UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________________________________________
`
`SONY CORPORATION, SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG DISPLAY CO., LTD.
`
`Petitioners
`
`
`
`Patent No. 7,202,843
`Issue Date: April 10, 2007
`Title: DRIVING CIRCUIT OF A LIQUID CRYSTAL DISPLAY
`PANEL AND RELATED DRIVING METHOD
`__________________________________________________________________
`
`DECLARATION OF THOMAS CREDELLE
`IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,202,843
`
`No. IPR2015-00862
`
`__________________________________________________________________
`
`
`
`
`
`
`
`IPR2015-00862
`Petition for Inter Partes Review of U.S. Patent 7,202,843 - EXHIBIT 1015_Page 1
`
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________________________________________
`
`SONY CORPORATION, SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG DISPLAY CO., LTD.
`
`Petitioners
`
`
`
`Patent No. 7,202,843
`Issue Date: April 10, 2007
`Title: DRIVING CIRCUIT OF A LIQUID CRYSTAL DISPLAY
`PANEL AND RELATED DRIVING METHOD
`__________________________________________________________________
`
`DECLARATION OF THOMAS CREDELLE
`IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,202,843
`
`No. IPR2015-00862
`
`__________________________________________________________________
`
`
`
`
`
`
`
`IPR2015-00862
`Petition for Inter Partes Review of U.S. Patent 7,202,843 - EXHIBIT 1015_Page 1
`
`
`
`I, Thomas Credelle, do hereby declare that:
`
`1.
`
`I have been retained by counsel for petitioner Sony Corporation
`
`(“Sony”) to provide assistance regarding U.S. Patent No. 7,202,843 (“the ’843
`
`Patent”).
`
`I. Professional Background
`
`2.
`
`I have more than 40 years of industry experience in research and
`
`development in the areas of Liquid Crystal Display (LCD) technology and in other flat
`
`panel displays.
`
`3.
`
`I received my M.S. degree
`
`in Electrical Engineering from the
`
`Massachusetts Institute of Technology in 1970, with an emphasis on Electro-optics
`
`and Solid State Materials. I received my B.S. degree in Electrical Engineering in 1969
`
`from Drexel University.
`
`4.
`
`I was employed by RCA at Sarnoff Labs in Princeton, NJ from 1970
`
`through 1986. I was initially employed by RCA as an Individual Contributor. At the
`
`time of my departure from RCA, I held the title of Group Manager. During my time
`
`at RCA, I participated in research and development projects relating to optical
`
`materials and flat panel displays, including LCD devices. In 1983, I established the
`
`Thin-Film Transistor (TFT) LCD Program at Sarnoff Labs. As a Group Manager, I
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`led a project that resulted in the development of the first poly-Silicon TFT LCD at
`
`
`
`1
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`Page 2
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`
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`Sarnoff Labs. I received the Sarnoff Outstanding Achievement Award for Large-Area
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`Flat Panel TV Developments.
`
`5.
`
`From 1986 to 1991, I was employed by GE as the Manager of TFT
`
`LCD Research and Development at the GE Research and Development Center in
`
`Schenectady, NY. My duties included managing research and development efforts
`
`relating to TFT and LCD technology for avionics applications. While employed by
`
`GE, I led the team that built the world’s first 1 million pixel color LCD device. I also
`
`led development of numerous other display devices utilizing LCD technology.
`
`6.
`
`From 1991 to 1994, I was employed by Apple Computer as the Manager
`
`of Display Engineering. In my role at Apple, I supervised all LCD design,
`
`engineering, and qualification for the first Powerbook notebook computers
`
`introduced to market in the United States.
`
`7.
`
`From 1994 to 1996, I was employed as the Director of Advanced
`
`Product Marketing by Allied Signal, where I was involved with the design and
`
`engineering of optical film for improving the viewing angle performance of LCD
`
`devices.
`
`8.
`
`From 1996 to 1999, I was employed as the Director of Product
`
`Marketing for Motorola’s Flat Panel Display Division, where I worked in the
`
`development of new flat panel technology, and I also worked closely with Motorola
`
`groups responsible for integrating LCD technology into mobile phone products.
