UNITED STATES PATENT AND TRADEMARK OFFICE
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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`SONY CORPORATION, SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG DISPLAY CO., LTD.
`Petitioners,
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`v.
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`SURPASS TECH INNOVATION LLC
`Patent Owner.
`
`_______________
`
`Case IPR2015-00863
`Patent 7,202,843 B2
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`_______________
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`
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`DECLARATION OF WILLIAM K. BOHANNON
`IN RESPONSE TO PETITION OF SONY CORPORATION ET AL.
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`I, William K. Bohannon, hereby declare as follows:
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`I have been retained by Patent Owner Surpass Tech Innovation LLC to
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`provide my opinions in support of its Response to the Petition for Inter Partes
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`Review of Patent No. 7,202,843 (the ‘843 patent). I am being compensated for my
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`time at the rate of $250 per hour. I have no interest in the outcome of this
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`proceeding.
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`I. BACKGROUND AND QUALIFICATIONS

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`1.
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`I am currently employed as an independent electronics and display
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`technologies expert and consultant. My background and qualifications are set forth
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`in my curriculum vitae, attached as Appendix A.
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`2.
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`As set forth in my curriculum vitae, I have an undergraduate degree in
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`Mathematics, graduate work in mathematics, physics, and computer science, and
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`over thirty years of professional experience in the areas of displays and electronics.
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`3.
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`During this time, I have worked as a consultant, as an expert, as a
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`named inventor on seven patents, and as a company founder and executive.
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`Specific display technologies that I have worked with include all aspects of LCD
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`projector design, LCD control electronics including various LCD drive electronics
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`circuits, and testing equipment for LCD drive electronics and display performance.
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`I have invented and designed LCD projection systems and their associated control
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`electronics and in addition I have worked with various LC device and component
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`manufacturers to develop custom LCD components.
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`4. My experience includes decades of electronics and display product
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`development. It also includes consulting and providing expert experience in many
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`aspects of the display electronics field. I have experience as a design engineer,
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`systems architect, principal engineer, project manager, and company executive, as
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`well as experience in reverse engineering.
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`5.
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`I have many years of experience in designing, developing,
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`manufacturing and testing electronic display systems. As an independent
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`consultant and analyst, I also acquired, analyzed, tested and then published the test
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`results for over one hundred different display systems produced by major
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`electronics manufacturers. The company I helped to found, Planet ATE,
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`developed many unique electronic test technologies that were used by major,
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`worldwide electronics companies to test various electronics circuits including LCD
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`drivers.
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`6. My additional experience is listed in my curriculum vitae, attached as
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`an Appendix to this declaration.
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`II. MATERIALS CONSIDERED
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`7.
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`In forming my opinions, in addition to my knowledge and experience,
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`I have considered the following documents and things that I have obtained, or that
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`have been provided to me, as well as any other references cited herein that may not
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`be listed below:
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` U.S. Patent No. 7,202,843 to Shen et al., (Ex. 1001) along with
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`aspects of its prosecution history before the U.S. Patent & Trademark
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`Office (Ex. 1002)
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` U.S. Patent Application Publication No. 2003/0156092 (“Suzuki”)
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`(Ex. 1003)
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` Japanese Laid Open Patent Application No. 2002-132224 (“Nitta”)
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`(Ex. 1005)
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` The Petition for Inter Partes Review filed by the Petitioners against
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`the ‘843 patent (IPR2015-00863), focusing on the instituted ground
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`based on Suzuki and Nitta
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` Declaration of Thomas Credelle (Ex. 1014)
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` Curriculum Vitae of Thomas Credelle (Ex. 1015)
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` Transcript for the Deposition of Thomas Credelle dated October 28,
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`2015 (Ex. 2004)
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` Transcript for the Deposition of Richard Zech, Ph.D. dated November
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`13, 2015, in IPR2015-00885 (Ex. 2007)
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` U.S. Patent Application Publication No. 2008/0106540 (“Chien”) (Ex.
