UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`SONY CORPORATION, SAMSUNG ELECTRONICS CO., LTD., and
`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
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`
`OF U.S. PATENT NO. 7,202,843
`
`No. IPR2015-00863
`__________________________________________________________________
`
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`

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`
`
`Table of Contents
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`
`Page
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`I. Mandatory Notices (37 C.F.R. § 42.8) .............................................................................. 1
`III. Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3))
` and Relief Requested (37 C.F.R. § 42.22(a)(1)) ............................................................ 2
`A. Background of the ’843 Patent .................................................................................... 2
`B. Printed Publications Relied On ................................................................................... 3
`1. Sony-1003: U.S. Patent Application Publication
` No. 2003/0156092 (August 21, 2003) (“Suzuki”) ............................................... 3
`2. Sony-1004, Sony-1005: Japanese Laid Open Patent Application
` No. 2002-132224 (May 9, 2002) and
` Certified English Translation Thereof (“Nitta”) .................................................. 4
`3. Sony-1006: U.S. Patent Application Publication
` No. 2002/0044115 (April 18, 2002) (“Jinda”)...................................................... 6
`4. Sony-1007: U.S. Patent Application Publication
` No. 2003/0048247 (March 13, 2003) (“Ham”) ................................................... 7
`C. Statutory Grounds for Challenge ................................................................................ 8
`D. Claim Construction ...................................................................................................... 8
`IV. How the Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)-(5)) ....... 8
`A. Claims 4-9 Would Have Been Obvious Over Suzuki in View of Nitta ................ 9
`1. Claim 4 ....................................................................................................................... 9
`i. A method for driving a liquid crystal display (LCD) panel, ............................ 9
`ii. the LCD panel comprising: .............................................................................. 10
`a. a plurality of scan lines; ................................................................................. 12
`b. a plurality of data lines; ................................................................................. 12
`c. 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, ......... 13
`iii. and the method comprising: receiving continuously
` a plurality of frame data, .................................................................................. 16
`iv. generating a plurality of data impulses for each pixel within
` every frame period according to the frame data; and .................................. 16
`v. applying the data impulses to the liquid crystal device of
`one of the pixels within one frame period via the data line
`connected to the pixel in order to control a transmission
`rate of the liquid crystal device of the pixel. ............................................... 19
`
`
`
`
`
`ii
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`

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`2. Claim 5: The method of claim 4 further comprising: delaying
`the frame data to generate a plurality of corresponding
`delayed frame data; and comparing current frame data and
`corresponding delayed data to determine voltage values of
`the data impulses when generating the data impulses. ....................................... 21
`3. Claim 6: The method of claim 5 wherein the data impulses
`are a first data impulse and a second data impulse applied to
`the liquid crystal device of the pixel in sequence with the frame period. ........ 23
`4. Claim 7: The method of claim 6 further comprising determining
` a difference between the first data impulse and the second
` data impulse according to the current frame data and the
` corresponding delayed frame data. ...................................................................... 24
`5. Claim 8: The method of claim 4 further comprising: applying
`a scan line voltage to the switch device of the pixel via the scan
`line connected to the pixel in order to have the data impulses be
`applied to the liquid crystal device of the pixel. .................................................. 26
`6. Claim 9: The method of claim 4 wherein each frame data comprises
` a plurality of pixel data, and each pixel data corresponds to a pixel. ................ 28
`B. Claims 4-9 Would Have Been Obvious Over Jinda in View of Nitta ................. 30
`1. Claim 4 ...................................................................................................................... 31
`i. A method for driving a liquid crystal display (LCD) panel, .......................... 31
`ii. 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 display
` device and a switching device connected to the corresponding
` scan line, the corresponding data line, and the liquid crystal device, .......... 31
`a. a plurality of scan lines; .................................................................................. 32
`b. a plurality of data lines; ................................................................................. 33
`c. 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, ...... 33
`iii. and the method comprising: receiving continuously a
` plurality of frame data, ...................................................................................... 34
