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. IPR2015-00863
`
`__________________________________________________________________
`
`
`
`
`
`
`
`IPR2015-00863
`Petition for Inter Partes Review of U.S. Patent 7,202,843 - EXHIBIT 1014_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. IPR2015-00863
`
`__________________________________________________________________
`
`
`
`
`
`
`
`IPR2015-00863
`Petition for Inter Partes Review of U.S. Patent 7,202,843 - EXHIBIT 1014_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
`
`led a project that resulted in the development of the first poly-Silicon TFT LCD at
`
`
`
`1
`
`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
`
`
`
`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
`
`founded TLC Display Consulting, a company that provides technical consulting in the
`
`
`
`3
`
`Page 4
`
`
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`areas of flat panel displays, liquid crystal displays, and related electronics. I currently
`
`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
`
`Page 5
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`
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`16. Counsel for Sony requested that I provide analysis pertinent to the ’843
`
`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. 2002/0044115 (“Jinda”),
`
`identified as Ex. Sony-1006 in the petition;
`
`d. U.S. Patent Application Publication No. 2003/00482474 (“Ham”),
`
`identified as Ex. Sony-1007 in the petition;
`
`e. Ernst Lueder, LIQUID CRYSTAL DISPLAYS (2001), identified as Ex.
`
`Sony-1009 in the petition;
`
`f. William C. O’Mara, LIQUID CRYSTAL FLAT PANEL DISPLAYS (1993),
`
`identified as Ex. Sony-1010 in the petition;
`
`g. IEEE 100: THE AUTHORITATIVE DICTIONARY OF IEEE STANDARDS
`
`TERMS (7th ed., 2000), identified as Ex. Sony-1011 in the petition;
`
`h. MC-GRAW HILL DICTIONARY OF SCIENTIFIC AND TECHNICAL TERMS
`
`(6th ed., 2003), identified as Ex. Sony-1012 in the petition;
`
`i. MICROSOFT COMPUTER DICTIONARY (5th ed., 2002), identified as
`
`Ex. Sony-1013 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,
`6
`
`
`
`Page 7
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`
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`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
`
`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
`
`
`
`7
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`Page 8
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`
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`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
`
`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.
`
`8
`
`
`
`Page 9
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`
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`28.
`
` The ’843 Patent purports to address the blurring issue by providing a
`
`driving circuit that generates and applies a plurality of 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 “generates two pieces of pixel data in each frame period,” and includes a
`
`source driver that “generate[s] two corresponding data impulses according to the two
`
`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.
`
`V. Analysis of Claim Terms in the ’843 Patent
`
`29.
`
`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.
`
`30. Based on this understanding of how claim terms should be construed, I
`
`apply the ordinary and customary meaning of the claims terms recited in claims 4-9 of
`
`the ’843 Patent.
`
`VI. Overview of the State of the Art
`
`9
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`Page 10
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`31.
`
`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
`
`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-1010 at p.4 (copyright page). The U.S. Copyright
`
`Office record for the O’Mara textbook shows a publication date of March 26, 1993,
`
`evidencing that the O’Mara Textbook was published at least as early as March 26,
`
`1993. Id. at p.1 (Copyright Office record).
`
`10
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`Page 11
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`
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`panels used in consumer display devices throughout the 1990s and at the filing date of
`
`the ’843 Patent:
`
`Ex. Sony-1010 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
`
`32.
`
`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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`11
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`Page 12
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`
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`33.
`
`Suzuki states that “[l]iquid crystal cells vary in transmittance relatively
`
`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.
`
`34. 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.
`
`35.
`
`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 are
`
`accordingly unable to sufficiently respond to rapid changes in the image signal.” Jinda
`
`at ¶ 2.
`
`36.
`
`Finally, Ham states that “[t]he LCD has a disadvantage in that it has a
`
`slow response time due to inherent characteristics of a liquid crystal,” and that
`12
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`Page 13
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`
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`because “a liquid crystal has a response time longer than one frame interval . . . of a
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`moving picture, a voltage charge in the liquid crystal cell is progressed into the next
`
`frame prior to arriving at a target voltage. Thus, due to a motion-blurring
`
`phenomenon a screen is blurred out at the moving picture.” Ham at ¶¶ 4, 7.
`
`37. 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. Use of a Source Driver to Send Data Voltages on the Data Lines of an
`LCD Device Was Well Known in the Art
`
`38.
`
`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:
`
`
`
`13
`
`Page 14
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`
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`Ex. Sony-1010 at 34.
`
`
`
`39. 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.”
`
`
`
`14
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`Page 15
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`
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`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
`
`40. Claim 4 of the ’843 Patent purports to recite a “method for driving” an
`
`LCD panel. ’843 Patent at claim 4. However, claim 4 also recites the elements
`
`comprising the LCD panel itself. Specifically, claim 4 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
`
`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:
`
`
`
`15
`
`Page 16
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`
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`Ex. Sony-1010 at 34.
`
`
`
`
`41. 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
`
`line. Ex. Sony-1010 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
`
`
`
`16
`
`Page 17
`
`
`
`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.
