, and ZnSe
`QD. Exh. 1007, p. 7, ll. 3-6. Burt also teaches
`using QDs having a PbS core and an
`overcoating of CdSe. Exh. 1007, p. 10, ll. 16-
`20.
`
`Burt teaches using QDs having a PbS core and
`an overcoating of CdS or CdSe. Exh. 1007, p.
`10, ll. 16-20.
`
`Burt discloses a semiconductor laser light
`source which is a solid-state laser. Exh. 1007, p.
`8, ll. 8-11.
`
`The QDs of Burt are prepared by precipitation
`without doping. Exh. 1007, p. 7, ll. 3-12 and p.
`10, ll. 16-20.
`
`This element is merely a description of how
`QDs emit light. It was known that the emission
`of a QD is a function of its size. Exh. 1003,
`Hines Decl., ¶¶ 9-14. Thus, the color of light
`emitted by a QD is characteristic of the size of
`the QD. Burt recognizes this relationship
`because Burt, endeavoring to achieve a broad
`spectrum of emission, states that a spread in the
`sizes of QDs should be used. Exh. 1007, p. 8, ll.
`25-32.
`
`
`
`
`
`(cid:3)
`
`6 of 38
`
`

`
`Claim
`1. An electronic device comprising:
`
`a solid-state device which serves as a
`primary light source;
`
`and a population of photoluminescent
`quantum dots dispersed in a host matrix,
`
`LAWANDY/ Ground 3
`Lawandy describes light-emitting
`materials incorporating QDs for use
`in televisions, monitors, and flat
`panel displays, which are electronic
`devices. Exh. 1008, abstract.
`Lawandy teaches that QDs can be
`used as a replacement for
`conventional phosphors in such
`applications. Id.
`Lawandy describes a primary light
`source. In the exemplary
`embodiment, the primary light source
`is an arc lamp. To the extent an arc
`lamp is not considered a “solid-state
`device,” the choice to use a solid-
`state primary light source is a routine
`and obvious design choice.(cid:3) Whether
`the primary light source is solid-state
`is not significant; it is the energy of
`the primary light that causes the
`photoluminescence. Exh. 1003,
`Hines Dec. ¶ 10-14. For example,
`Butterworth discloses an LED light
`source for illuminating a phosphor.
`See II.A. above. A POSITA would
`have been motivated to combine
`Lawandy and Butterworth because
`they are both directed at illuminating
`a phosphor. Exh. 1003, Hines Dec., ¶
`26 Lawandy describes other
`excitation sources, such as an electron
`beam from a cathode ray tube and
`displays, such as flat panel display.
`Id., 6:23 - 29.
`Lawandy teaches a population of
`photoluminescent QD phosphors
`applied to the surface of a substrate.
`Exh.1008, Figs. 1-7 and entirety of
`Lawandy. Lawandy states that the
`
`(cid:3)
`
`7 of 38
`
`

`
`Claim
`
`at least a portion of the quantum dots
`having a band gap energy smaller than
`the energy of at least a portion of the
`light produced by the source,
`
`and the matrix allowing light from the
`source to pass therethrough.
`
`2. The device of claim 1, where the
`quantum dots comprise at least one
`material selected from the group
`consisting of CdS, CdSe, CdTe, ZnS,
`and ZnSe.
`
`LAWANDY/ Ground 3
`QD phosphors can be applied to the
`substrate using “conventional
`phosphor-type deposition methods.”
`Id. 4:61 – 63. A POSITA would
`recognize that “conventional
`phosphor-type deposition methods”
`include methods whereby phosphors
`are suspended in a matrix and applied
`to a substrate, as illustrated in
`Shimizu, Fig. 2 (attached as Exh.
`1009 and discussed in more detail in
`Section E, below). Exh. 1003, Hines
`Dec., ¶ 24.
`The QDs of Lawandy act as
`phosphors, absorbing light of a first
`wavelength and emitting light at a
`lower wavelength, as illustrated in
`Figs. 6 and 7 and described at 6:30 –
`57. Exh. 1008. The QDs absorb
`ultraviolet radiation and emit visible
`radiation. Id. Such
`absorption/emission is only possible
`because the QDs have band gap
`energy smaller than the energy of the
`light produced by the source. Exh.
`1003, Hines Decl., ¶¶ 8-10.
`QD phosphors would not be capable
`of absorbing light from the source if
`that light did not pass through the
`matrix material; the light must reach
`the QD for it to be absorbed.
`Lawandy uses CdS, CdSe, ZnS, and
`ZnSe QDs. Exh. 1008, 3:20 –4:30.
`
`3. The device of claim 2, where the
`quantum dots further comprise an
`
`Lawandy describes QDs overcoated
`with ZnSe. Exh. 1008, 4:15-21.
`
`(cid:3)
`
`8 of 38
`
`