`iv. generating a plurality of data impulses for each pixel
` within every frame period according to the frame data; ................................ 34
`
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`iii
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`v. and applying the data impulses to the liquid crystal device
`of one of the pixels within one frame period via the data
`line connected to the pixel in order to control a transmission
` rate of the liquid crystal device of the pixel. .................................................. 36
`2. Claim 5: The method of claim 4 further comprising: delaying
`the frame data to generate a plurality of corresponding delayed
`frame data; and comparing current frame data and corresponding
`delayed data to determine voltage values of the data impulses
`when generating the data impulses. ...................................................................... 38
`3. Claim 6: The method of claim 5 wherein the data impulses are
` a first data impulse and a second data impulse applied to
` the liquid crystal device of the pixel in sequence within the frame period. .... 40
`4. Claim 7: The method of claim 6 further comprising determining
` a difference between the first data impulse and the second
` data impulse according to the current frame data and the
` corresponding delayed frame data. ...................................................................... 41
`5. Claim 8: The method of claim 4 further comprising: applying
` a scan line voltage to the switch device of the pixel via
` the scan line connected to the pixel in order to have the data
` impulses be applied to the liquid crystal device of the pixel............................. 43
`6. Claim 9: The method of claim 4 wherein each frame data comprises
` a plurality of pixel data, and each pixel data corresponds to a pixel. ................ 44
`C. Claims 4, 8, and 9 Would Have Been Obvious in View of Ham ........................ 45
`1. Claim 4 ..................................................................................................................... 45
`i. A method for driving a liquid crystal display (LCD) panel, ............................ 45
`ii. The LCD panel comprising: .............................................................................. 46
`a. a plurality of scan lines; .................................................................................. 46
`b. a plurality of data lines; .................................................................................. 47
`c. 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, ...... 47
`iii. and the method comprising: receiving continuously a
` plurality of frame data; ...................................................................................... 48
`iv. generating a plurality of data impulses for each pixel
` within every frame period according to the frame data; ............................... 49
`v. and applying the data impulses to the liquid crystal device
`of one of the pixels within one frame period via the data
`line connected to the pixel in order to control a transmission
`rate of the liquid crystal device of the pixel. .................................................... 50
`iv
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`v
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`2. Claim 8: The method of claim 4 further comprising: applying
`a scan line voltage to the switch device of the pixel via the scan
`line connected to the pixel in order to have the data impulses be
`applied to the liquid crystal device of the pixel. .................................................. 51
`3. Claim 9: The method of claim 4 wherein each frame data
`comprises a plurality of pixel data, and each pixel data
`corresponds to a pixel. ........................................................................................... 52
`V. The Grounds Related to Suzuki, Jinda, and Ham
` Are Not Redundant of One Another ........................................................................... 53
`VI. Conclusion ..................................................................................................................... 54
`VII. Abridged Claim Charts ............................................................................................... 54
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`
`Exhibit List
`
`U.S. Patent No. 7,202,843
`Publicly Available File History of U.S. Patent No. 7,202,843
`U.S. Patent Application Publication No. 2003/0156092 (August
`21, 2003)
`Japanese Laid Open Patent Application No. 2002-132224 (May 9,
`2002)
`Certified Translation of Japanese Laid Open Patent Application
`No. 2002-132224
`U.S. Patent Application Publication No. US 2002/0044115 (April
`18, 2002)
`U.S. Patent Application Publication No. 2003/0048247 (March
`13, 2003)
`U.S. Patent Application Publication No. 2004/0196229 (October
`7, 2004)
`Ernst Lueder, LIQUID CRYSTAL DISPLAYS (2001)
`William C. O’Mara, LIQUID CRYSTAL FLAT PANEL DISPLAYS
`(1993)
`IEEE 100: THE AUTHORITATIVE DICTIONARY OF IEEE
`STANDARDS TERMS (7th ed., 2000)
`MCGRAW-HILL DICTIONARY OF SCIENTIFIC AND TECHNICAL
`TERMS (6th ed., 2003)
`MICROSOFT COMPUTER DICTIONARY (5th ed., 2002)
`Declaration of Thomas Credelle
`Curriculum Vitae of Thomas Credelle
`
`
`Ex. Sony-1001
`Ex. Sony-1002
`Ex. Sony-1003
`
`Ex. Sony-1004
`
`Ex. Sony-1005
`
`Ex. Sony-1006
`
`Ex. Sony-1007
`
`Ex. Sony-1008
`
`Ex. Sony-1009
`Ex. Sony-1010
`
`Ex. Sony-1011
`
`Ex. Sony-1012
`
`Ex. Sony-1013
`Ex. Sony-1014
`Ex. Sony-1015
`
`
`
`vi
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`

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`I. Mandatory Notices (37 C.F.R. § 42.8)
`
`
`
`Real Party-in-Interest: Sony Corporation, Samsung Electronics, Co., Ltd., and
`
`Samsung Display Co., Ltd. (“Petitioners”); Sony Electronics, Inc., Sony Corporation
`
`of America, and Samsung Electronics America, Inc.