`2
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`
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`Page 3
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`
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`9.
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`From 1999 to 2001, I served as the Vice President of Operations of
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`Alien Technology Corporation. During my time at Alien Technology, I was involved
`
`with the design and architecture of drive-electronics packaging technology suitable for
`
`flexible LCD devices.
`
`10.
`
`From 2001 to 2007, I served as the Vice President of Engineering for
`
`Clairvoyante, Inc. My responsibilities as the VP of Engineering included managing
`
`research, development, engineering, and marketing of technologies for improving the
`
`resolution and power consumption of color flat panel displays. During my time at
`
`Clairvoyante, I was heavily involved with the design of LCD driving circuitry and
`
`image processing circuitry, including image processing algorithms that interacted with
`
`overdrive operations. My work resulted in the issuance of multiple patents relating to
`
`display technology.
`
`11.
`
`From 2007 to 2008, I served as the Senior VP of Engineering for
`
`Puredepth, Inc. My responsibilities included the design of hardware and software to
`
`create 3D images on LCDs.
`
`12.
`
`From 2012 through 2015, I served as the Vice President of Application
`
`Engineering and Device Performance for Innova Dynamics, Inc., a nanotechnology
`
`company developing materials to be used in LCDs and touch sensors. In 2008, I
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`founded TLC Display Consulting, a company that provides technical consulting in the
`
`
`
`3
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`Page 4
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`
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`areas of flat panel displays, liquid crystal displays, and related electronics. I currently
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`serve as the President of TLC Display Consulting.
`
`13.
`
`I have been a member of the Society for Information Display for over
`
`40 years. I was a member of the Society for Information Display’s Program
`
`Committee for 15 years, and the Director of the Society for Information Display’s
`
`Symposium Committee for 10 years. In 1984, I was awarded the title of Society for
`
`Information Display Fellow in recognition of my achievements and contributions to
`
`flat panel display technology.
`
`14.
`
`I am a named inventor on over 70 patents relating to flat panel display
`
`and LCD technology, including U.S. Patent No. 4,630,893, entitled “LCD Pixel
`
`Incorporating Segmented Back-to-Back Diode”; U.S. Patent No. 5,477,350, entitled
`
`“Interferometric Spatial Switch for Polarized or Unpolarized Light Using Liquid
`
`Crystal”; and U.S. Patent No. 7,791,679, entitled “Alternative Thin Film Transistors
`
`for Liquid Crystal Displays.” I have also authored a number of articles relating to
`
`LCD technology and flat panel displays that were published by industry periodicals
`
`such as Information Display and peer-reviewed journals such as the Society for
`
`Information Display’s Digest of Technical Papers.
`
`15. My curriculum vitae is attached as Exhibit Sony-1016.
`
`II. Assignment & Materials Considered
`
`
`
`4
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`Page 5
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`
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`16. Counsel for Sony requested that I provide analysis pertinent to the ’843
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`patent in connection with the present petition for inter partes review. Counsel for Sony
`
`has informed me that the real-parties-in-interest are Sony Corporation, Samsung
`
`Electronics Co., Ltd., and Samsung Display Co., Ltd., Sony Electronics, Inc., Sony
`
`Corporation of America, and Samsung Electronics America, Inc.. I understand that
`
`Surpass Tech Innovation LLC is the owner of the ’843 Patent.
`
`17.
`
`For time spent in connection with this case, I am being compensated at
`
`my customary rate. My compensation is not dependent upon the outcome of this
`
`petition or any issues involved in or related to the ’843 Patent, and I have no other
`
`financial stake in this matter. I have no financial interest in, or affiliation with, any of
`
`the real-parties-in-interest or the patent owner.
`
`18. The patent-related materials I considered include the ’843 Patent and the
`
`original prosecution history for the ’843 Patent.