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`2018)
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` U.S. Patent No. 5,642,133 (“Scheffer”) (Ex. 2019)
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` U.S. Patent No. 5,280,280 (“Hotto”) (Ex. 2020)
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` U.S. Patent No. 6,606,247 (“Credelle”) (Ex. 2021)
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`III. THE PERSON OF ORDINARY SKILL IN THE ART AND
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`LEGAL STANDARD IN INTER PARTES REVIEW
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`8.
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`The ‘843 patent relates to methods and circuitry for driving an LCD
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`panel. I understand that the factors considered in determining the level of ordinary
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`skill in the art include education and experience of persons working in the art, and
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`the types of problems encountered in the art. Based on these factors, in my opinion,
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`a person of ordinary skill in the relevant art of the ‘843 patent has at least a
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`bachelor’s degree in electrical engineering, mathematics, or computer science with
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`two or more years of experience in designing electronics and displays. For
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`example, a person of ordinary skill in the art would have education and experience
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`sufficient to understand both the disclosures of Suzuki, Nitta, and the background
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`of the ‘843 patent’s specification. This includes the ability to understand the
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`overdriving concept as it is discussed in the ‘843 patent. I would expect this
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`background to include experience in LCD control electronics. A person having
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`this background would understand factors associated with driving electronic
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`5
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`impulses, and would also understand the concepts of pixel voltage versus light
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`transmission and pixel response time.
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`9. My opinions contained in this declaration are given from the
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`perspective of a person of ordinary skill in the art at the time of the November 17,
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`2003 filing of the Taiwanese application No. 92132122 A upon which the ‘843
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`patent is based, unless specifically stated, even if my opinion is expressed in the
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`present tense. As of November 17, 2003, I satisfied the standard of a person of
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`ordinary skill in the art described above in ¶8.
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`10.
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`In an inter partes review (IPR) proceeding before the Patent Trial and
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`Appeal Board, I understand that a petitioner has the burden to prove patent
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`invalidity by a “preponderance of the evidence” standard. I have evaluated the
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`Petition in this case and reach my opinions below according to that burden of
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`proof. I also understand that from the Board’s perspective, attorney argument does
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`not constitute evidence for satisfying this burden.
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`IV. THE ‘843 PATENT
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`11.
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`I have reviewed Patent No. 7,202,843 (the ‘843 patent) entitled
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`“Driving Circuit of a Liquid Crystal Display Panel and Related Driving Method.”
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`The ‘843 patent describes both the background technology of blurring in a liquid
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`crystal display (LCD) panel due to slow response time of the liquid crystal (LC)
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`molecules, and a driving method developed in response to the blurring problem.
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`A. The Background of the Technology
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`12. As the ‘843 patent explains, an LCD panel includes LC molecules
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`arranged between the electrodes of the pixels. In order to display an intended
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`image on the LCD panel, a potential difference is applied across the electrodes.
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`The potential difference causes the LC molecules to twist and rearrange to allow a
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`brightness level of light, usually generated via a backlight, to pass through the LC
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`molecules. Once the potential difference is applied, the LC molecule rearranging is
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`not immediate. Time is necessary for the LC molecules in the pixel to complete
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`their rearranging and for the pixel to generate the intended brightness level of light.
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`Further, where the LC molecule rearrangement cannot be completed within a target
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`frame period, the ‘843 patent explains that “blurring” may occur. [‘843 patent, col.
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`1, lines 1-2]. This concept is explained in the Background of the ‘843 patent, and I
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`agree with the way in which that concept is explained there.
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`13. The ‘843 patent also describes the concept of overdriving.
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`Specifically, according to the ‘843 patent, a way to reduce the risk of blurring is
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`overdriving, “which means applying a higher or a lower data impulse to the pixel
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`electrode to accelerate the speed of the liquid crystal molecules,” and may allow
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`the pixel to reach a predetermined gray level in a predetermined frame period.
