UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`SONY CORPORATION
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`_______________
`
`Case:
`
`U.S. Patent No. 7,300,194
`
`DECLARATION OF RICHARD A. FLASCK
`
`
`
`
`
`
`
`
`
`SONY_000315
`
`Sony Corp. Exhibit 1004
`
`

`
`TABLE OF CONTENTS
`Page
`
`INTRODUCTION ................................................................................................... 1
`
`
`I.
`
`A.
`
`B.
`
`Background And Qualifications ................................................................... 1
`
`Information Considered ................................................................................ 4
`
`II.
`
`LEGAL STANDARDS ............................................................................................ 4
`
`A.
`
`B.
`
`Person Of Ordinary Skill In The Art ........................................................... 5
`
`Anticipation ..................................................................................................... 6
`
`C. Obviousness .................................................................................................... 7
`
`D.
`
`Claim Construction ...................................................................................... 10
`
`III. TECHNOLOGY BACKGROUND.................................................................... 11
`
`A. Historical Perspective .................................................................................. 11
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`Light Source/Lamp ...................................................................................... 14
`
`Reflector ........................................................................................................ 16
`
`Light Guide ................................................................................................... 17
`
`Reflector Sheet .............................................................................................. 19
`
`Set Of Light Redirecting Sheets ................................................................. 19
`
`Case/Frame/Tray ......................................................................................... 23
`
`LCD Panel ..................................................................................................... 24
`
`IV. THE '194 PATENT ................................................................................................ 25
`
`A.
`
`B.
`
`C.
`
`D.
`
`Background Of The '194 Patent ................................................................. 25
`
`Prosecution History Of The '194 Patent (Ex.1002) ................................. 26
`
`Challenged Claims ........................................................................................ 27
`
`Claim Construction ...................................................................................... 27
`
`
`
`
`
`-i-
`
`
`
`SONY_000316
`
`

`
`TABLE OF CONTENTS
`
`Page
`"Deformities" .................................................................................... 27
`
`"Air Gap" ........................................................................................... 28
`
`"Well Defined" .................................................................................. 29
`
`1.
`
`2.
`
`3.
`
`V.
`
`PRIOR ART ANALYSIS ....................................................................................... 30
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`Claims 16-18, 22-24, 26, 27, And 31 Are Unpatentable
`Under §102(a) As Being Anticipated By Matsuoka .................................. 30
`
`Claims 16, 22, 23, 26, 27, And 31 Are Unpatentable
`Under §102(e) As Being Anticipated By Nishio '332............................... 36
`
`Claims 1, 4-6, 11, 12, And 28 Are Unpatentable
`Under § 103(a) As Being Obvious Over Pristash .................................... 41
`
`Claims 1, 10, 11, 15, 16, 22, 23, 27, And 31 Are Unpatentable
`Under § 102(e) As Being Anticipated By Funamoto ............................... 51
`
`Claims 4, 5, 6, And 18 Are Unpatentable
`Under § 103(a) As Obvious Over Funamoto ........................................... 69
`
`Claims 1, 2-6, 11, 12, 14, 15, And 28 Are Unpatentable
`Under § 102(e) As Being Anticipated By Nishio '280 ............................. 73
`
`VI.
`
`SECONDARY CONSIDERATIONS ................................................................ 87
`
`VII. CONCLUSION ....................................................................................................... 87
`
`
`
`
`
`
`
`-ii-
`
`
`
`SONY_000317
`
`