`
`19. The materials I considered include the following:
`
`a. U.S. Patent Application Publication No. 2003/0156092 (“Suzuki”),
`
`identified as Ex. Sony-1003 in the petition;
`
`b. A certified English translation of Japanese Laid Open Patent
`
`Application No. 2002-0132224 (“Nitta”), identified as Ex. Sony-1005
`
`in the petition;
`
`5
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`Page 6
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`
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`c. U.S. Patent Application Publication No. 2003/0214473 (“Lee”),
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`identified as Ex. Sony-1006 in the petition;
`
`d. U.S. Patent Application Publication No. 2002/0044115 (“Jinda”),
`
`identified as Ex. Sony-1007 in the petition;
`
`e. Ernst Lueder, LIQUID CRYSTAL DISPLAYS (2001), identified as Ex.
`
`Sony-1008 in the petition;
`
`f. William C. O’Mara, LIQUID CRYSTAL FLAT PANEL DISPLAYS (1993),
`
`identified as Ex. Sony-1009 in the petition;
`
`g. Betty Prince, HIGH PERFORMANCE MEMORIES (1996), identified as
`
`Ex. Sony-1010 in the petition;
`
`h. Baek-woon Lee, et al., Reducing Gray-Level Response to One Frame:
`
`Dynamic Capacitance Compensation, SID 2001 DIGEST, 51.2 (2001),
`
`identified as Ex. Sony-1011 in the petition;
`
`i. IEEE 100: THE AUTHORITATIVE DICTIONARY OF IEEE STANDARDS
`
`TERMS (7th ed., 2000), identified as Ex. Sony-1012 in the petition;
`
`j. MC-GRAW HILL DICTIONARY OF SCIENTIFIC AND TECHNICAL TERMS
`
`(6th ed., 2003), identified as Ex. Sony-1013 in the petition;
`
`k. MICROSOFT COMPUTER DICTIONARY (5th ed., 2002), identified as
`
`Ex. Sony-1014 in the petition.
`
`6
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`
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`Page 7
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`
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`l. U.S. Patent Application Publication No. 2003/0048247 (“Ham”),
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`identified as Ex. Sony-1017 in the petition.
`
`20.
`
`In addition, in the context of my work on this matter, I have drawn on
`
`my experience and knowledge, as discussed above and described more fully in my CV,
`
`in the areas of LCD technology and flat panel displays.
`
`21.
`
`I understand that the application leading to the ’843 Patent was U.S.
`
`Patent Application No. 10/707,741, filed January 8, 2004. I also understand that the
`
`’843 Patent claims priority to a Taiwanese patent application filed November 17,
`
`2003. Therefore, for the purposes of my analysis herein, I assume the time of the
`
`purported invention of the ’843 Patent to be November 17, 2003.
`
`III. Person of Ordinary Skill in the Art
`
`22. The ’843 Patent relates to methods and circuitry for driving an LCD
`
`device, such as an LCD computer monitor or LCD television.
`
`23.
`
`I understand that the factors considered in determining the ordinary
`
`level of skill in the art include the level of education and experience of persons
`
`working in the field, the types of problems encountered in the field, and the
`
`sophistication of the technology.
`
`24. Based on these factors, in my opinion, a person of ordinary skill in the
`
`art relating to the technology of the ’843 Patent at the time of the purported invention
`
`of the ’843 Patent would have been a person with a bachelor’s degree or equivalent in
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`Page 8
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`
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`Electrical Engineering and approximately three to five years of experience in
`
`designing and developing LCD devices and LCD driving circuitry.
`
`25. The opinions I express herein are given from the point of view of a
`
`person of ordinary skill in the art, as described above, at the time of the purported
`
`invention of the ’843 Patent.
`
`IV. Overview of the ’843 Patent
`
`26. The ’843 Patent is directed to a driving circuit and method for an LCD
`
`panel that seeks to decrease the reaction time of a liquid crystal element by applying
`
`two data impulses to a pixel electrode within one frame period. ’843 Patent at 1:8-12.
`
`27. The ’843 Patent describes that LCD devices have a disadvantage in
`
`displaying moving images compared to traditional Cathode Ray Tube (CRT) displays
`
`due to the characteristics of liquid crystal molecules. ’843 Patent at 1:20-24. To drive
`
`a pixel in an LCD device, a driving circuit applies a data impulse which corresponds to
`
`the desired gray level for the pixel. Id. at 1:39-52. The data impulse, which is a
`
`voltage level applied for a specific amount of time, applies charge to the liquid crystal
`
`and causes the pixel’s liquid crystal molecules to “twist” to a desired transmission rate.