`
`Claim
`overcoat of at least one material selected
`from the group consisting of ZnS, ZnSe,
`CdS, CdSe, CdTe, and MgSe.
`
`LAWANDY/ Ground 3
`
`4. The device of claim 1, where the host
`matrix comprises at least one material
`selected from the group consisting of
`polymers, silica glasses, and silica gels.
`
`Lawandy describes embodiments
`wherein QDs are dispersed directly in
`the top layers of a substrate such as
`glass. Exh. 1008, 5:3-11 and Fig. 4.
`
`5. The device of claim 1, where the host
`matrix comprises at least one polymer
`selected from the group consisting of
`polystyrene, polyimides, and epoxies.
`
`10. The device of claim 1, wherein the
`quantum dots comprise an undoped
`semiconductor material.
`
`11. The device of claim 1, wherein the
`quantum dots photoluminensce light of a
`color characteristic of their sizes in
`response to light from the light source.
`
`Lawandy also describes embodiments
`wherein the QDs are applied to a
`substrate using “conventional
`phosphor-type deposition methods.”
`Exh. 1008, 4:61-67. An example of
`such conventional phosphor-type
`deposition methods is provided by
`Shimizu, which teaches suspending
`conventional phosphors in a resin,
`such as an epoxy resin, so as to
`down-convert light emitted from an
`LED chip. Shimizu, Exh. 1009, Figs.
`1 and 2 and 16: 54-60. Thus, if claim
`5 is not anticipated, then it is at least
`obvious in view of Lawandy
`combined with Shimizu, since
`Lawandy explicitly points the reader
`to conventional phosphor techniques
`for depositing the QDs.
`Lawandy teaches both doped and
`undoped QDs. Exh.1008, 4: 36-39
`(“in some embodiments of the
`invention doping of the
`semiconductor core material with a
`luminescent center is not required.).”
`This element is merely a description
`of how QDs emit light. It was known
`that the emission of a QD is a
`function of the size of the QD. That
`relationship is explicitly stated in the
`
`(cid:3)
`
`9 of 38
`
`

`
`Claim
`
`
`
`
`
`LAWANDY/ Ground 3
`formula at col. 5, line 55 of Lawandy.
`See also Exh. 1003, Hines Decl., ¶¶
`10-14. Thus, the color of light
`emitted by a QD is characteristic of
`the size of the QD.
`
`(cid:3)
`
`10 of 38
`
`

`
`a solid-state device which serves as
`a primary light source;
`
`HAKIMI / Ground 4
`Claim
`1.0 An electronic device comprising: Hakimi is directed to a QD laser (an
`electronic device) having a plurality of
`QDs disposed in a host material and also
`having a pumping source for exciting the
`QDs. Exh. 1010, Abstract.
`Fig. 1 illustrates a QD laser, as described
`in Hakimi. The QD laser includes a
`pumping source 20, which is a light
`source for exciting QDs 14. Pumping
`source 20 is a primary light source laser.
`Exh. 10, 2:1-2. Hakimi is general as to
`the type of laser. Examples of lasers
`include solid state lasers, such as the
`semiconductor laser described in Burt.
`Exh. 1007, p. 8, ll. 4- 16.
`The QD laser illustrated in Fig. 1 includes
`a population of QDs 14 dispersed in a
`host material 12. Exh. 1010, 3: 31-46.
`The QDs absorb light from the pumping
`source and re-emit different colored light.
`Exh. 1010, 3:4-8. The QDs thus
`necessarily have a band gap energy
`smaller than the energy of the light
`produced by the pumping source. Exh.
`1003, Hines Decl., ¶ 10.
`The matrix necessarily allows light from
`the source to pass through, or else the
`QDs would not be excited by light from
`the light sources. The QD must absorb
`the light from the primary light source
`before the QD can emit See Exh. 1003 ¶
`10-14.
`Hakimi teaches ZnSe and CdSe QDs.
`Exh. 1010, 2: 64-68.
`
`and a population of
`photoluminescent quantum dots
`dispersed in a host matrix,
`at least a portion of the quantum
`dots having a band gap energy
`smaller than the energy of at least a
`portion of the light produced by the
`source,
`
`and the matrix allowing light from
`the source to pass therethrough.
`
`2. The device of claim 1, where the
`quantum dots comprise at least one
`material selected from the group
`consisting of CdS, CdSe, CdTe,
`ZnS, and ZnSe.
`
`(cid:3)
`
`11 of 38
`
`