`
`
`
`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.
`
`42.
`
`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
`
`
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`17
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`Page 18
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`
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`simplifies the electronics of the flat panel display,” and that “[v]arious kinds of
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`switches have been investigated for this application, including diodes and transistors.”
`
`Ex. Sony-1010 at 27. The O’Mara Textbook further states that “[c]urrent production
`
`displays employ . . . a MOS thin film transistor (TFT) . . . .” Id.
`
`43. 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:
`
`Ex. Sony-1009 at 18.
`
`
`
`
`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-1009 at p. 3 (copyright page).
`
`18
`
`
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`Page 19
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`
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`44. 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 line). Ex. Sony-1009 at 18. The Lueder Textbook states
`
`that “The TFTs are n-channel Field Effect Transistors (FETs) fabricated with thin
`
`film technology. They operate as switches in the pixels.” Id. Thus, in my opinion,
`
`the Lueder Textbook further illustrates that the LCD panel recited in claim 1 of the
`
`’843 Patent is a conventional AMLCD panel that was well known by those of ordinary
`
`skill in the art at the time of the purported invention.
`
`A. Use of Gate Driver to Send Scan Voltage to Switch Device of Pixel in
`an AMLCD Panel was Well Known in the Art
`
`45.
`
`It is my opinion that a person of ordinary skill in the art at the time of
`
`the purported invention knew that a gate driver was routinely used to send scan
`
`voltages to the pixels of a conventional AMLCD panel, in order to activate the
`
`switching device of the pixel so that a data voltage could be applied to the
`
`corresponding liquid crystal element. For example, as set forth above, the Lueder
`
`Textbook shows that the pixels of the AMLCD comprise a TFT connected to a
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`“video information” line (i.e., a data line) and a line carrying a “gate impulse” (i.e., a
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`gate line). Ex. Sony-1009 at 18. The Lueder Textbook further states that “[a]ll TFTs
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`in a row are rendered conductive by a positive gate impulse Vg,” and “[t]he video
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`19
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`Page 20
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`information is fed in through the columns and the conducting TFTs into all the pixels
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`of a row simultaneously.” Id.
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`46. The O’Mara Textbook similarly shows that the pixels of an AMLCD
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`panel comprise a TFT connected to a gate line, which is in turn connected to a “gate
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`scan.” Ex. Sony-1010 at 34. Likewise, Fig. 5 of Ham provides a schematic diagram of
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`an LCD driving circuit including a gate driver (identified as element 54), and states
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`that the “gate driver 54 applies a scanning pulse to the gate lines 56 of the liquid
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`crystal display panel 57.” Ham at ¶ 35 & Fig. 5. Ham further describes that “[t]he
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`TFT provided at each intersection between the data lines 55 and the gate lines 56
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`responds to a scanning pulse to apply data on the data lines 55 to the liquid crystal cell
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`Clc.” Id. at ¶ 36. Accordingly, it is my opinion that the use of a gate driver to convey
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`scan voltages to the switching devices of the pixels of an AMLCD panel was well
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`known to those of ordinary skill in the art at the time of the purported invention of
`
`the ’843 Patent.
`
`VIII. The Suzuki Reference
`
`47.
`
`Suzuki discloses a driving circuit for an LCD that seeks to improve the
`
`display of moving images on LCD devices. As discussed above, Suzuki recognizes
`
`that there is a time delay when applying charges to a pixel of an LCD to effect a
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`change in the transmission rate of the liquid crystal element, and that this delay can
`
`cause blurring when displaying moving images on an LCD device. Suzuki at ¶ 4.
`20
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`Page 21
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`
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`Suzuki also describes that the conventional overdrive technique was developed to
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`address this problem, but fails to resolve the issue entirely. Id. At ¶¶ 5-7.
`
`48.
`
`In order to address the blurring issue, Suzuki describes a driving circuit
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`that divides a frame period into a plurality of temporal subfields, and supplies data
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`signal voltages to each of the liquid crystal cells of an LCD panel in each subfield of
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`the frame period. Suzuki at ¶ 11. In a first embodiment of a driving circuit as taught
`
`by Suzuki, a frame period is divided into two subfields, and a data signal voltage is
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`supplied to each pixel of an LCD panel in each subfield. Suzuki at ¶¶ 39, 46, 64 &
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`Fig. 2.
`
`IX. The Nitta Reference
`
`49. Nitta teaches an LCD device and driving method for improving the
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`quality of moving pictures displayed on an LCD device. The LCD device described
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`by Nitta “has a TFT liquid crystal panel 101” having “signal lines” carrying “voltages
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`that correspond to the display data” and “gates lines “carrying “voltages that
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`correspond to the scan signals”; accordingly, it is my opinion that a person of ordinary
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`skill in the art would understand Nitta as describing a conventional AMLCD panel
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`using TFTs as the switching device for each pixel. Nitta at ¶ 32. As discussed above,
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`Nitta recognizes that there is a “blurriness” issue when displaying motion pictures on
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`an LCD device due to the slow response time of liquid crystal elements. Nitta at ¶¶ 2-
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`3. To solve this problem, Nitta discloses a liquid crystal control circuit that divides a
`21
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`Page 22
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`frame period into a plurality of temporal subdivision, referred to as “fields,” and
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`applies a data voltage to every pixel of an LCD panel in each field. In Nitta’s first
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`embodiment, “one conventionally driven frame is divided into two fields, and driving
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`is done at twice the speed.” Nitta at ¶ 27.