`
`Related Matters: The following matters would affect or be affected by the decision in
`
`this proceeding: Surpass Tech Innovation LLC v. Sharp Corp., et al., No. 14-cv-00338-LPS
`
`(D. Del.); Surpass Tech Innovation LLC v. Samsung Display Co., Ltd., et al., No. 14-cv-
`
`00337-LPS (D. Del.); Surpass Tech Innovation LLC v. LG Display Co. Ltd., et al., No. 14-
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`cv-00336-LPS (D. Del.); and Sharp Corp. v. Surpass Tech Innovation LLC, IPR2015-
`
`00021 (P.T.A.B.); Petitioners’ IPR 2015-000862 (P.T.A.B.).
`
`Counsel: Lead Counsel: Michelle Carniaux (Reg. No. 36,098), Backup Counsels:
`
`Lewis Popovski (Reg. No. 37,423), and Aaron Zakem (Reg. No. 72,521), all of
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`Kenyon & Kenyon LLP; and Backup Counsel: Jay I. Alexander (Reg. No. 32,678), of
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`Covington & Burling LLP.
`
`Electronic Service: Sony-SurpassTech@kenyon.com
`
`Post and Delivery: Kenyon & Kenyon LLP, One Broadway, New York, NY 10004.
`
`Telephone: 212-425-7200
`
`
`
`
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`Facsimile: 212-425-5288
`
`II. Grounds for Standing (37 C.F.R. § 42.104(a))
`
`Petitioners certify that the patent for which review is sought, U.S. Patent No.
`
`7,202,843 (“the ’843 Patent,” Sony-1001), is available for inter partes review and that
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`1
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`
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`Petitioners are not barred or estopped from requesting an inter partes review
`
`challenging the patent claims on the grounds identified in this petition.
`
`III. Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1))
`
`
`
`Petitioners challenge claims 4-9 of the ’843 Patent under 35 U.S.C. § 103.
`
`Cancellation of those claims is requested. In support of the following grounds,
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`Petitioners submit the declaration of technical expert Thomas Credelle (Sony-1014).
`
`A. Background of the ’843 Patent
`
`
`
`The ’843 Patent describes the invention as a driving circuit of a liquid crystal
`
`display (LCD) panel, and more particularly a driving circuit and method for decreasing
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`the reaction time of a liquid crystal element by applying two data impulses to a pixel
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`electrode within one frame period. ’843 Patent at 1:8-12.
`
`
`
`According to the ’843 Patent, LCD devices have a disadvantage compared to
`
`traditional Cathode Ray Tube (CRT) displays due to the characteristics of liquid
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`crystal molecules. Id. at 1:20-24. To drive a pixel in an LCD device, a driving circuit
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`applies a charge to the pixel which corresponds to a desired gray level for the pixel.
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`Id. at 1:39-52. The charge causes the pixel’s liquid crystal molecules to “twist” to a
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`desired transmission rate (i.e., brightness level). Id. at 1:19-24, 1:53-65. The driving
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`circuit outputs the appropriate charge based on input frame data, which defines the
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`gray level that each pixel must reach within a frame period. Id. at 1:27-35. However,
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`“[t]here is a time delay when charging liquid crystal molecules. . . . Such a delay causes
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`
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`2
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`

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`
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`blurring.” Id. at 1:62-2:2. 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.,
`
`charges) to each pixel of an LCD device within a single frame period. Id. at 2:33-48.
`
`In the driving circuit, a source driver “generate[s] corresponding data line voltages . . .
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`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. Thus, the data impulses are voltages applied
`
`to the pixels of the LCD panel. Credelle Decl. at ¶ 28. The impulses are generated
`
`based on values determined 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. Id. at 2:33-40, 4:49-55, 5:11-13.