`
`Claim
`4. The device of claim 1, where the
`host matrix comprises at least one
`material selected from the group
`consisting of polymers, silica
`glasses, and silica gels.
`
`8. The device of claim 1, where the
`primary light source is selected from
`the group consisting of a light-
`emitting diode, a solid-state laser,
`and a solid-state ultraviolet source.
`
`9. The device of claim 1, where the
`quantum dots have a size
`distribution having less than a 10%
`in diameter of the dots.
`
`10. The device of claim 1, wherein
`the quantum dots comprise an
`undoped semiconductor material.
`
`11. The device of claim 1, wherein
`the quantum dots photoluminensce
`light of a color characteristic of their
`sizes in response to light from the
`light source.
`
`
`
`
`
`HAKIMI / Ground 4
`Examples of host materials disclosed in
`Hakimi include polymers such as
`polymethylmethacrylate (PMMA). Exh.
`1010, 3: 8-10.
`
`Fig. 1 illustrates a QD laser, as described
`in Hakimi. The QD laser includes a
`pumping source 20, which is a light
`source for exciting QDs 14. Pumping
`source 20 is a primary light source laser.
`Exh. 1010, 2:1-2. Hakimi is general as to
`the type of laser. Examples of lasers
`include solid state lasers, such as the
`semiconductor laser described in Burt.
`1007, p. 8, ll. 4- 16.
`The broadest reasonable interpretation of
`“less than 10% in diameter” is that it
`means less than 10% in variation of
`diameter size. Hakimi teaches
`embodiments wherein the QDs are all of
`the same size. Exh. 1010, e.g. 1:67-68;
`claim 4.
`Hakimi teaches CdSe and ZnSe QDs.
`Exh. 1010, 2: 64-68. Hakimi does not
`mention that the QDs are doped.
`Therefore a POSITA would understand
`that those materials are not doped. Exh.
`1003, Hines Decl., ¶ 25.
`This element is merely a description of
`how QDs emit light. Hakimi teaches that
`the fluorescing wavelength of the QD can
`be changed as determined by the diameter
`of the QD, i.e. the color is characteristic
`of the size. Exh. 1010, 3: 1-4.
`
`(cid:3)
`
`12 of 38
`
`

`
`a solid-state device which serves as
`a primary light source;
`
`and a population of
`photoluminescent quantum dots
`dispersed in a host matrix,
`
`CPR / Ground 5
`Claim
`1. An electronic device comprising: Each of the conventional phosphor
`references illustrate an electronic lighting
`device having an essentially identical
`structure as the device(s) illustrated in the
`‘091 Patent. See Exh. 1009, Shimizu, Fig.
`1; Exh. 1011, Baretz, Fig. 1, and Exh.
`1012, Vriens, Fig. 2. The difference is
`that they use conventional phosphors
`rather than QDs.
`Each of the conventional phosphor
`references disclose a solid-state LED as a
`primary light source. See Shimizu, Fig. 1;
`Baretz, Fig. 1, and Vriens, Fig. 2, and
`descriptions thereof.
`Each of the conventional phosphor
`references teaches embodiments wherein
`conventional phosphors are dispersed in a
`host matrix. See Shimizu, Fig. 1; Baretz,
`Fig. 1, and Vriens, Fig. 2, and
`descriptions thereof. It would have been
`obvious to a POSITA to substitute QDs in
`place of the conventional phosphors, as
`illustrated by the teachings of Burt,
`Lawandy or Hakimi, wherein QDs are
`substituted in the place of conventional
`phosphors in optical devices.
`The QD phosphors described in Burt,
`Lawandy and Hakimi, as well as the
`conventional phosphors described in the
`conventional phosphor references, down-
`convert light from a primary light source.
`The QD phosphors have a band gap
`energy smaller than the energy of the light
`produced by the light source. Exh. 1003,
`Hines Dec., ¶¶ 10-14.
`In each of the conventional phosphor
`references, the host matrix allows light
`from the source to pass through and be
`absorbed by the phosphor. Shimizu, 16:
`
`at least a portion of the quantum dots
`having a band gap energy smaller
`than the energy of at least a portion
`of the light produced by the source,
`
`and the matrix allowing light from
`the source to pass therethrough.
`
`(cid:3)
`
`13 of 38
`
`