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`[‘843 patent, col. 2, lines 3-7]. Figure 2 of the ‘843 patent is described as “a timing
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`diagram of different transmission rates of a pixel, varying in accordance with the
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`frames.” [‘843 patent, col. 1, lines 53-55]. “The curve C1 shows the transmission
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`rate of a pixel not overdriven corresponding to the frames, and the curve C2 shows
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`the transmission rate of the pixel overdriven corresponding to the frames.” [‘843
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`patent, column 1, lines 57-60]. However, even curve C2 does not reach the target
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`transmission rate of T2 until frame N+1. Therefore, the ‘843 patent seeks a further
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`improvement on overdriving. [‘843 patent, col. 2, lines 7-12]. The ‘843 patent
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`states that a “primary object of the claimed invention” is “to provide a driving
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`circuit of an LCD panel and its relating driving method to solve the [response
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`speed] problem mentioned above.” [‘843 patent, col. 2, lines 16-18]. It is clear to
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`me that the phrase “its relating driving method” refers back to the “driving circuit
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`of an LCD panel” based on how this sentence is constructed. I find this sentence
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`helpful for understanding the claimed invention in the ‘843 patent.
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`B. The ‘843 Patent’s Disclosure
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`14. The main focus of the ‘843 patent is controlling the transmission rate
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`of the LC molecules in a pixel by applying at least two data impulses based on
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`overdriven data. The ‘843 patent includes three block diagrams of driving circuits
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`or components thereof, and each performs overdriving on the pixel data. [‘843
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`patent, Figures 3, 7 and 8]. Additionally, the ‘843 patent includes two timing
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`diagrams showing two overdriven pixel data signals applied per frame. [‘843
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`patent, Figures 5 and 10].
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`15.
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`In the block diagrams of the driving circuit 10, a blur clear converter
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`14 is included and “continuously receives the controls signals C and the frame data
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`included in the frame signals G and generates processed frame signals G including
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`a plurality of overdriven data according to the frame data.” [‘843 patent, col. 3,
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`lines 24-28]. This embodiment is shown in Fig. 3 of the ‘843 patent.
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`16. Figures 7 and 8 show first and second embodiments of the blur clear
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`converter 14 shown and described with respect to Figure 3. Figure 7’s
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`embodiment of the blur clear converter includes a processing circuit 42.
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`According to the ‘843 patent, the “processing circuit 42 generates a plurality of
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`overdriven pixel data GN according to the current pixel data Gm and the delayed
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`pixel data Gm-1.” [‘843 patent, col. 4, lines 53-55]. The overdriven pixel data are
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`identified as “overdriven pixel data GN, GN(2).” [‘843 patent, col. 4, lines 62-63].
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`Similar to the embodiment of Figure 7, the blur clear converter of Figure 8 also has
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`a processing circuit 74. This processing circuit 74 also “generates two pieces of
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`overdriven pixel data GN1, GN-1(2) for each pixel 36 in every frame period
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`according to the pixel data Gm-1, Gm-2.” [‘843 patent, col. 5, lines 17-19].
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`Therefore, in these disclosed embodiments of the driving circuit 10, the ‘843 patent
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`discloses circuitry for generating two overdriven pixel data in a frame.
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`17. Further, in the timing diagrams of Figures 5 and 10, it is clear that the
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`‘843 patent is describing the timing of applied overdriven pixel data. When
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`describing the output of blur clear converter according to embodiments, the ‘843
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`patent uses capitalized “N”, as in “GN,” to refer to overdriven pixel data, and uses
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`lower-case “m,” as in “Gm” or “Gm-1,” to refer to original pixel data. Examples
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`of this can be found in col. 4, lines 49-63; col. 5, lines 7-22; and col. 5, lines 28-42.