`
`
`
`I.
`
`I, RICHARD A. FLASCK, declare and state as follows:
`
`INTRODUCTION
`1.
`
`I have been retained by Sony Corporation ("Sony") as an expert in the
`
`relevant art.
`
`2.
`
`I have been asked to provide my opinions and views on the materials I
`
`have reviewed in this case related to Ex.1001, U.S. Patent No. 7,300,194 ("the
`
`'194 Patent"), and the scientific and technical knowledge regarding the same subject
`
`matter before and for a period following the date of the first application for the
`
`'194 Patent was filed.
`
`3.
`
`I am being compensated at the rate of $375/hour for my work, plus
`
`reimbursement for expenses. My compensation has not influenced any of my
`
`opinions in this matter and does not depend on the outcome of this proceeding or
`
`any issue in it.
`
`4. My opinion and underlying reasoning for this opinion is set forth below.
`
`A.
`
`5.
`
`Background And Qualifications
`
`I received a Bachelor of Science degree in Physics from the University of
`
`Michigan (Ann Arbor, MI) in 1970. I received a Master of Science degree in Physics
`
`from Oakland University (Rochester, MI) in 1976.
`
`6. My forty-four year career has involved high tech product development,
`
`intellectual property issues, projection displays, optical design and components
`
`(including illumination systems), LCD flat panel displays and modules, backlighting of
`
`1
`
`SONY_000318
`
`

`
`
`
`flat panel displays, CCFL and LED product development, injection molding,
`
`chip-onboard development, and High Definition Television (HDTV) systems.
`
`7.
`
`I founded Alphasil, Inc. in 1982 and was one of the first to work in
`
`amorphous silicon thin film transistor ("TFT") active matrix liquid crystal displays
`
`("LCD"). As CEO of Alphasil, I was responsible for establishing the first amorphous
`
`silicon TFT LCD pilot production line (2000 square feet of class 10 cleanroom) in
`
`Fremont California in 1986.
`
`8. My experience includes developing the TFT active matrix circuits and
`
`production processes, video controllers, scalers, gate drive circuits, data drive circuits,
`
`and cold cathode fluorescent lamp ("CCFL") backlight units ("BLU") for the LCD
`
`modules which Alphasil developed and sold. This activity included the design and
`
`development of BLUs and CCFL drive circuit technology.
`
`9.
`
`At Alphasil, I pioneered the use of CCFLs in LCD backlight units
`
`(BLUs) starting in 1986. By 1988 I had managed the development of some of the first
`
`LCD backlight units (BLUs), including one of the first dimming inverters (then called
`
`"electronic ballasts") for driving CCFLs in such BLUs.
`
`10.
`
`I founded RAF Electronics Corp. in 1989 and pioneered Liquid Crystal
`
`On Silicon ("LCOS") projection technology. My experience included developing LCD
`
`microdisplay circuits, video controller, scalers, and illumination systems for LCOS
`
`microdisplays.
`
`2
`
`SONY_000319
`
`

`
`
`
`11.
`
`I am an inventor on 25 issued patents. Some patents of particular
`
`relevance are listed below:
`
` 4,842,378 6/27/89 Method of illuminating Flat Panel Displays to Provide CRT
`Appearing Displays
` 4,736,229 4/5/88 Method of Manufacturing Flat Panel Backplanes, Display
`Transistors and Displays Made Thereby
` 4,651,185 3/17/87 Method of Manufacturing Thin Film Transistors and
`Transistors Made Thereby
` 4,545,112 10/8/85 Method of Manufacturing Thin Film Transistors and
`Transistors Made Thereby
`12.
`In addition, I am the author of various publications, conference papers
`
`and presentations. Some publications of particular interest are:
`
` R. Flasck, "The Critical Role of Optical Interference Coatings in High
`Brightness – Etendue Limited Systems Such as HDTV Projectors", at the 2007
`Optical Interference Coatings Topical Meeting and Tabletop Exhibit, Optical
`Society of America, June 7, 2007.
` R. Flasck, "Current and Near Term Applications of Flat Panel Display
`Devices," Applications of Electronic Imaging; John Urbach, Editor;
`Proceedings of SPIE, Vol. 1082 (1989). – Invited Critical Review Paper
` R. Flasck, "U.S. Display Suppliers and Developers: Comments on
`Developments and Manufacturing," Flat Panel Displays 1988 Conference and
`Exhibition; Stanford Resources, Inc. (1988). – Invited Presentation and Expert
`Panel Member
`13.
`I have testified as an expert witness in several patent cases. The patent
`
`cases involving LCD BLUs were:
`
`2006 - 2007
`Date
`Law Firm Bingham McCutchen LLP
`Client
`Defendant - Seoul Semiconductor Company, Inc.
`Nichia Corporation v. Seoul Semiconductor
`Case
`
`3:06-cv-0162 USDC, Northern District of California
`Expert witness, reports, trial testimony
`
`Services
`
`3
`
`SONY_000320
`
`