`
`B. Printed Publications Relied On
`
`Petitioners rely on the following patents and publications:
`
`1. Sony-1003: U.S. Patent Application Publication No. 2003/0156092
`(August 21, 2003) (“Suzuki”)
`
`Suzuki was filed on September 30, 2002 and published on August 21, 2003, and
`
`
`
`is prior art to the ’843 Patent under at least 35 U.S.C. § 102(e). Suzuki was not cited
`
`during the prosecution of the ’843 Patent.
`
`
`
`Suzuki discloses a driving circuit for an LCD that seeks to improve the display
`
`of moving images on LCD devices. Like the ’843 Patent, Suzuki recognizes that there
`
`is a time delay when applying a charge to a pixel of an LCD to alter its brightness level,
`
`which can result in blurring of displayed images. Suzuki at ¶ 4. To address the
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`
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`3
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`

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`
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`blurring issue, Suzuki describes a driving circuit that divides a frame period into a
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`plurality of temporal subfields, and supplies data signal voltages (i.e., data impulses) to
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`each of the liquid crystal cells of an LCD panel in each subfield of the frame period.
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`Suzuki at ¶¶ 11, 39, 42, 44, 46. Accordingly, multiple data impulses are applied to
`
`each pixel of the LCD panel within every frame period. Id. Like the ’843 Patent,
`
`Suzuki discloses that the driving circuit includes a memory for storing the pixel data
`
`for a preceding frame, and that overdriven data is determined based on the current
`
`frame’s pixel data and the preceding frame’s pixel data. Suzuki at ¶¶ 9, 11.
`
`
`
`2. Sony-1004, Sony-1005: Japanese Laid Open Patent Application No.
`2002-132224 (May 9, 2002) and Certified English Translation Thereof
`(“Nitta”)
`
`Nitta was published on May 9, 2002, and is prior art to the ’843 Patent under at
`
`
`
`least 35 U.S.C. § 102(b). All citations to Nitta herein refer to the certified English
`
`translation of the Japanese Patent Office publication, provided herewith as Exhibit
`
`Sony-1005. Nitta was not cited during the prosecution of the ’843 Patent.
`
`
`
`Nitta teaches a liquid crystal display device and drive method that “can display
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`moving pictures with high picture quality in an active matrix liquid crystal display
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`device.” Nitta at ¶ 1. Like the ’843 Patent, Nitta acknowledges the “blurriness” issue
`
`when displaying moving pictures on LCD devices because “the response speed of the
`
`liquid crystal material is equal to or slower than the frame period of the display
`
`signal.” Id. at ¶¶ 2-3.
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`
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`4
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`

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`
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`To solve this problem, Nitta discloses a liquid crystal control circuit that divides
`
`a frame period into a plurality of temporal subdivisions, referred to as “fields,” and
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`applies a driving signal to every pixel of an LCD panel in each field. Nitta at ¶ 9.
`
`Specifically, in the first embodiment disclosed in Nitta, “one conventionally driven
`
`frame is divided into two fields, and driving is done at twice the speed.” Id. at ¶ 27. A
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`first signal voltage is applied to each pixel of the LCD panel during the time interval
`
`of the first field of the frame period, and a second signal voltage is applied to each
`
`pixel of the LCD panel during the time interval of the second field of the frame
`
`period. Id. at ¶¶ 50-51. The level of the signal voltage applied to each pixel
`
`corresponds to the image data for each pixel. Id. In order to apply two signals within
`
`one frame period, the driving circuit of Nitta uses a liquid crystal timing controller to
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`double the speed of the vertical and horizontal synchronization signals. Id. at ¶ 47
`
`(“[T]he liquid crystal timing controller 104 supplies, to data driver 102 and scan driver
`
`103, the liquid crystal synchronization signals FLM and CL1, CL3 in which VSYNC
`
`and HSYNC have accelerated two fold.”). Nitta’s driver circuit then applies the data
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`signals to the pixels of the LCD panel according to the doubled synchronization
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`signals. Id. at ¶¶ 32 (“The liquid crystal display device 100 of this embodiment . . .
`
`has . . . a data (signal) driver 102 that conveys to the signal lines of the TFT liquid
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`crystal panel 101 voltages that correspond to the display data . . . .”), 49 (“according to
`
`CL1, gradation voltages corresponding to the OUTdata are supplied to the signal
`
`lines”).