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`In both Figures 5 and 10, the ‘843 patent uses labels indicating overdriven pixel
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`data. This is consistent with Figure 5 showing the overdriven pixel data impulses
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`GN, GN(2)… from driving circuit 10, which outputs overdriven data via blur clear
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`converter 14. This is also consistent with Figure 10 showing the overdriven pixel
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`data impulses GN, GN(2)… from blur clear converter 60 of Figure 8. This is
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`expressly contrasted with Figure 9’s use of lower-case “m” indicating non-
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`overdriven (or original) pixel data. [‘843 patent, col. 5, lines 28-31].
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`18. Based on my review of the ‘843 patent’s detailed description of the
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`invention and its embodiments, the ‘843 patent uniformly correlates the idea of
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`overdriving and controlling the transmission rate of the LC molecules of a pixel.
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`19. As I noted above, the ‘843 patent describes the concept of
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`overdriving. Specifically, according to the background of the ‘843patent, a way to
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`reduce the risk of blurring is overdriving, “which means applying a higher or a
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`lower data impulse to the pixel electrode to accelerate the speed of the liquid
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`crystal molecules,” and may allow the pixel to reach a predetermined gray level in
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`a predetermined frame period. [‘843 patent, col. 2, lines 3-7]. Here, the patent’s
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`explanation of what is meant by overdriving specifically ties the application of
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`higher or lower data pulses to the speed of the LC molecules.
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`20. Another example of this correlation between overdriving voltages and
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`transmission rate comes from column 3, lines 60-62, which describes the theory
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`behind overdriving: “Different data voltages cause different twisting angles and
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`show different transmission rates.”
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`21.
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`In describing Figure 5, the ‘843 patent states that the overdriven pixel
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`data impulses GN, GN(2) from driving circuit 10, which outputs overdriven data
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`via blur clear converter 14, are applied to the LCD panel “in order to control the
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`transmission rate of the liquid crystal device 39.” [‘843 patent, col. 4, lines 13-14].
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`22. Figure 6 is described consistently with this correlation as well.
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`Driving circuit 10, which outputs overdriven data via blur clear converter 14,
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`applies data impulses to the liquid crystal device 39 “in order to control the
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`transmission rate and gray level of the pixel electrode 39.” [‘843 patent, col. 4,
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`lines 24-28].
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`23. Claim 1 of the ‘843 patent also specifically correlates the overdriven
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`pixel data and controlling a transmission rate of the liquid crystal device. [‘843
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`patent, col. 6, lines 15-21].
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`24. The Petition does not specifically address whether claim 4 requires
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`overdriving.
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`25. However, based on my review of the ‘843 patent discussed in
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`paragraphs 14-23 above, and based on the ‘843 patent’s discussion of controlling
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`transmission rates of liquid crystal devices through different data voltages, a
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`person of ordinary skill in the art would understand that the disclosed embodiments
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`in the ‘843 patent combine both overdriving and applying two overdriven pulses in
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`a frame.
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`A. CLAIM CONSTRUCTION
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`26.
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`I understand that in an Inter Partes review of an unexpired patent,
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`claim terms are given their broadest reasonable interpretation that is consistent
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`with the specification, as would be understood by a person of ordinary skill in the
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`art. The following claim constructions reflect my view of the broadest reasonable
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`interpretation of the ‘843 patent terms that are consistent with the specification, as
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`would be understood by a person of ordinary skill in the art.
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`27. Claim 4 recites that a plurality of data impulses are generated and
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`applied “to control a transmission rate of the liquid crystal device of the panel.” I
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`understand that Petitioners did not put forth any evidence or testimony on the
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`meaning of this term, and instead stated that this term and the other terms of claim
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`4 “should be given their broadest reasonable construction in view of the
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`specification” of the ‘843 Patent, “and should be construed in accordance with
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`their ordinary meaning.” [Petition, page 8]. However, Petitioners provided no
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`discussion of what is “reasonable” in light of the specification.