`
`Id. at 1:19-24, 1:53-65. Liquid crystals do not generate light; rather, in conjunction
`
`with polarizers, they permit certain amounts of light to pass through them depending
`
`on their orientation. Thus, the amount of light that is transmitted through the pixel
`
`depends on the orientation of the corresponding liquid crystal element, and thus sets
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`Page 9
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`the brightness or gray level of the pixel in an LCD device. The ’843 Patent describes
`
`that an LCD driving circuit outputs an appropriate data impulse for each pixel based
`
`on input frame data, which defines the gray level that each pixel of the LCD device
`
`must reach within a frame period. Id. at 1:27-35. However, the ’843 Patent states that
`
`“[t]here is a time delay when charging liquid crystal molecules. . . . Such a delay causes
`
`blurring.” Id. at 1:62-2:2.
`
`28. The ’843 Patent describes that, in order to address the issue of blurring
`
`caused by the delay in liquid crystal reaction speed, “some conventional LCD are
`
`overdriven, which means applying a higher or a lower data impulse to the pixel
`
`electrode to accelerate the reaction speed of the liquid crystal molecules, so that the
`
`pixel can reach the predetermined gray level in a predetermined frame period.” ’843
`
`Patent at 2:2-7. The ’843 Patent further states that while the overdrive technique
`
`improves the reaction speed of liquid crystal molecules, the desired transmission rate
`
`still cannot be reached within one frame period, thus the blurring issue persists. Id. at
`
`2:7-12.
`
`29.
`
` The ’843 Patent purports to address the blurring issue by providing a
`
`driving circuit that generates and applies a plurality of overdriven data impulses (i.e.,
`
`voltages) to each pixel of an LCD device within a single frame period. Id. at 2:33-48.
`
`As described by the ’843 Patent, an embodiment of the driving circuit claimed by the
`
`’843 Patent “generate[s] two pieces of pixel data in each frame period,” and includes a
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`Page 10
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`source driver that “generates two corresponding data impulses according to the two
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`pieces of pixel data and applies them to the pixel electrode [] of the corresponding
`
`pixel.” Id. at 4:22-27. The ’843 Patent further states that the source driver
`
`“generate[s] corresponding data line voltages . . . according to the plurality of
`
`overdriven data included in the frame signals G in order to drive the LCD panel.” Id.
`
`at 3:28-36. Accordingly, the data impulses described by the ’843 Patent are voltages
`
`applied to the pixels of an LCD panel. The ’843 Patent describes that the overdriven
`
`data impulses are generated by comparing the input frame data for the current frame
`
`period with delayed frame data for the preceding frame period; the delayed frame data
`
`is stored in a memory device, which the ’843 Patent identifies as an “image memory.”
`
`Id. at 2:33-40; 4:49-55.
`
`V. Analysis of Claim Terms in the ’843 Patent
`
`30.
`
`I understand that, in an inter partes review, patent claim terms are to be
`
`given their broadest reasonable interpretation as understood by a person of ordinary
`
`skill in light of the patent specification.
`
`31. Based on this understanding of how claim terms should be construed, I
`
`address the construction for one claim term, “blur clear converter”, below. For any
`
`other claim terms, I apply their ordinary and customary meaning.
`
`32.
`
`Independent claim 1 of the ’843 Patent recites “a blur clear converter for
`
`receiving frame data every frame period, each frame data comprising a plurality of
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`pixel data and each pixel data corresponding to a pixel, the blur clear converter
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`delaying current frame data to generate delayed frame data and generating a plurality
`
`of overdriven pixel data within every frame period for each pixel.” In my opinion, the
`
`term “blur clear converter” is not a term of art that would have had any commonly
`
`accepted or understood meaning to those of ordinary skill in the art at the time of the
`
`purported invention of the ’843 Patent. Instead, it is a coined term that a person of
`
`ordinary skill in the art would have interpreted as some unspecified device for
`
`addressing the blurring issue that was well known in the LCD industry at the time of
`
`the purported invention. It is my opinion that a person of ordinary skill in the art
`
`would have understood that the “blur clear converter” was intended to improve the
`
`response time of liquid crystal elements in an LCD device, but would not have known
`
`what structure or circuitry was being used to accomplish this.