`
`
`
`
`2008 - 2009
`Date
`Law Firm Howrey LLP
`Client
`Complainant - O2Micro
`O2Micro v Monolithic Power Systems, MicroSemi
`Case
`
`
` U.S. International Trade Commission Investigation No. 337-TA-666
`Services
`Expert witness, reports, ITC hearing testimony
`14. A detailed record of my professional qualifications, including a list of
`
`publications, awards, and professional activities, is set forth in my curriculum vitae,
`
`attached to this report as Appendix A.
`
`B.
`15.
`
`Information Considered
`
` In addition to my general knowledge gained as a result of my education
`
`and experience in this field, I have reviewed and considered, among other things, the
`
`'194 Patent, the prosecution history of the '194 Patent, the prior art of record, and the
`
`papers submitted by LG Display Group LLC in connection with its IPR2014-01097.
`
`16. The full list of information that I have considered in forming my
`
`opinions for this report is set forth throughout the report and listed in the attached
`
`Appendix B.
`
`II.
`
`LEGAL STANDARDS
`17.
`
`In forming my opinions and considering the patentability of the claims
`
`of the '194 Patent, I am relying upon certain legal principles that counsel has
`
`explained to me.
`
`18.
`
`I understand that for an invention claimed in a patent to be found
`
`patentable, it must be, among other things, new and not obvious in light of what came
`
`4
`
`SONY_000321
`
`

`
`
`
`before it. Patents and publications which predated the invention are generally referred
`
`to as "prior art."
`
`19.
`
`I understand that in this proceeding the burden is on the party asserting
`
`unpatentability to prove it by a preponderance of the evidence. I understand that "a
`
`preponderance of the evidence" is evidence sufficient to show that a fact is more
`
`likely than not.
`
`20.
`
`I have been informed that an unexpired claim subject to Inter Partes
`
`Review is given its "broadest reasonable construction in light of the specification of
`
`the patent in which it appears." The claims after being construed in this manner are
`
`then to be compared to information that was disclosed in the prior art.
`
`A.
`21.
`
`Person Of Ordinary Skill In The Art
`
`I have been informed that the claims of a patent are judged from the
`
`perspective of a hypothetical construct involving "a person of ordinary skill in the
`
`art." The "art" is the field of technology to which the patent is related. I understand
`
`that the purpose of using a person of ordinary skill in the art's viewpoint is objectivity.
`
`Thus, I understand that the question of validity is viewed from the perspective of a
`
`person of ordinary skill in the art, and not from the perspective of (a) the inventor,
`
`(b) a layperson, or (c) a person of extraordinary skill in the art. I have been informed
`
`that the claims of the patent-at-issue are interpreted as a person of ordinary skill in the
`
`art would have understood them in the relevant time period (i.e., when the patent
`
`application was filed or the earliest effective filing date).
`
`5
`
`SONY_000322
`
`