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`28. As an initial matter, I believe that “transmission rate” is not a common
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`term when discussing LCD technology. I agree with Richard Zech, Ph.D., who
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`testified in IPR2015-00885 on November 13, 2015 as stating, “Transmission rate is
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`not only not a term of the art, it’s not a term of anything.” [Transcript for the
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`Deposition of Richard Zech, Ph.D. dated November 13, 2015, 47:16-17.] The use
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`of this term in the claims required me to read the ‘843 patent carefully so I could
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`understand what is meant by claim 4’s term, “to control a transmission rate of the
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`liquid crystal device of the panel.”
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`29. As I have explained above, the ‘843 patent correlates controlling a
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`transmission rate of a liquid crystal device of a panel with overdriving, or applying
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`higher or lower voltages. A key example of this theory is column 3, lines 60-62:
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`“Different data voltages cause different twisting angles and show different
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`transmission rates.” Specifically, the ‘843 patent states that overdriven means
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`“applying a higher or a lower data impulse to the pixel electrode to accelerate the
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`speed of the liquid crystal molecules,” and this may allow the pixel to reach the
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`predetermined gray level in a predetermined frame period. [‘843 patent, col. 2,
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`lines 3-7]. In fact, the Petitioners do not cite to and I am not aware of embodiment
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`in the ‘843 patent where a transmission rate is described as being controlled
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`without overdriving.
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`30. Additionally, the ‘843 patent specifically does not state that the
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`transmission rate could be controlled by applying two or more non-overdriven data
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`impulses. Such a construction is not supported by and is inconsistent with the ‘843
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`specification. Therefore, I understand that it cannot constitute the broadest
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`reasonable interpretation consistent with the specification.
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`31. Consistent with the ‘843 patent specification, which discloses that
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`“[d]ifferent data voltages cause different twisting angles and show different
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`transmission rates,” a person of ordinary skill in the art would have understood that
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`the broadest reasonable interpretation of controlling the transmission rate refers to
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`applying a higher or lower voltage to a liquid crystal device, or overdriving.
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`VI. CONSIDERATION OF THE PETITION, THE PRIOR ART, AND
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`THE DECLARATION OF THOMAS CREDELLE

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`32.
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`I have reviewed the Petition and Declaration of Thomas Credelle, and
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`understand that the Petitioners argue that claims 4-9 are obvious over Suzuki in
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`view of Nitta.
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`33.
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`I further understand from the deposition transcript of Thomas Credelle
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`that Mr. Credelle assumed Suzuki to disclose an active matrix LCD (“AMLCD”)
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`based on certain factors. I agree with Mr. Credelle that Suzuki does not disclose
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`any details about the substrates on which the LCD panel is formed, and does not
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`disclose the substrates on which Suzuki’s drivers are attached. I also note that
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`Suzuki’s ¶ 47 indicates that the LCD panel includes pixels P arranged in a matrix,
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`but does not further describe the structure or arrangement of the panel or the pixels
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`P.
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`34.
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`I do not agree with Mr. Credelle that Suzuki discloses AMLCD. Mr.
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`Credelle bases his conclusion of AMLCD on four factors, as I understand it. First,
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`Mr. Credelle explains that he was “not sure how you would implement an
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`overdrive in a passive matrix addressing scheme.” [Credelle Transcript at 44:8-9.]
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`In my experience, my understanding of the overdriving concept is that it is and has
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`been applicable to passive matrix LCD technology. Evidence of this understanding
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`is confirmed in U.S. Patent No. 5,642,133 (“Scheffer”), which discloses a “pulse-
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`height modulated column signal” in the context of a passive matrix LCD and
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`therefore discloses overdriving in a passive matrix LCD panel. Ex. 2019 at 8:9-11;
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`FIG. 5b; 21:32-54. Scheffer was filed in 1995, prior to Suzuki’s filing date. Ex.
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`2019 at 1. Additionally, U.S. Patent No. 5,280,280 (“Hotto”) filed in 1991
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`describes “pixel power modulation” to provide improved display performance for
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`both passive matrix and active matrix LCDs. Ex. 2020 at 2:40-47. Hotto’s
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`disclosure suggests that the “pixel power modulation” term pre-dates the more
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`modern “overdriving” term, but these different terms disclose the same concept.