`
`Claim
`
`2. The device of claim 1, where the
`quantum dots comprise at least one
`material selected from the group
`consisting of CdS, CdSe, CdTe,
`ZnS, and ZnSe.
`
`3. The device of claim 2, where the
`quantum dots further comprise an
`overcoat of at least one material
`selected from the group consisting of
`ZnS, ZnSe, CdS, CdSe, CdTe, and
`MgSe.
`
`4. The device of claim 1, where the
`host matrix comprises at least one
`material selected from the group
`consisting of polymers, silica
`glasses, and silica gels.
`
`5. The device of claim 1, where the
`host matrix comprises at least one
`polymer selected from the group
`consisting of polystyrene,
`polyimides, and epoxies.
`
`CPR / Ground 5
`54-67 (describing the matrix material as
`“transparent.”); Baretz, 8: 62-64
`(describing the matrix material as
`“translucent.”); and Vriens, 3: 32-51
`(disclosing that the matrix material is
`epoxy, the same material disclosed in the
`‘091 Patent).
`Hakimi uses CdSe or ZnSe QDs. Exh.
`1010, 2: 64-68. Lawandy uses QDs
`having a CdS core and a ZnSe shell. Exh.
`1008, 4: 15-21. Burt uses QDs having a
`PbS core and a CdS or a CdSe shell. Exh.
`1007, p. 7, ll 18-20.
`Lawandy uses QDs having a CdS core
`and a ZnSe shell. Exh. 1008, 4: 15-21.
`Burt uses QDs having a PbS core and a
`CdS or a CdSe overcoat. Exh. 1007, p. 7,
`ll.18-20.
`
`Each of the conventional phosphor
`references teaches that the host material
`can be a polymer or a glass. For example,
`the host material of Shimizu is an epoxy
`resin or glass. Exh. 1009, 16: 54-67. The
`host material of Baretz is a translucent
`polymer or a glass material. Exh. 1011,
`8: 58-64. The host material of Vriens is
`epoxy. Exh. 1012, 2: 12-16. Likewise,
`Hakimi teaches that the host material can
`be a polymer. Exh. 1010, e.g., col. 3,
`lines 8-10.
`The host material of Shimizu is an epoxy
`resin or glass. Exh. 1009, 16: 54-67. The
`host material of Baretz is a translucent
`polymer or a glass material. Exh. 1011,
`8: 58-64. The host material of Vriens is
`epoxy. Exh. 1012, 2: 12-16.
`
`(cid:3)
`
`14 of 38
`
`

`
`Claim
`6. The device of claim 1, where the
`quantum dots comprise a coating
`having an affinity for the host
`matrix.
`
`7. The device of claim 6, where the
`host matrix comprises a polymer and
`the coating comprises a related
`monomer.
`
`8. The device of claim 1, where the
`primary light source is selected from
`the group consisting of a light-
`emitting diode, a solid-state laser,
`and a solid-state ultraviolet source.
`
`9. The device of claim 1, where the
`quantum dots have a size
`distribution having less than a 10%
`in diameter of the dots.
`
`CPR / Ground 5
`Burt, Lawandy, and Hakimi are silent as
`to the QDs having a coating with an
`affinity for the host matrix. However,
`Bhargava, which is also directed to using
`QDs to down-convert primary light,
`teaches QD films wherein the surfaces of
`the QDs are coated with a methacrylic
`acid surfactant, which a person of skill in
`the art would recognize is a
`polymerizable monomer. Exh. 1004, 5:
`55-58, see also Exh. 1003, Hines Decl.,
`¶ 17. Bhargava also references Bhargava
`II, which teaches conditions for
`polymerizing the surfactant and also
`provides other examples of host matrices,
`which include photocurable polymers.
`Exh. 1006, p. 2, col. 1.
`See Claim 6.
`
`Each of the conventional phosphor
`references teaches an LED as a primary
`light source. See claim 1.
`
`Hakimi teaches that the QDs can be all of
`the same size so that the QD laser
`described therein produces a single,
`narrow spectral band. Exh. 1010, 3: 10-
`14. Moreover, it was well known prior to
`the filing date of the ‘091 Patent, as
`illustrated in Bawendi and Hines (both
`discussed below) to use QDs having a
`narrow size distribution to obtain a
`narrow emission spectrum. See, e.g., Exh.
`1013, 2: ll. 59 – 61 (teaching QDs having
`
`(cid:3)
`
`15 of 38
`
`