`
`
`
`22.
`
`It is my opinion that a person of ordinary skill in the art relevant to the
`
`'194 Patent would have at least an undergraduate degree in physics, optics,
`
`engineering, or applied mathematics and three years of work experience (or a graduate
`
`degree) in a field related to optical technology.
`
`23.
`
`I understand that a "person of ordinary skill is also a person of ordinary
`
`creativity, not an automaton" and that would be especially true of anyone developing
`
`LCD structures.
`
`B.
`24.
`
`Anticipation
`
`I understand that the following standards govern the determination of
`
`whether a patent claim is "anticipated" by the prior art. I have applied these standards
`
`in my analysis of whether claims of the '194 Patent were anticipated at the time of the
`
`invention.
`
`25.
`
`I understand that a patent claim is "anticipated" by a single prior art
`
`reference if that reference discloses each element of the claim in a single embodiment.
`
`A prior art reference may anticipate a claim inherently if an element is not expressly
`
`stated, but only if the prior art necessarily includes the claim limitations.
`
`26.
`
`I understand that the test for anticipation is performed in two steps.
`
`First, the claims must be interpreted to determine their meaning. Second, a prior art
`
`reference is analyzed to determine whether every claim element, as interpreted in the
`
`first step, is present in the reference. If all the elements of a patent claim are present in
`
`the prior art reference, then that claim is anticipated and is invalid.
`
`6
`
`SONY_000323
`
`

`
`
`
`27.
`
`I understand that it is acceptable to examine extrinsic evidence outside
`
`the prior art reference in determining whether a feature, while not expressly discussed
`
`in the reference, is necessarily present within that reference.
`
`C. Obviousness
`28.
`I understand that a claim can be invalid in view of prior art if the
`
`differences between the subject matter claimed and the prior art are such that the
`
`claimed 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.
`
`29.
`
`I understand that the obviousness standard is defined at 35 U.S.C.
`
`§ 103(a). I understand that a claim is obvious over a prior art reference if that
`
`reference, combined with the knowledge of one skilled in the art or other prior art
`
`references disclose each and every element of the recited claim.
`
`30.
`
`I also understand that the relevant inquiry into obviousness requires
`
`consideration of four factors:
`
`
`
`
`
`
`
`
`
`a.
`
`b.
`
`c.
`
`d.
`
`The scope and content of the prior art;
`
`The differences between the prior art and the claims at issue;
`
`The knowledge of a person of ordinary sill in the pertinent art; and
`
`Objective factors indicating obviousness or non-obviousness may be
`
`present in any particular case, such factors including commercial success of products
`
`covered by the patent claims; a long-felt need for the invention; failed attempts by
`
`others to make the invention; copying of the invention by others in the field;
`
`7
`
`SONY_000324
`
`

`
`
`
`unexpected results achieved by the invention; praise of the invention by the infringer
`
`or others in the field; the taking of licenses under the patent by others; expressions of
`
`surprise by experts and those skilled in the art at the making of the invention; and that
`
`the patentee proceeded contrary to the accepted wisdom of the prior art.
`
`31.
`
`I understand that when combining two or more references, one should
`
`consider whether a teaching, suggestion, or motivation to combine the references
`
`exists so as to avoid impermissible hindsight. I have been informed that the
`
`application of the teaching, suggestion or motivation test should not be rigidly
`
`applied, but rather is an expansive and flexible test. For example, I have been
`
`informed that the common sense of a person of ordinary skill in the art can serve as
`
`motivation for combining references.
`
`32.
`
`I also understand from the Supreme Court case of KSR International Co. v.
`
`Teleflex Inc., 550 U.S. 398 (2007), that the following are rationales that may support a
`
`conclusion of obviousness: (A) combining prior art elements according to known
`
`methods to yield predictable results; (B) simple substitution of one known element for
`
`another to obtain predictable results; (C) use of known techniques to improve similar
`
`devices (methods, or products) in the same way; (D) applying a known technique to a
`
`known device (method, or product) ready for improvement to yield predictable
`
`results; (E) "obvious to try" ____ choosing from a finite number of identified,
`
`predictable solutions, with a reasonable expectation of success; (F) known work in
`
`one field of endeavor may prompt variations of it for use in either the same field or a
`
`8
`
`SONY_000325
`
`