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`Scheffer and Hotto both disclose overdriving in the context of passive matrix
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`LCDs, and would be instructive to a person of ordinary skill in the art that the
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`overdriving technique is and was applicable to passive matrix LCDs before and at
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`the time that Suzuki was filed.
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`35. Second, Mr. Credelle believes that passive matrix LCD is not used to
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`display “moving images.” [Credelle Transcript at 70:18-20.] However, he earlier
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`testified in his deposition that computer monitors display moving images and that
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`passive matrix is suitable for computer monitors. [Credelle Transcript at 27:16-
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`28:13.] I agree with his testimony that passive matrix LCD technology was
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`capable of displaying moving images at the time that Suzuki was filed.
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`36. Third, Mr. Credelle believes that Suzuki’s disclosure of “hold drive”
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`means that it is only applicable to AMLCD. I disagree. Suzuki defines a “hold
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`drive system” as “a technology in which signals corresponding to the same image
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`data are output to the liquid crystal cells over a period of one frame.” [Suzuki,
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`¶[0005].] Based on this description of “hold drive,” this description also applies to
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`passive matrix LCD technology.
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`37.
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` Specifically, Suzuki discloses in paragraph 5 that a “hold drive”
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`system refers to a technology in which signals corresponding to the same image
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`data are output to the liquid crystal cells over a period of one frame. Also in
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`paragraph 5, Suzuki states the desire to “bring the moving image display
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`performance close to that of CRTs... .” [Suzuki, ¶[0005].]
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`38. Therefore, Suzuki relates the “hold drive” concept to LCDs and
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`CRTs. Suzuki’s description of hold drive for LCDs is in distinction to a CRT’s
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`analog drive method where the CRT’s deflection coils and beam intensity
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`constantly change in response to a changing real time signal. The LCD hold drive
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`system that Suzuki describes is based upon creating, frame by frame, a digital pixel
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`image of the scene to be displayed and then holding it in a frame memory or buffer
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`before writing the static frame memory contents to the LCD. This type of hold
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`drive system is used for any type of digital pixel display system whether any kind
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`of LCD (including passive matrix LCD panel) or even a mechanical pixelated
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`display system such as TI’s digital micro-mirror display (DMD) system.
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`39. Further, I understand that another expert presented by other petitioners
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`in IPR2015-00885 against Surpass was unable to explain the meaning of “hold
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`drive” as it relates to LCD technology. [Zech Transcript at 89:11-90:4] Therefore, I
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`believe this term is not commonly known to a person of ordinary skill in the art,
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`and it is necessary to rely on Suzuki’s definition of the term to understand its
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`meaning.
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`40. Fourth, Mr. Credelle drew assumptions based on Suzuki’s disclosure
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`of a source driver 16 and a gate driver 18. [Credelle Transcript at 70:5-14.] Suzuki
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`does describe a source driver 16 that generates, according to the driving signals
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`DRV, the “applied voltage” VS to be supplied to pixels (liquid crystal cells) of the
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`LCD panel. The gate driver 18 generates gate signals GT for “selecting pixels” of
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`the LCD panel. However, this terminology is not dispositive of the type of the
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`LCD panel. Rather, Suzuki’s description of source and gate signals are in
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`accordance with a wide variety of LCDs formed by a matrix of overlapping row-
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`select and columns data electrodes where the row electrodes are used to “select”
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`the pixels driven by the voltages “applied” by the column electrodes. Therefore, I
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`do not agree that this disclosure indicates with certainty that Suzuki discloses
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`AMLCD.
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`41. Further, I understand that the Petitioners are simply looking to Nitta
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`for the details of an AMLCD. However, they have not evaluated whether Suzuki
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`and Nitta are compatible. That would require determining first what type of LCD
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`panel is disclosed in Suzuki. If this is not possible from Suzuki, then Petitioners
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`would need to evaluate whether Suzuki is compatible with an AMLCD panel. The
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`Petition does not include this analysis, and Credelle does not perform this analysis.
