Sony Corporation, Samsung Electronics Co.,
`Ltd., and Samsung Display Co., Ltd., .
`v.
`Surpass Tech Innovation LLC, Patent Owner
`IPR2015-00863
`U.S. Patent 7,202,843
`Petitioners’ Demonstratives
`Walter Hanley, Lead Counsel
`John Flock, Backup Counsel
`Jay Alexander, Backup Counsel
`
`1
`
`
`
`
`Ltd., and Samsung Display Co., Ltd., .
`v.
`Surpass Tech Innovation LLC, Patent Owner
`IPR2015-00863
`U.S. Patent 7,202,843
`Petitioners’ Demonstratives
`Walter Hanley, Lead Counsel
`John Flock, Backup Counsel
`Jay Alexander, Backup Counsel
`
`1
`
`
`
`
`
`Grounds for Institution
`Trial instituted on Claims 4 to 9 of the ’843 Patent:
`
`• Obviousness over Suzuki and Nitta under 35 U.S.C. §
`103(a).
`
`Institution Decision (Paper 11) at 13.
`
`2
`
`
`
`’843 Patent
`
`
`
`
`Ex. 1001 at 1:14-26; Petition (Paper 1) at 2-3.
`
`3
`
`
`
`’843 Patent
`
`
`
`
`Ex. 1001 at Figs. 1, 5
`
`4
`
`
`
`’843 Patent: Claim 4
`
`Ex. 1001 at Claim 4.
`
`5
`
`
`
`Suzuki
`
`
`
`
`
`
`Ex. 1003 at ¶ 4; Petition (Paper 1) at 3.
`
`6
`
`
`
`Suzuki
`
`
`
`
`
`
`Ex. 1003 at Fig. 2, ¶ 53, 54, Fig. 2; Petition (Paper 1) at 16-20; Institution Decision (Paper 11) at 8.
`
`7
`
`
`
`Suzuki
`
`
`
`
`“The source driver 16 generates, according to the driving signals DRV from
`the timing control unit 14, the applied voltages VS to be supplied to pixels P
`(liquid crystal cells) of the liquid crystal panel in synchronization with the timing
`signals TIM. The gate driver 18 generates gate signals GT for selecting
`pixels P of the liquid crystal panel in synchronization with the timing signals
`TIM. The liquid crystal panel 20 has a plurality of pixels P which are
`formed in a matrix.”
`
`Ex. 1003 at ¶ 47, Fig. 1; Petition (Paper 1) at 16-18.
`
`8
`
`
`
`Nitta
`
`
`
`
`
`
`
`Ex. 1005 at ¶ 3; Petition (Paper 1) at 4, 10-11.
`
`
`9
`
`
`
`Nitta
`
`
`
`
`
`
`
`Ex.1005 at ¶ 9; Petition (Paper 1) at 5.
`
`
`10
`
`
`
`Nitta
`
`
`
`
`
`
`“The liquid crystal display device 100 . . . has a TFT liquid
`crystal panel 101, a data (signal) driver 102 that conveys to
`the signal lines of the TFT liquid crystal panel 101 voltages that
`correspond to the display data, scan drivers 103-1 and 103-2
`that convey to the gate lines of the TFT liquid crystal panel101
`voltages that correspond to the scan signals . . . .”
`
`
`Ex. 1005 at ¶ 32, Fig. 3; Institution Decision (Paper 11) at 9; Petition (Paper 1) at 14, 20-21.
`
`
`11
`
`
`
`Suzuki and Nitta
`Dr. Credelle
`
`“[B]oth Suzuki and Nitta seek to address the issue of
`blur in the display of moving pictures on LCD devices by
`applying a plurality of data voltages to each pixel of an
`LCD device within a single frame period.”
`
`“[B]ecause both Suzuki and Nitta are directed to the
`issue of blurring in the display of moving pictures on LCD
`devices, and approach the issue in a similar manner, it
`is my opinion that a person of ordinary skill in the art at
`the time of the purported invention would have
`combined their teachings.”
`
`Ex. 1014 at ¶¶ 32-34, 54; Petition (Paper 1) at 10-11; Petitioners’ Reply (Paper 27) at 4-5.
`
`12
`
`
`
`Suzuki and Nitta
` Dr. Credelle
`
`“[A] person of ordinary skill in the art would have recognized
`that the driving circuit of Suzuki could be used to drive
`the conventional AMLCD panel of Nitta.”
`
`“[A] person of ordinary skill in the art would have recognized
`that the data voltages carried by the data lines of Nitta are
`applied to the liquid crystal elements of the pixels of the LCD
`panel to effect a change in the brightness level, and the data
`voltages generated by the driving circuit of Suzuki would
`likewise be applied to the liquid crystal elements of the
`LCD panel for the same purpose.”
`
`Ex. 1014 at ¶ 54; Petition (Paper 1) at 10-11, 12-13, Petitioners’ Reply, Paper No. 27 at 5.
`
`13
`
`
`
`Suzuki and Nitta
` Dr. Credelle
`
`“Suzuki teaches a driving circuit that generates and applies
`multiple data voltages to the pixels of an LCD panel within a
`single frame period, and teaches that the driving circuit
`includes a gate driver. . . .”
`
`“[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 application of scan voltages as
`described by Nitta with the driving circuit taught by
`Suzuki.”
`
`Ex. 1014 at ¶ 55; Petitioners’ Reply (Paper 27) at 6.
`
`14
`
`
`
`Suzuki and Nitta
`Mr. Bohannon
`
`
`Ex. 1019 at 22:24-23:6; Petitioners’ Reply (Paper 27) at 7.