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`5
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`

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`
`
` 3. Sony-1006: U.S. Patent Application Publication No. 2002/0044115
`(April 18, 2002) (“Jinda”)
`
`Jinda was filed on August 2, 2001 and published on April 18, 2002, and is prior
`
`
`
`art to the ’843 Patent under at least 35 U.S.C. § 102(b). Jinda was cited, but not
`
`discussed, during the prosecution of the ’843 Patent.
`
`
`
`Jinda discloses a driving circuit and method for an LCD device for improving
`
`the display quality of moving images. Like the ’843 Patent, Jinda states that LCD
`
`devices have a disadvantage in displaying moving images compared to CRT devices
`
`due to the slow response speed of liquid crystals with respect to changes in
`
`transmittance. Jinda at ¶ 2. To solve this issue, Jinda discloses an LCD device and
`
`driving method wherein a plurality of data signal voltages (i.e., data impulses) are
`
`applied to the pixels of an LCD panel within one vertical synchronization interval. Id.
`
`at ¶¶ 8-10, 37-38.1 Like the ’843 Patent, image data is stored in memory to create
`
`delayed frame data, and the value of the signals to be applied to the LCD panel are
`
`1 A “vertical synchronization interval” as used in Jinda is a frame period. Credelle
`
`Decl. at ¶¶ 58-60. As shown in Fig. 2 of Jinda, image data is read into a “frame
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`memory” in one vertical synchronization interval. Jinda at ¶¶ 37-38. The image data
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`read in during the period of one vertical synchronization interval includes image data
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`for each pixel of an LCD device. Jinda at ¶¶ 8-9; Credelle Decl. at ¶¶ 58-59. A frame
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`is a complete screen or picture; accordingly, a vertical synchronization interval as
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`described in Jinda is a frame period. Credelle Decl. at ¶¶ 60.
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`6
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`determined based on comparing the delayed frame data and the current frame data.
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`Id. at ¶¶ 37-38.
`
`4. Sony-1007: U.S. Patent Application Publication No. 2003/0048247
`(March 13, 2003) (“Ham”)
`
`Ham was filed on November 27, 2001 and published on March 13, 2003, and is
`
`
`
`prior art to the ’843 Patent under at least 35 U.S.C. § 102(e).
`
`Like the ’843 Patent, Ham acknowledges that LCD technology has “a
`
`disadvantage in that it has a slow response time due to inherent characteristics of a
`
`liquid crystal.” Ham at ¶ 4. Ham then describes a method and apparatus for driving a
`
`liquid crystal display to enhance picture quality. Ham states that due to the slow
`
`response time of liquid crystals, a target brightness level cannot be reached within a
`
`single frame period, causing blurring in the display of moving images. Id. at ¶¶ 7-8.
`
`In order to address this issue, Ham applies two analog data signals (i.e., data impulses)
`
`to the liquid crystal cells of an LCD within a single frame period. Id. at ¶¶ 20-22, 39.
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`As in the ’843 Patent, the circuit taught by Ham includes a frame memory for storing
`
`delayed frame data for a preceding frame period. Id. at ¶ 40 & Fig. 6. The value of
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`the first data signal applied within the frame period is determined based on a
`
`comparison of the current frame data and the delayed frame data stored in the frame
`
`memory. Id. at ¶¶ 40-41.
`
`During prosecution of the ’843 Patent, the examiner cited U.S. Patent
`
`Application Publication No. 2004/0196229 (“the ’229 Publication”), which is a
`
`
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`7
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`
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`continuation of Ham. The examiner discussed the ’229 Publication in a single
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`sentence, and did not appear to appreciate that the ’229 Publication (like Ham)
`
`teaches a data driver that generates two data impulses for each pixel of an LCD panel
`
`within a single frame period, as well as a gate driver that scans all lines of an LCD
`
`panel twice within a single frame period. Ex. Sony-1002, October 31, 2006 Reason
`
`for Allowance at 2; ’229 Publication at ¶¶ 40-41; Ham at ¶¶ 38-39.
`
`C. Statutory Grounds for Challenge
`
`Cancelation of claims 4-9 is requested on the following grounds:
`
`A. Claims 4-9 are invalid under 35 U.S.C. § 103 as being obvious over Suzuki
`
`in view of Nitta.