`
`
`
`different one based on design incentives or other market forces if the variations are
`
`predictable to one of ordinary skill in the art; (G) 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.
`
`33.
`
`I understand that the content of a patent or other printed publication
`
`(i.e., a reference) should be interpreted the way a person of ordinary skill in the art
`
`would have interpreted the reference as of the effective filing date of the patent
`
`application for the '194 Patent. I have assumed that the person of ordinary skill is a
`
`hypothetical person who is presumed to be aware of all the pertinent information that
`
`qualifies as prior art. In addition, the person of ordinary skill in the art makes
`
`inferences and creative steps. He or she is not an automaton, but has ordinary
`
`creativity.
`
`34.
`
`I have been informed that the application that issued as the '194 Patent
`
`was filed in 2005. However, the application claims priority to a parent application that
`
`was filed on June 27, 1995. As a result, I will assume the relevant time period for
`
`determining what one of ordinary skill in the art knew is June 27, 1995, the effective
`
`filing date for purposes of this proceeding.
`
`9
`
`SONY_000326
`
`

`
`
`
`D. Claim Construction
`35.
`I have been informed that an unexpired claim subject to Inter Partes
`
`Review is given its "broadest reasonable construction in light of the specification of
`
`the patent in which it appears."
`
`36.
`
`I have also been informed that if an Inter Partes Review involves claims of
`
`an expired patent, a patentee is unable to make claim amendments, and the Board
`
`applies the claim construction principles outlined in Phillips v. AWH Corp., 415 F.3d
`
`1303 (Fed. Cir. 2005), that the words of a claim "are generally given their ordinary and
`
`customary meaning" as understood by a person of ordinary skill in the art in question
`
`at the time of the invention. I have been informed that this means that the words of
`
`the claim are given their plain meaning from the perspective of one of ordinary skill in
`
`the art unless that meaning is inconsistent with the specification. I understand that the
`
`"plain meaning" of a term means the ordinary and customary meaning given to the
`
`term by those of ordinary skill in the art at the time of the invention and that the
`
`ordinary and customary meaning of a term may be evidenced by a variety of sources,
`
`including the words of the claims, the specification, drawings, and prior art.
`
`37.
`
`I understand that, in construing claims, all words in a claim must be
`
`considered in judging the patentability of that claim against the prior art.
`
`38.
`
`I understand that extrinsic evidence may be consulted for the meaning
`
`of a claim term as long as it is not used to contradict claim meaning that is
`
`unambiguous in light of the intrinsic evidence. I also understand that in construing
`
`10
`
`SONY_000327
`
`

`
`
`
`claim terms, the general meanings gleaned from reference sources must always be
`
`compared against the use of the terms in context, and the intrinsic record must always
`
`be consulted to identify which of the different possible dictionary meanings is most
`
`consistent with the use of the words by the inventor.
`
`III. TECHNOLOGY BACKGROUND
`A. Historical Perspective
`39.
`Flat panel display development for TVs, computers and laptops was
`
`pioneered in the 1980s. There were several technical approaches pursued including
`
`electroluminescent, plasma, vacuum fluorescence, electrochromic, field emission, and
`
`liquid crystal. By the early 1990s it became clear that active matrix liquid crystal display
`
`technology would dominate the target market segments for at least several decades.
`
`40.
`
`Liquid crystal matrix displays comprise an x-y array of pixels (picture
`
`elements) which can be individually set to any gray level by the application of electrical
`
`signals to the gate lines (rows) and data lines (columns). By the mid 1990s (the time
`
`period of the original filing of the Parker patents) a typical commercial LC display had
`
`a diagonal of 8 to 15 inches and an SVGA (600 x 800) color triad pixel format, or
`
`something similar.
`
`11
`
`SONY_000328
`
`