`
`15
`
`
`
`Suzuki: Source and Gate Drivers
`Suzuki
`
`
`
`Dr. Credelle
`“An active matrix LCD panel comprises an array of pixels where
`each pixel includes a switch such as a TFT; the TFT has a “gate”
`which is used to open and close the switch, as well as a “source”
`and “drain” to allow current to flow to the liquid crystal capacitor, and
`optionally a storage capacitor.”
`
`
`
`Ex. 1003 at ¶ 47; Ex. 1020 at ¶ 10; Petitioners’ Reply (Paper 27) at 8-9.
`
`16
`
`
`
`“Source” and “Gate”
`Mr. Bohannon
`
`
`
`Ex. 1019 at 141:5-10; Petitioner’s Reply (Paper 27) at 9.
`
`17
`
`
`
`Claim 5
`
`Patent Owner
`
`“However, Section IV.A.1.iv of the Petition also provides no
`explanation to substantiate the argument that operational unit 32
`determines voltage values OSD and ODD “based on the
`difference (DIF) between the current frame data and delayed
`frame data.”
`
`Ex. 1001 at Claim 5; Patent Owner’s Response (Paper 21) at 36.
`
`18
`
`
`
`Claim 5
`
`Suzuki
`
`
`
`“The data comparison unit 30 compares image data supplied
`anew and image data stored last time in a data memory unit
`12a of the frame memory 12 frame by frame, and outputs the
`difference in data as a difference signal DIF pixel by pixel. After
`the comparison by the data comparison unit 30, the data memory
`unit 12a is overwritten with the image data supplied anew.”
`
`Ex. 1003 at ¶ 40, Fig. 1; Petition (Paper 1) at 17-18, 21-23; Petitioners’ Reply (Paper 27) at 14.
`
`19
`
`
`
`Claim 5
`Suzuki
`
`“The first operational unit 32a determines, simultaneously
`with the start of the sub field SF1, an overshoot value
`pixel by pixel based on the difference signal DIF from
`the data comparison unit 30, and outputs the determined
`value as display data OSD.”
`
`Ex. 1003 at Fig. 1, ¶ 42; Petition (Paper 1) at 17-18, 21-23; Petitioner’s Reply (Paper 27) at 14.
`
`20
`
`
`
`Claim 5
`Suzuki
`
`“second operational unit 32(b) determines overdrive value pixel by
`pixel based on DIF”
`
`“[t]he third operational unit 32(c) [a part of operational unit 32] restores .
`. . the overdrive values for use in the subfield SF2 from [i.e., current
`frame data] . . . and the difference data stored in the first memory unit
`12b and outputs the resultants as display data ODD . . . .”
`
`Ex. 1003 at Fig. 1, ¶¶ 43-44; Petition (Paper 1) at 17-18, 21-23 Petitioner’s Reply (Paper 27) at 14-15.
`
`21
`
`
`
`Claim 5
`
`Mr. Bohannon
`“In paragraph 42, Suzuki continues to describe that the
`first operational unit 32a determines, simultaneously
`with the start of the subfield SF1, an overshoot value...
`based upon the difference signal DIF from the data
`comparison unit 30 and outputs the determined value
`as display data OSD.”
`
`“Clearly this [paragraph 43] describes how the DIF signal
`is a frame by frame comparison of image data that is used
`to calculate an ODD overdriving signal.”
`
`Ex. 2022 at ¶ 45; Petitioners’ Reply (Paper 27) at 13-14.
`
`22
`
`
`
`Claim 7
`
`Patent Owner
`“Suzuki does not disclose determining a difference between
`ODD and OSD . . . . Calculating each of the ODD and OSD
`separately based on the DIF value, as Credelle testifies, does
`not disclose the terms of claim 7 as recited.”
`
`Ex. 1001 at Claims 6, 7; Patent Owner’s Response (Paper 21) at 39-40.
`
`23
`
`
`
`Claim 7
`Suzuki
`
`“Initially . . . In the first sub field SF1 of the frame period FL1, the
`source driver 16 shown in FIG. 1 outputs to the liquid crystal panel
`20 an applied voltage VS higher than the target value according to
`the exceeded display data OSD determined by the first operational
`unit 32a (FIG. 2(a)).”
`
`“Next, in the subfield SF2 (last subfield) of the
`frame period FL1, the source driver 16 outputs an applied
`voltage (exceeded applied voltage) VS slightly lower than the
`target applied voltage according to the target display data ODD
`determined by the third operational unit 32c.”
`
`Ex. 1003 at ¶¶ 53-54; Petition (Paper 1) at 25; Petitioners’ Reply (Paper 27) at 16; See also, Ex. 1003 at ¶¶ 42-44.
`
`24
`
`
`
`Claim 7
`Suzuki
`
`“In other words, the operational unit 32 generates the exceeded
`display data OSD and target display data ODD so that the
`transmittance in a single frame period averages the target value.”
`
`Ex. 1003 at ¶ 58, Fig. 2; Petition (Paper 1) at 25; Petitioners’ Reply (Paper 27) at 16.
`
`25
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`In accordance with § 42.6(e)(1), the undersigned hereby certifies that the
`
`foregoing PETITIONERS’ DEMONSTRATIVES was served electronically via
`
`email on May 10, 2016, in its entirety on the following:
`
`Patent Owners:
`
`Wayne M. Helge
`Donald L. Jackson
`Michael R. Casey
`wheldge@dbjg.com
`djackson@dbjg.com
`mcasey@dbjg.com
`
`Davidson Berquist Jackson & Gowdey, L.L.P.
`8300 Greenboro Drive, Suite 500
`McLean, VA 221102
`
`
`
`
`
`Dated: May 10, 2016
`
`/Walter E. Hanley Jr./
`Walter E. Hanley, Jr.
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`
`
`\
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