`
` B. Claims 4-9 are invalid under 35 U.S.C. § 103 as being obvious over Jinda in
`
`view of Nitta.
`
`C. Claims 4, 8, and 9 are invalid under 35 U.S.C. § 103 as being obvious over
`
`Ham.
`
`D. Claim Construction
`
`Generally, the claim terms should be given their broadest reasonable
`
`construction in view of the specification, and should be construed in accordance with
`
`their ordinary meaning.
`
`IV. How the Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)-
`(5))
`
`The challenged claims are invalid for the reasons discussed below.
`
`
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`8
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`

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`
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`A. Claims 4-9 Would Have Been Obvious Over Suzuki in View of Nitta
`
`
`The crux of the alleged invention of independent claim 4 of the ’843 Patent is
`
`generating multiple data impulses for the pixels of an LCD panel within every frame
`
`period according to received frame data, and applying multiple data impulses to one
`
`of the pixels within a single frame period. ’843 Patent at 1:8-12, 5:45-55 & claim 4.
`
`The remaining elements recited in claim 4 are directed to nothing more than the
`
`structure of a conventional LCD panel. Id., claim 4; Credelle Decl. at ¶ 40.
`
`As described in detail below, both Suzuki and Nitta expressly disclose the crux
`
`of claim 4. Suzuki also discloses an LCD panel but does not expressly describe its
`
`structure. Nitta, however, describes the structural elements of a conventional LCD
`
`panel. Thus, the combination of Suzuki and Nitta discloses every element of claim 4,
`
`and therefore renders this claim invalid as obvious. And, as described in detail below,
`
`the combination of Suzuki and Nitta also renders dependent claims 5-9 obvious.
`
`1. Claim 4
`
`For the reasons set forth below, the combination of Suzuki and Nitta renders
`
`claim 4 obvious, and thus invalid under 35 U.S.C. § 103.
`
`
`
`i. A method for driving a liquid crystal display (LCD) panel,
`
`Suzuki teaches a “display control device of a liquid crystal panel for controlling
`
`display data to be displayed on the liquid crystal panel,” in which a timing control unit
`
`“outputs driving signals according to the received display data.” Suzuki at ¶¶ 2, 10.
`
`Thus, Suzuki discloses the preamble of claim 4. Likewise, Nitta teaches “a liquid
`9
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`
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`crystal display device drive method” for a LCD device that has “a signal driver
`
`circuit.” Nitta at ¶¶ 1, 9. As such, Nitta also discloses the preamble of claim 4.
`
`
`
`ii. the LCD panel comprising:
`
`Although claim 4 purports to recite a “method for driving” an LCD panel, the
`
`claim also sets forth elements directed to the LCD panel itself. Specifically, according
`
`to claim 4, the LCD panel to be driven by the “method for driving” comprises scan
`
`lines, data lines, and pixels, and is nothing more than a conventional LCD panel that
`
`was well known to those of ordinary skill in the art at the time of the alleged
`
`invention. See Credelle Decl. at ¶ 40-44; Sony-1010 at 34; Ham at ¶¶ 3, 35 & Fig. 5.
`
`Indeed, in its preliminary response to a pending petition for inter partes review of the
`
`’843 Patent filed by a third party, the Patent Owner admitted that “[a] conventional
`
`LCD panel includes a source driver connected to data lines arranged in a first
`
`direction, a gate driver connected to scan lines arranged in a second direction, and a
`
`matrix of pixels arranged at the intersection of each scan line and data line.”
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`IPR2015-00021, Paper 9 at 3 (P.T.A.B. Jan. 20, 2015). Suzuki discloses a
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`conventional LCD panel. See Suzuki at ¶¶ 38, 47 & Fig. 1 (element 20).
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`Nitta discloses the details of a common TFT LCD panel. Nitta at ¶ 32 & Fig.