`
`
`TYPICAL ACTIVE MATRIX LCD FLAT TYPICAL ACTIVE MATRIX LCD FLAT
`
`PANEL MODULEPANEL MODULE
`
`Column (Source) Column (Source)
`
`DriversDrivers
`
`
`Tcon /Tcon /
`
`LogicLogic
`
`
`
`
`Pix ClockPix Clock
`
`HsyncHsync
`
`VsyncVsync
`
`Data-Data-
`
`EnableEnable
`
`Digital R Digital R
`
`Digital GDigital G
`
`Digital BDigital B
`
`
`Row (Gate) Row (Gate)
`
`DriversDrivers
`
`
`Fixed Pixel Fixed Pixel
`
`ArrayArray
`
`
`
`41. Each pixel acts as a variable shutter and exhibits a level of opacity
`
`determined by the data line signals. LC displays do not generate light, but merely act
`
`as a large matrix of miniature variable shutters that modulate light passing through the
`
`display panel. Therefore, LC displays, in the mid 1990s and still today, typically need a
`
`light generating structure unit beneath the LC panel to provide the requisite light.
`
`These light generating structures are commonly called backlight units (BLUs). The
`
`BLU must provide light of sufficient brightness and uniformity to enable a user
`
`(usually looking directly at the display) to easily see the intended text, graphics or
`
`video image.
`
`12
`
`SONY_000329
`
`

`
`
`
`42. A complete LCD module comprises an LCD panel, the drive electronics,
`
`and the BLU.
`
`
`
`43.
`
`Since the mid 1990s, the typical BLU found in commercially available
`
`
`
`products comprised:
`
` A light source.
` A reflector to concentrate the light.
` A light guide with deformities on the lower surface.
`
`13
`
`SONY_000330
`
`

`
`
`
` A set of light re-directing films, sheets or plates between the light guide and
`the LC panel.
` A tray / case / frame.
`
`44. During the 1980s and into the early 1990s, several BLU technologies and
`
`structures were researched, developed, patented and commercialized. By the mid
`
`1990s, a basic BLU structure and design was widely available commercially and began
`
`dominating the market. That basic design, shown below, is still used today:
`
`LC Module = LC Panel + BLU
`
`LC Panel
`
`Light source / Lamp
`
`Reflector
`
`Light re-directing
`sheets:
`Horizontal BEF
`Vertical BEF
`Diffuser
`
`Light Guide
`
`Reflector sheet
`
`Case / Tray
`
`
`
`B.
`Light Source/Lamp
`45. The most common BLU lamp technologies are the Cold Cathode
`
`Fluorescent Lamp (CCFL) and the Light Emitting Diode (LED). The design choice
`
`between the two was based on desired thinness profile, brightness, and power
`
`14
`
`SONY_000331
`
`

`
`
`
`consumption. CCFLs were prevalent in the consumer market until about 2005. Steady
`
`improvements in LED performance and reduced cost have allowed LEDs to largely
`
`supplant CCFLs in BLUs today.
`
`CCFL Construction
`
`From JKL Miniature Fluorescent Lamp Catalog, © 1999
`
`
`
`46. Generally, the CCFL today have been largely replaced with a linear array
`
`of LEDs. This use of LEDs was known in from the early 1990s as indicated by Mino
`
`JP H-242731, Ex.1016, filed in February 1993 and published in September 1994.
`
`15
`
`SONY_000332
`
`

`
`
`
`
`
`Fig 3 Mino JP H06-242731Fig 3 Mino JP H06-242731
`
`
`
`47.
`
`It was also well known by the mid 1990s that multiple lamps could be
`
`used in a BLU. One common configuration was to dispose the lamps along opposite
`
`edges of the light guide as shown below from Fig. 4 of Ciupke, U.S. Patent
`
`No. 5,461,547, Ex.1019:
`
`
`
`Fig 4 Ciupke U.S. Patent No. 5,461,547Fig 4 Ciupke U.S. Patent No. 5,461,547
`
`C. Reflector
`48. The lamp reflector is usually a wrap of reflective foil or shiny stamped
`
`sheet metal. The reflector allows the capture and concentration of a larger fraction of
`
`
`
`16
`
`SONY_000333
`
`