`
`33. Because the term “blur clear converter” would not have been recognized
`
`as identifying any structure, device, component, or circuitry to a person of ordinary
`
`skill in the art at the time of the purported invention, I understand that this term is a
`
`means-plus-function claim term. I further understand that a means-plus-function
`
`claim term should be interpreted by identifying the function it performs, and then
`
`identifying the structure that is clearly linked to the performance of that function in
`
`the specification of the patent. Based on this understanding, I interpret the function
`
`of the “blur clear converter” as (1) “receiving frame data every frame period,” (2)
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`“delaying current frame data to generate delayed frame data,” and (3) “generating a
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`plurality of overdriven pixel data within every frame period for each pixel.”
`
`34. The ’843 Patent describes two embodiments of a “blur clear converter”
`
`for performing these functions. In the first embodiment, a first image memory is
`
`controlled by a first memory controller to delay current pixel data for a frame period.
`
`’843 Patent at 4:49-53 & Fig. 7. The first embodiment also describes a processing
`
`circuit that generates a plurality of overdriven pixel data according to the current pixel
`
`data and the delayed pixel data stored in the first image memory. ’843 Patent at 4:53-
`
`55 & Fig. 7. The ’843 Patent does not disclose how the processing circuit generates
`
`the plurality of pixel data; it does not, for example, provide an algorithm or circuit for
`
`determining an overdriven pixel value based on a current pixel value and a preceding
`
`pixel value. Thus, I interpret the structure for the “blur clear converter” as
`
`constituting an image memory and corresponding memory controller for generating
`
`pixel data that is delayed by a frame period, as well as some type of processing circuit
`
`for determining a plurality of overdriven pixel data according to the current pixel data
`
`and the delayed pixel data stored in the image memory. I understand that the
`
`structure for the “blur clear converter” may also include equivalents of the image
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`memory, memory controller, and processing circuit.
`
`VI. Overview of the State of the Art
`
`
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`12
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`Page 13
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`35.
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`It is my opinion that the use of LCD devices for the display of moving
`
`pictures was well-known to those of ordinary skill in the art at the time of the
`
`purported invention of the ’843 Patent. Active Matrix LCDs (“AMLCD”), in which
`
`each pixel of an LCD panel includes a switching device, were known in the industry
`
`and sold to consumers in the late 1980s and early 1990s. My own work at G&E in
`
`the 1980s included the development of AMLCDs for avionics applications.
`
`AMLCDs were also used in small consumer televisions in the late 1980s. In the early
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`1990s, various computer manufacturers included AMLCDs in their notebook
`
`computer products. I myself was employed by Apple in the early 1990s, and
`
`supervised the design of the AMLCD for Apple’s first Powerbook notebook
`
`computer. A schematic diagram of an AMLCD panel designed by Hitachi is shown in
`
`the 1993 textbook LIQUID CRYSTAL FLAT PANEL DISPLAYS authored by William C.
`
`O’Mara (“the O’Mara Textbook”),1 and, in my opinion, is typical of the AMLCD
`
`
`1 The O’Mara Textbook has a copyright date of 1993 and a Library of Congress stamp
`
`dated April 2, 1993. See Ex. Sony-1009 at p.4 (copyright page). The U.S. Copyright
`
`Office record for the O’Mara textbook shows a publication date of March 26, 1993,
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`evidencing that the O’Mara Textbook was published at least as early as March 26,
`
`1993. Id. at p.1 (Copyright Office record).
`
`13
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`Page 14
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`panels used in consumer display devices throughout the 1990s and at the filing date of
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`the ’843 Patent:
`
`Ex. Sony-1009 at 34.
`
`A. Blurring in the Display of Moving Pictures as a Result of the Slow
`Response Time of Liquid Crystal Elements Was Well Known in the Art
`
`36.