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`50.
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`In order to apply two data voltages within one frame period, the driving
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`circuit of Nitta uses a liquid crystal timing controller to double the speed of the
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`vertical and horizontal synchronization signals. Nitta at ¶ 47 (“[T]he liquid crystal
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`timing controller 104 supplies, to data driver 102 and scan driver 103, the liquid
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`crystal synchronization signals FLM and CL1, CL3 in which VSYNC and HSYNC
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`have accelerated two fold.”). Nitta’s driver circuit then applies the data voltages to the
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`pixels of the LCD panel according to the doubled synchronization signals. Id. at ¶¶
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`32 (“The liquid crystal display device 100 of this embodiment . . . has . . . a data (signal)
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`driver 102 that conveys to the signal lines of the TFT liquid crystal panel 101 voltages
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`that correspond to the display data . . . .”), 49 (“according to CL1, gradation voltages
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`corresponding to the OUTdata are supplied to the signal lines”).
`
`A. The “Signal Lines” Described by Nitta are the “Data Lines”
`Described in the ’843 Patent
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`51. Nitta uses the term “signal lines” to refer to the lines that convey data
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`voltages to the TFTs of an LCD panel, rather than the term “data lines” as recited in
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`the claims of the ’843 Patent. Nitta at ¶¶ 9, 32.
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`22
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`Page 23
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`52.
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`In my opinion, a person of ordinary skill in the art at the time of the
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`purported invention would have understood the “signal lines” of Nitta as the “data
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`lines” recited in the claims of the ’843 Patent. As stated in Nitta, the disclosed LCD
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`device comprises “a data (signal) driver 102 that conveys to the signal lines of the
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`TFT liquid crystal panel 101 voltages that correspond to the display data . . . .” Nitta
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`at ¶ 32. Likewise, the ’843 Patent states that “data voltages are applied to the data
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`lines 34 and transmitted to the pixel electrodes 30 through the switching devices 38.”
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`’843 Patent at 3:47-51. Both the “signal lines” of Nitta and the “data lines” of the
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`’843 Patent are used to convey data voltages to the pixels of an LCD panel, as
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`opposed to scan or gate signals. Therefore, it is my opinion that a person of ordinary
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`skill in the art at the time of the purported invention would have understood that the
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`“signal lines” of Nitta are the “data lines” of the ’843 Patent.
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`X. Suzuki in View of Nitta
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`53.
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`It is my opinion that a person of ordinary skill in the art at the time of
`
`the purported invention of the ’843 Patent would have had reason to combine the
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`conventional AMLCD panel described by Nitta with the driving circuit taught by
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`Suzuki. Suzuki teaches a driving circuit for a conventional LCD panel, but does not
`
`describe the details of the conventional LCD panel. Nitta describes a conventional
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`AMLCD panel, having “multiple scan lines,” “multiple signal [i.e., data] lines,” and
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`multiple pixels located at the intersections of the data lines and scan lines. Nitta at ¶
`23
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`Page 24
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`
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`32. Fig. 3 of Nitta illustrates this conventional AMLCD panel, which is identified as a
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`“TFT liquid crystal panel.” Id. Accordingly, it is my opinion that a person of ordinary
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`skill in the art at the time of the purported invention would have understood that the
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`TFT liquid crystal panel of Nitta was an AMLCD panel using TFTs as the switching
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`devices for the pixels; as discussed above, those of skill in the art knew that TFTs
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`were routinely used for that purpose.
`
`Nitta, Fig. 3.
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`
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`54. Accordingly, it is my opinion that a person of ordinary skill in the art at
`
`the time of the purported invention of the ’843 Patent would have combined the
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`conventional AMLCD panel taught by Nitta with the driving circuit disclosed by
`
`Suzuki. As discussed above, both Suzuki and Nitta seek to address the issue of blur in
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`the display of moving pictures on LCD devices by applying a plurality of data voltages
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`to each pixel of an LCD device within a single frame period. Suzuki at ¶¶ 4, 11, 39,
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`24
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`Page 25
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`
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`42, 44, 46; Nitta at ¶¶ 2-3, 27-28, 32, 37, 47, 49, 50-51. Therefore, because both
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`Suzuki and Nitta are directed to the issue of blurring in the display of moving pictures
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`on LCD devices, and approach the issue in a similar manner, it is my opinion that a
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`person of ordinary skill in the art at the time of the purported invention would have
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`combined their teachings. In particular, it is my opinion that a person of ordinary skill
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`in the art would have recognized that the driving c
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