`
`
`
`the light generated by the lamp. This concentrated or focused light is injected into the
`
`entrance port edge of the light guide.
`
`D. Light Guide
`49. The light guide transports the light from the input edge adjacent to the
`
`lamp, to the output port, which is the top surface of the light guide plate. The light
`
`guide is generally a transparent plastic plate. The light injected into the entrance edge
`
`port of the light guide is captured in, and uniformly distributed throughout, the light
`
`guide by the principle of Total Internal Reflection (TIR). A hollow cavity with
`
`specularly reflective walls is sometimes substituted for the solid transparent light
`
`guide.
`
`50. The wave guide generally has deformities on the bottom surface
`
`(commonly white painted dots). When the TIRed light encounters such a deformity,
`
`the scattered light is produced at such angles that the TIR condition is defeated and
`
`the scattered light exits through the top exit surface of the light guide as seen in Fig. 2
`
`of Ciupke, U.S. Patent No. 5,461,547, Ex.1019:
`
`
`
`17
`
`SONY_000334
`
`

`
`
`
`51.
`
`In the mid 1990s, wedged light guides were known and used as seen in
`
`Fig. 6 of Nagatani (JP H06-003526), Ex.1020, below. The deformities on the bottom
`
`surface could be white dots, roughened regions, or other surface structures. Light
`
`guides could have a saw-tooth surface on the bottom to partially collimate the light
`
`leaving the top exit surface of the light guide in the plane perpendicular to both the
`
`surface of the light guide and the lamp as shown below.
`
`Fig 2 from Jannson U.S. Patent
`N 5 853 403
`
`
`
`52.
`
`Further, by the mid 1990s it was also well known that the light extracting
`
`deformities on the light guide could be on either the top surface of the light guide, the
`
`bottom surface of the light guide. Further, it was known that such deformities could
`
`vary in shape, size and spacing across the surface of the light guide. These attributes
`
`are shown in Figures 5 and 6 from JP H06-003526 to Nagatani, Ex.1020:
`
`18
`
`SONY_000335
`
`

`
`
`
`
`
`JP H06-003526 NagataniJP H06-003526 Nagatani
`
`
`
`E. Reflector Sheet
`53. A reflector sheet is usually disposed under the light guide. This reflector
`
`sheet is commonly a matte white diffuse reflector or a shiny specular reflective film.
`
`Since the early 1990s 3M has been a major supplier of such film. This reflector sheet
`
`prevents light leakage from the bottom of the BLU (especially from light recycled
`
`from the BEF sheets) and it could also be disposed along light guide edges that were
`
`not adjacent to the lamp.
`
`F.
`54.
`
`Set Of Light Redirecting Sheets
`
`From the mid 1990s, in was common to include a set of light
`
`re-directing films that re-directed light rays emerging from the light guide surface at
`
`oblique angles to angles more nearly perpendicular to the light guide top exit surface.
`
`This action provides a brighter image to the user located at the usual position directly
`
`in front of the screen. Thus useful screen brightness and lower power consumption
`
`could be achieved. A typical set of films (from the bottom up) comprises:
`
`19
`
`SONY_000336
`
`

`
`
`
`55.
`
`1) A diffusion film, which generally is a transparent sheet with a
`
`randomly roughened surface or inclusions of a refractive index different than that of
`
`the surrounding matrix. Other surface structures such as pyramids could also act as
`
`diffusers. The light distribution at the top surface of the light guide generally exhibits
`
`residual inhomogeneities from the spatial structure of the scattering deformities on
`
`the bottom surface of the light guide. The diffusion sheet tended to even out the light
`
`distribution. Examples of different diffusion sheets are shown below from Takeuchi,
`
`U.S. Patent No. 5,944,405, Ex.1023:
`
`Diffusion sheet examples
`
`
`
`20
`
`SONY_000337
`
`