`
`In my opinion, the slow response time of LCD crystals was a well-
`
`
`
`known issue to those of ordinary skill in the art at the time of the purported
`
`invention, and widely recognized to cause deterioration in the quality of moving image
`
`display, such as blurring. Indeed, each of the prior art references I reviewed describes
`
`the existence of this problem.
`
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`14
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`Page 15
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`37.
`
`Suzuki states that “[l]iquid crystal cells vary in transmittance relatively
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`slowly. Consequently, in displaying moving images in particular, blurs in which data
`
`of previous frames appear overlapped (image trails) tend to occur. This phenomenon
`
`is unique to liquid crystal display device, not seen in CRTs (Cathode Ray Tubes).”
`
`Suzuki at ¶ 4.
`
`38. Likewise, Nitta states that “TFT liquid crystal displays, which are active
`
`matrix liquid crystal display devices, are widely used as display devices,” but that
`
`“upon displaying television images on a liquid crystal display, or displaying moving
`
`pictures such as playing a digital video disk (DVD), because of the slow response
`
`speed in displaying intermediate gradations, afterimages occur, and the display
`
`properties are degraded. Thus, the challenge in adapting TFT liquid crystal displays to
`
`multimedia is to solve these problems.” Nitta at ¶ 2.
`
`39. Lee acknowledges that “LCDs are used in notebook computers as well
`
`as desktop computers. Computer users desire to see moving pictures by using the
`
`computers provided with developed multimedia environment. Thus, it is necessary to
`
`improve the response speed of the LCDs.” Lee at ¶ 5.
`
`40.
`
`Finally, Jinda describes that “the liquid crystal display cannot obtain vivid
`
`images in displaying dynamic images in comparison with the CRT (Cathode Ray
`
`Tube) type display. The liquid crystal employed in the liquid crystal display have a
`
`slower response speed with regard to its transmittance to the applied voltage . . . and
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`are accordingly unable to sufficiently respond to rapid changes in the image signal.”
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`Jinda at ¶ 2.
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`41. As evidenced by these publications, it is my opinion that the issue of
`
`slow liquid crystal response time resulting in blurring in the display of moving pictures
`
`on LCD devices was well known by those of ordinary skill in the art at the time of the
`
`purported invention .
`
`B. The Overdrive Method was Well Known in the Art as a Technique for
`Accelerating the Response Time of Liquid Crystal Elements
`
`42.
`
` As acknowledged in the ’843 Patent, the overdriving method was well
`
`known by those of ordinary skill in the art at the time of the purported invention as a
`
`technique for improving the display of moving images prior to the filing date of the
`
`’843 Patent. ’843 Patent at 1:56-2:7. The ’843 Patent identifies U.S. Patent
`
`Application Publication No. 2002/0050965 as “one of the references of the
`
`conventional overdriving method.” Id. at 1:60-62. Likewise, each of the prior art
`
`references I reviewed discusses the overdrive method, further demonstrating that this
`
`technology was well understood by those of ordinary skill in the art at the time of the
`
`purported invention.
`
`43.
`
`Suzuki states that “techniques named as an overdrive method and an
`
`overshoot method have been developed for the sake of improved moving image
`
`display performance,” and identifies Japanese Unexamined Patent Application
`
`
`
`16
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`Page 17
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`
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`Publication No. 2001-125067 as disclosing “[a]n overview of the overdrive method
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`and overshoot method.” Suzuki at ¶¶ 5-6.
`
`44.
`
`Jinda also identifies an earlier publication, “Japanese Patent Laid-Open
`
`Publication No. HEI 6-62355,” as disclosing “a method for improving the reduction
`
`in the response speed of liquid crystals” by “superimposing a difference component
`
`by comparison with the previous image signal.” Jinda at ¶ 4. Although Jinda does not
`
`refer to this method using the term “overdrive,” a person of ordinary skill in the art at
`
`the time of the filing date of the ’843 Patent would have understood Jinda as
`
`describing the overdrive method, because “superimposing a difference component by
`
`comparison with the previous image signal” means increasing or decreasing the level
`
`of the current image signal to emphasize the difference between the current image
`
`signal and the previous image signal. In other words, the current image signal is raised
`
`to a higher level when the preceding image signal was at a lower level, and the current
`
`image signal is decreased to a lower level when the preceding image was at a higher
`
`level. In my opinion, a person of ordinary skill in the art at the time of the purported
`
`invention would have understood this method as an example of the overdrive
`
`method described in the ’843 Patent, which states that overdriving “means applying a
`
`higher or a lower data impulse to the pixel electrode to accelerate the reaction speed
`
`of the liquid crystal molecules.” ’843 Patent at 2:2-7.