`
`Claim
`
`10. The device of claim 1, wherein
`the quantum dots comprise an
`undoped semiconductor material.
`
`11. The device of claim 1, wherein
`the quantum dots photoluminensce
`light of a color characteristic of their
`sizes in response to light from the
`light source.
`
`
`
`
`
`CPR / Ground 5
`less than a 5 % distribution in the
`diameter of the cores); see also Exh.
`1016, abstract and entirety of Hines.
`Lawandy teaches both doped and
`undoped QDs. Exh. 1008, 4: 36-39 (“in
`some embodiments of the invention
`doping of the semiconductor core
`material with a luminescent center is not
`required.).” Hakimi teaches CdSe and
`ZnSe QDs. Exh. 1010, 2: 64-68. Hakimi
`does not mention whether its QDs are
`doped. The QDs of Burt are prepared by
`precipitation without doping. Exh. 1007,
`p. 7, ll. 3-12 and p. 10, ll. 16-20.
`This element is merely a description of
`how QDs emit light. It was known that
`the emission of a QD is a function of the
`size of the QD. That relationship is
`explicitly stated in the formula at
`Lawandy, Exh. 1008, 5: 55; see also Exh.
`1003, Hines Dec., ¶¶ 10-14. Thus, the
`color of light emitted by a QD is
`characteristic of the size of the QD.
`
`Burt recognizes that the light emitted is a
`characteristic of the size of the QD.
`Specifically, Burt, endeavoring to achieve
`a broad spectrum of emission, states that a
`spread in the sizes of QDs should be used.
`Exh. 1007, p. 5, ll. 25-32.
`
`Likewise, Hakimi teaches that the
`fluorescing wavelength of the QD can be
`changed as determined by the diameter of
`the QD. Exh. 1010, 3: 1-4.
`
`(cid:3)
`
`16 of 38
`
`

`
`Claim
`12. A quantum dot colloid,
`comprising
`
`a population of quantum dots
`dispersed in a nonconductive host
`matrix,
`
`each quantum dot having a
`substantially uniform surface
`energy,
`
`wherein the dots are of a size
`distribution, composition, or a
`combination thereof, selected to
`photoluminesce light of a spectral
`distribution of wavelengths
`characteristic of a selected color
`when the host matrix is irradiated
`with light from a primary source
`whose wavelength is shorter than the
`longest wavelength of said spectral
`distribution.
`
`13. The colloid of claim 12, where
`the quantum dots comprise at least
`one material selected from the group
`
`FOGG / Ground 8
`Fogg describes colloids of CdSe QDs
`dispersed in copolymer matrices. Exh.
`1015, Abstract and entirety of Fogg.
`Fogg describes colloids of CdSe QDs
`dispersed in copolymer matrices of
`phosphine- or phosphine oxide-
`functionalized polynorborene. Those
`materials are nonconductive. Exh. 1015,
`Abstract and entirety of Fogg; see also
`Exh. 1003, Hines Dec., ¶ 30.
`The QDs are prepared by pyrolysis of
`demethylcadmium and selenium
`trictylphosphine. See Exh. 1015, p. 2. A
`POSITA would therefore understand that
`this method is a colloidal synthesis and,
`therefore, provides QDs having
`substantially uniform surface energy, as
`that term is used in the ‘091 Patent. See
`Exh. 3, Hines Dec., ¶ 16.
`This element is merely a description of
`how QDs emit light. Figure 2 and 3
`illustrate the photoluminescence of QDs
`dispersed in block copolymers. Exh.
`1015, Figure 2, 3. Fogg recognizes that
`the luminescence color of QDs can be
`“tuned” (i.e., selected) by selecting the
`size of the QD. See Exh. 1015, p. 1
`(discussing variation of QD luminescence
`by variation of QD size). The wavelength
`of the primary source must be shorter than
`the longest wavelength of the light
`emitted from the QD for
`photoluminescence to happen. See Exh.
`3, Hines Dec., ¶¶ 10-14.
`Fogg teaches CdSe QDs. Exh. 1015,
`Abstract and entirety of Fogg.
`
`(cid:3)
`
`17 of 38
`
`