`
`
`
`56.
`
`2) The Vertical BEF sheet: The Vertical Brightness Enhancement Film
`
`(BEF) is usually a transparent prismatic sheet having V shaped grooves running
`
`vertically along the top surface, although the bottom surface is sometimes used. The
`
`action of the vertical BEF is to partially collimate light in the plane perpendicular to
`
`both the lamp and the Light guide surface. Such BEFs were first introduced by 3M in
`
`the late 1980s and were used in commercial product since the early 1990s. Other
`
`structures besides triangular grooves can be used in such BEF sheets.
`
`57.
`
`3) The Horizontal BEF
`
`sheet: The Horizontal Brightness
`
`Enhancement Film (BEF) is usually a transparent prismatic sheet having V shaped
`
`grooves running horizontally along the top surface, although the bottom surface is
`
`sometimes used. The action of the horizontal BEF is to partially collimate light in the
`
`plane perpendicular to light guide surface and parallel to the lamp. Such BEFs were
`
`first introduced by 3M in the late 1980s and were used in commercial product since
`
`the early 1990s. Other structures besides triangular grooves as shown below in Fig. 32
`
`of Ando, U.S. Pat. No. 5,808,784, Ex.1024, can be used in such BEF sheets :
`
`21
`
`SONY_000338
`
`

`
`
`
`Crossed BEF sheets as shown in Fig 32 in
`A d
`
`200 x edge-on micrograph taken of a BEF in a
`Hitachi LCD module manufactured in April 1996
`
`
`
`
`
`58.
`
`Such BEF sheets were first produced by 3M in the late 1980s, and are
`
`shown for example in a 3M product brochure 75-0500-0403-7, "Brightness
`
`Enhancement Film (BEF)." (1993), Ex.1025.
`
`59.
`
`Further, it was well known that structures other than prismatic V
`
`grooves could be used as the surface structures of BEF films, as shown in Figs. 24, 25
`
`and 26 from Ando, US Patent No. 5,808,784, Ex.1024:
`
`22
`
`SONY_000339
`
`

`
`
`
`
`
`US Patent No. 5,808,784 AndoUS Patent No. 5,808,784 Ando
`
`
`
`60. The combined action of the light re-directing sheets is to re-direct rays
`
`from oblique angles and bring them to a direction more perpendicular to the LC panel
`
`surface. When two crossed BEFs are used, each BEF provides partial collimation in
`
`the plane perpendicular to its prisms or grooves. The net action of two crossed BEFs
`
`is to provide light that is partially collimated in the axis perpendicular to the plane of
`
`the LC panel, thus making the image brighter for a user located directly in front of the
`
`LCD.
`
`G. Case/Frame/Tray
`61. By the early 1990s, the components of the LCD module were often
`
`physically held in place by a metal tray. The lamp, reflector, light guide, re-directing
`
`sheet set, LCD panel, and many times the LCD gate and data line drive electronics
`
`were contained in the tray. The bottom and sides of the tray were sometimes
`
`reflective and the top of the tray was open to allow the image to be viewed by the
`
`user. Below are examples of such trays from Figures 4 and 5 from JP H06-230378 to
`
`Kisoo, Ex.1026, and Figures 4 and 5 from JP H05-69732 to Seraku, Ex.1029:
`
`23
`
`SONY_000340
`
`

`
`
`
`
`
`
`
`62. Both examples show trays which hold all of the components of the
`
`BLU.
`
`H. LCD Panel
`63. As previously discussed, the LCD panel is an x-y matrix of pixels. The
`
`partially collimated light from the BLU enters the LCD panel from the bottom and
`
`exits the top to be viewed by the user. Each individually addressed pixel in the LCD
`
`24
`
`SONY_000341
`
`

`
`
`
`matrix individually modulates the light from the BLU to present text, graphic, or
`
`video images to the user.
`
`IV. THE '194 PATENT
`
`A.
`
`Background Of The '194 Patent
`
`64. The '194 Patent generally relates to "light emitting panel assemblies each
`
`including a transparent panel member for efficiently conducting light, and controlling
`
`the light conducted by the panel member to be emitted from one or more light output
`
`areas along the length thereof." Ex.1001, 1:19-23. It includes several different light
`
`emitting pan