`
`
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`17
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`Page 18
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`45.
`
`Similarly, while not using the term “overdrive,” Nitta identifies the
`
`earlier Japanese patent publication JP-11-044874-A as disclosing “an example of a
`
`drive method that improves the response speed by superimposing on the display
`
`signal a signal that emphasizes changes in the display signal.” Nitta at ¶ 4. Again, it is
`
`my opinion that this would be understood by a person of ordinary skill in the art at
`
`the time of the purported invention as describing the overdrive method, because
`
`emphasizing the change in the display signal means increasing the level of the display
`
`signal when the preceding image signal was lower, and decreasing the level of the
`
`display signal when the preceding image signal was higher.
`
`46. Lee states that “[o]ne exemplary technique for improving the response
`
`speed of the LCDs is dynamic capacitance compensation (‘DCC’).” Lee at ¶ 7. As
`
`described by Lee, DCC processes data “by comparing gray value for a pixel in a
`
`previous frame with gray value for a pixel in a current frame and adding a
`
`predetermined value larger than the difference between the gray values to the gray
`
`value of the previous frame,” effectively increasing the voltage level for the current
`
`frame and thus “minimiz[ing] the time delay by applying a voltage larger than the
`
`predetermined voltage for a given gray to the pixel.” Id. at ¶ 8. Accordingly, in my
`
`opinion, a person of ordinary skill in the art at the time of the purported invention
`
`would have understood the existing DCC method described by Lee as an example of
`
`an overdrive operation as described in the ’843 Patent.
`18
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`
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`Page 19
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`
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`47. Thus, as acknowledged by the ’843 Patent and demonstrated by the prior
`
`art publications described above, it is my opinion that the overdrive method was well
`
`known by those of ordinary skill in the art at the time of the purported invention.
`
`C. Use of a Source Driver to Send Data Voltages on the Data Lines of an
`LCD Device Was Well Known in the Art
`
`48.
`
`It is my opinion that the use of a source driver to convey data voltages
`
`
`
`to the pixels of an LCD device via corresponding data lines was well known to those
`
`of ordinary skill in the art at the time of the purported invention of the ’843 Patent.
`
`For example, the 1993 textbook LIQUID CRYSTAL FLAT PANEL DISPLAYS authored by
`
`William C. O’Mara shows a schematic diagram for an AMLCD panel designed by
`
`Hitachi:
`
`19
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`
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`Page 20
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`
`
`Ex. Sony-1009 at 34.
`
`49. As shown in the O’Mara Textbook, a conventional AMLCD panel
`
`included multiple data lines, with each data line connected to each pixel in a
`
`corresponding column of pixels. The diagram presented in the O’Mara Textbook
`
`shows that the data lines are connected to a “data input” block. In my opinion, a
`
`person of ordinary skill in the art would have understood that the “data input” block
`
`represented a source driver for generating the data voltages to be applied to the data
`
`lines. For example, the 2003 Ham U.S. patent application publication, which has a
`
`filing date of November 27, 2001, describes that an “LCD driving apparatus includes
`
`a liquid crystal display panel 57 having a plurality of data lines 55,” and that “[a] data
`
`driver 53 supplies data to the data lines 55 of the liquid crystal display panel 57.”
`
`Ham at ¶ 35. Accordingly, it is my opinion that the use of a source driver to convey
`
`data voltages to the pixels of an LCD device via corresponding data lines was well
`
`known to those of ordinary skill in the art at the time of the purported invention.