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`3. A person of ordinary skill in the art of LCD driving circuitry would have combined
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`the driving circuit taught by Suzuki and the conventional LCD panel described by
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`Nitta, because both Suzuki and Nitta are directed to the same recognized problem in
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`the field of LCD devices, blurring in the display of motion pictures caused by the slow
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`response time of liquid crystal cells. See III.B.1, supra; Suzuki at ¶ 4; III.B.2, supra;
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`Nitta at ¶¶ 2-3; Credelle Decl. at ¶¶ 53-54. Further, a person of ordinary skill in the
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`art would also combine the teachings of Nitta and Suzuki because they both address
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`the same problem in a similar way: they each apply multiple data signals to each pixel
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`of an LCD device during every frame period to accelerate the liquid crystal response
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`speed. See III.B.1, supra; Suzuki at ¶¶ 11, 39, 42, 44, 46; III.B.2, supra; Nitta at
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`Abstract, ¶¶ 27-28, 32, 37, 47, 49, 50-51. Thus, a person of ordinary skill would have
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`combined their teachings. See KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 420 (2007)
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`(“Under the correct analysis, any need or problem known in the field of endeavor at
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`the time of the invention and addressed by the patent can provide a reason for
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`combining the elements in the manner claimed.”); see also Thomson Licensing SAS v. Int’l
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`Trade Comm’n, 527 Fed. Appx. 884, 889 (Fed. Cir. 2013) (holding a person of ordinary
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`skill would have been motivated to combine references that both “relate to LCD
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`panel manufacturing and the formation of spacers” and “share the common goal of
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`providing spacing elements that do not disturb the orientation or alignment of liquid
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`crystal molecules”); Belden Techs. Inc. v. Superior Essex Commc’ns, 802 F. Supp. 2d 555,
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`572 (D. Del. 2011) (“‘It is prima facie obvious to combine two compositions each of
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`which is taught by the prior art to be useful for the same purpose, in order to form a
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`third composition which is used for the very same purpose.’”) (quoting In re Kerkhoven,
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`626 F.2d 846, 850 (C.C.P.A. 1980)).
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`Each element of the claimed LCD panel is addressed below.
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`a. a plurality of scan lines;
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`Suzuki discloses a “gate driver” (18), which is an element routinely used for
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`sending scan signals on scan lines (also known as gate lines) of an LCD panel (20), but
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`does not expressly describe gate or scan lines. Suzuki at ¶ 38 & Fig. 1; Credelle Decl.
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`at ¶¶ 45-46; Sony-1009 at 18; Sony-1010 at 34; Ham at ¶¶ 35-36 & Fig. 5. However, it
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`was commonly understood by those of ordinary skill in the art at the time of the
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`alleged invention of the ’843 Patent that LCD panels typically comprised a plurality of
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`scan lines. Credelle Decl. at ¶¶ 40-41; Sony-1010 at 34; Ham at ¶¶ 34-36 & Fig. 5.
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`Moreover, Nitta explicitly teaches an LCD “that has a liquid crystal panel that
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`has . . . multiple scan lines.” Nitta at ¶¶ 9, 32 & Fig. 3. Therefore, to the extent that
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`Suzuki does not explicitly describe an LCD panel having a plurality of scan lines, a
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`person of ordinary skill in the art would have combined the driving circuit of Suzuki
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`and the conventional LCD panel of Nitta, including a a plurality of scan lines, as
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`discussed above. Credelle Decl. at ¶¶ 53-54. Accordingly, the combination of Suzuki
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`and Nitta discloses an LCD panel having a plurality of scan lines.
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`b. a plurality of data lines;
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`Suzuki discloses a liquid crystal display device that includes a “source driver”
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`(16), which is an element commonly used to send data signals on the data lines of an
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`LCD panel (20). Suzuki at ¶ 38 & Figs. 1; Credelle Decl. at ¶¶ 38-39; Sony-1010 at 34;
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`Ham at ¶ 35. Suzuki does not expressly describe the details of the panel; however, it
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`was commonly understood by those of ordinary skill in the art at the time of the
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`alleged invention of the ’843 Patent that LCD panels typically comprised a plurality of
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`data lines. See Credelle Decl. at ¶¶ 40-41; Sony-1010 at 34; Ham at ¶¶ 34-36 & Fig. 5.
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`Nitta explicitly teaches an LCD “that has a liquid crystal panel that has multiple
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`signal [i.e., data] lines.” Nitta at ¶¶ 9, 32 & Fig. 3; Credelle Decl. at ¶¶ 51-52. The
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`’843 Patent states that data impulses or voltages are applied to the pixels of the LCD
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`panel via the corresponding data line. ’843 Patent at 2:29-31, 3:47-51. Nitta likewise
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`teaches that “display voltage that corresponds to the liquid crystal display data” is
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`applied via signa