`
`Claim
`consisting of CdS, CdSe, CdTe,
`ZnS, and ZnSe.
`
`14. The colloid of claim 13, where
`the quantum dots further comprise
`an overcoating of at least one
`material selected from the group
`consisting of ZnS, ZnSe, CdS, CdSe,
`CdTe, and MgSe.
`
`15. The colloid of claim 12, where
`the host matrix comprises at least
`one material selected from the group
`consisting of a polymer, a silica
`glass, and a silica gel.
`
`16. The colloid of claim 12, where
`the host matrix comprises a polymer
`selected from the group consisting
`of polystyrene, polyimides, and
`epoxies.
`
`FOGG / Ground 8
`
`Fogg does not mention overcoated QDs.
`However, Fogg II, an article by the same
`researchers, teaches CdSe and ZnS-
`overcoated CdSe QDs incorporated into
`copolymer matrices. Exh. 1018, Abstract
`and entirety of Fogg II. Fogg II states
`that the ZnS overcoated QDs have a much
`greater quantum yield than the QDs
`described in the original Fogg reference.
`Exh. 1018, p. 2. A higher quantum yield
`means that those QDs produce more
`emitted light for a given amount of
`absorbed light. Exh. 3, Hines Dec., ¶ 31.
`A POSITA would be motivated to use the
`ZnS-overcoated QDs described in Fogg II
`to maximize the photoluminescent
`properties of the Fogg QD-copolymer
`compositions. Id.
`Fogg describes a colloid of CdSe QDs
`dispersed in copolymer host matrix. Exh.
`1015, Abstract and entirety of Fogg.
`
`Fogg describes colloids of CdSe QDs
`dispersed in copolymer matrices. Exh.
`1015, Abstract and entirety of Fogg.
`Fogg teaches that the QD/polymer
`composites could be useful in
`photoelectronic devices. Exh. 1015, p. 1.
`Fogg also recognizes that the
`QDs/polymer composites exhibit
`photoluminescence. Id. at p. 9. A
`POSITA would be motivated to exchange
`the polymers used in Fogg for epoxy
`polymers, as taught in Baretz (9: 24-29)
`
`(cid:3)
`
`18 of 38
`
`

`
`Claim
`
`17. The colloid of claim 12, where
`the quantum dots are coated with a
`coating material having an affinity
`for the host matrix.
`
`18. The colloid of claim 17, where
`the host matrix comprises a polymer
`and the coating material comprises a
`related monomer.
`
`19. The colloid of claim 12, where
`the size distribution is characterized
`by an rms deviation in diameter of
`the quantum dots of less than 10%.
`
`20. The quantum dot of claim 12,
`wherein the spectral distribution is
`determined by the size distribution
`of the quantum dots.
`
`FOGG / Ground 8
`or Vreins (3: 43- 4: 62), because those
`references teach that epoxy polymers are
`known to be suitable for dispersing
`phosphors in luminescent devices. Exhs.
`1011 and 1012. The selection of a known
`material based on its suitability for its
`intended use supports a prima
`facie obviousness determination. See
`MPEP 2144.07.
`The QDs of Fogg are coated with
`trioctylphosphine, which provides the
`QDs with an affinity for the phosphine-
`substituted portions of the block
`copolymers. Exh. 1015, p. 6, col. 2.
`Moreover, the phosphine-substituted
`monomers of the copolymer have an
`affinity for the QD surface. Id.
`The phosphine-substituted monomers of
`the block copolymer matrix have an
`affinity for the surface of the QDs and
`bind to the surface of the QDs. Id. In
`other words, the polymer matrix material
`and the coating (described in claim 17
`above) both incorporate the same type of
`monomer.
`The QDs of Fogg are described as nearly
`monodisperse. Exh. 1015 Abstract. The
`Fogg states that the process used to
`prepare the CdSe QDs yields QDs with
`size distributions less than 5 % rms in
`diameter. See Exh. 1015, p. 1, col. 2.
`It was known that the spectral distribution
`of light emitted by a QD i