`
`VII. Structure of a Conventional AMLCD Panel
`
`50. Claim 1 of the ’843 Patent purports to recite a “driving circuit for an
`
`LCD panel.” ’843 Patent at claim 1. However, claim 1 also recites the elements
`
`comprising the LCD panel itself. Specifically, claim 1 recites “the LCD panel
`
`comprising: a plurality of scan lines; a plurality of data lines; and a plurality of pixels,
`
`each pixel being connected to a corresponding scan line and a corresponding data
`20
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`Page 21
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`
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`line, and each pixel comprising a liquid crystal device and a switching device
`
`connected to the corresponding scan line, the corresponding data line, and the liquid
`
`crystal device.” Id. In my opinion, these elements constitute nothing more than a
`
`conventional AMLCD panel that was well known to those of ordinary skill in the art
`
`at the time of the purported invention of the ’843 Patent. For example, the 1993
`
`textbook LIQUID CRYSTAL FLAT PANEL DISPLAYS authored by William C. O’Mara
`
`shows a schematic diagram for an AMLCD panel designed by Hitachi:
`
`Ex. Sony-1009 at 34.
`
`
`
`
`51. As shown in the above diagram, the AMLCD panel shown in the
`
`O’Mara Textbook includes a plurality of data lines, a plurality of gate lines, and a
`
`plurality of pixels connected to a corresponding gate line and a corresponding data
`
`
`
`21
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`Page 22
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`
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`line. Ex. Sony-1009 at 34. The pixels comprise a liquid crystal (“LC”) cell connected
`
`to a thin-film transistor (“TFT”). Id. Each TFT is connected to a gate line, a data
`
`line, and a liquid crystal. Id. It is my opinion that this composition of a pixel in an
`
`LCD device was well known to those of ordinary skill in the art. For example, Ham
`
`describes that that a liquid crystal panel has “a plurality of data lines 55 and a plurality
`
`of gate lines 56 crossing each other and having TFT’s provided at each intersection to
`
`drive liquid crystal cells Clc.” Ham at ¶ 35. Fig. 5 of Ham provides a schematic
`
`diagram of an LCD driving circuit including an LCD panel (identified as element 57),
`
`and shows that a representative pixel of the LCD panel consists of a TFT connected
`
`to a liquid crystal element (liquid crystal cell Clc), a scan line, and data line connected
`
`to a data driver. Ham at ¶¶ 34-36.
`
`Ham, Fig. 5.
`
`22
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`Page 23
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`
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`Therefore, in my opinion, those of skill in the art at the time of the purported
`
`invention knew that a pixel in a conventional AMLCD panel typically comprised a
`
`TFT connected to a liquid crystal element, a scan line, and a data line.
`
`52.
`
` Further, it is my opinion that those of ordinary skill in the art at the time
`
`of the purported invention knew that a thin-film transistor (TFT) was commonly used
`
`as a switching device for the pixels of an AMLCD panel, as shown in the O’Mara
`
`Textbook. The O’Mara Textbook states that “[h]aving a switch at each pixel greatly
`
`simplifies the electronics of the flat panel display,” and that “[v]arious kinds of
`
`switches have been investigated for this application, including diodes and transistors.”
`
`Ex. Sony-1009 at 27. The O’Mara Textbook further states that “[c]urrent production
`
`displays employ . . . a MOS thin film transistor (TFT) . . . .” Id.
`
`53. Likewise, the 2001 textbook LIQUID CRYSTAL DISPLAYS authored by
`
`Ernst Lueder (“the Lueder Textbook)2 illustrates an AMLCD that uses TFTs as the
`
`switching devices for the pixels:
`
`
`2
`The Lueder Textbook has a copyright date of 2001 and a Library of Congress
`
`stamp dated 2001, evidencing that it was published at least as early as 2001. See Ex.
`
`Sony-1008 at p. 3 (copyright page).
`
`23
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`Page 24
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`
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`Ex. Sony-1008 at 18.
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`
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`54. As shown in the Lueder Textbook, the pixels of the AMLCD comprise a
`
`TFT connected to a “video information” line (i.e., a data line) and a line carrying a
`
`“gate impulse” (i.e., a gate l
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