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`42.
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`I believe that Suzuki is compatible with passive matrix LCD
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`technology because Suzuki’s disclosure, diagrams and the waveforms shown in
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`Figs. 2 and 5 are compatible with passive matrix LCDs. Suzuki’s Fig. 5 compares
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`well against Scheffer’s (‘133) Fig. 3B as well as does Hotto’s (‘280) description of
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`pixel power modulation in Col 2 line 40 and Fig. 6. Further, as Mr. Credelle
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`acknowledges in his deposition, passive matrix and active matrix panels include
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`different architecture and require different driving circuitry.
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`43. The only disclosure in Suzuki that the Petitioners can point to support
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`its argument that Suzuki describes an AMLCD is Suzuki’s use of the terms, “gate”
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`and “source” drivers as discussed above. To bolster their argument, the Petitioners
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`then point to Nitta, which does not use the terms gate and source driver. Rather,
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`Nitta instead uses the terms “scan” and “signal” to represent the row and column
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`drivers.
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`44. Since claims 5-9 depend from claim 4, I understand that these claims
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`incorporate all features from claim 4. Since the Petition fails to establish
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`obviousness of claim 4 over a combination of Suzuki and Nitta, the Petition also
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`fails to establish obviousness of claims 5-9 over this same combination.
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`45. Suzuki’s disclosure describes in paragraph 40 that the data
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`comparison unit 30 compares image data supplied anew and image data stored last
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`time in a data memory unit 12a... and outputs the difference in data as a difference
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`signal DIF pixel by pixel. In paragraph 42, Suzuki continues to describe that the
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`first operational unit 32a determines, simultaneously with the start of the subfield
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`SF1, an overshoot value... based upon the difference signal DIF from the data
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`comparison unit 30 and outputs the determined value as display data OSD. Suzuki
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`in paragraph 43 describes how the second operational unit 32b initially determines
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`an overdrive value... based on the difference signal DIF from the data comparison
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`unit 30. .... Here the applied voltages... are slightly higher or lower than the
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`applied voltages VS corresponding to the target transmittances (target applied
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`voltages). That is the display data ODD is target display data for setting the
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`applied voltages VS to a value greater or smaller than the target applied voltages...
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`so that the liquid crystal cells become the target transmittance. Clearly this
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`describes how the DIF signal is a frame by frame comparison of image data that is
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`used to calculate an ODD overdriving signal.
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`46. Shen in the ‘843 determines the difference between two different
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`overdriven data impulses GN+1 and GN+1(2) as shown in Fig. 10 as ΔG. This ΔG
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`value shown in Fig. 10 not the same as that shown in Shen Fig. 9 as the difference
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`(Diff) between the original Gm and the Gm+1 pixel data values. The Diff value
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`between the original Gm and the Gm+1 pixel data values corresponds more closely
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`to what Suzuki refers to as the DIF signal from data comparison unit 30.
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`47.
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`In Column 5, line 41 of the ‘843 description, Shen uses that ΔG
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`difference to “drive the LCD panel 30 properly” by modulating the difference ΔG
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`when the difference Diff exceeds a “specific” value.
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`48. Nowhere in Suzuki’s description is a difference Δ between the OSD
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`and ODD data determined, and nowhere in Suzuki’s description is a difference Δ
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`between the OSD and ODD data determined based on the DIF signal. Suzuki does
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`not disclose these elements of the ‘843 patent claim 7.
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`
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`I declare under penalty of perjury under the laws of the United States that
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`my foregoing testimony is true and correct.
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`
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`Executed this 24th day of November, 2015 in San Diego, California.
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`____________________________________
`
`William K. Bohannon
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`21
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`Exhibit 2022
`Page 21 of 31
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`Appendix A
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`IPR2015-00863
`Exhibit 2022
`Page 22 of 31
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`Page 2.
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`
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`William K. Bohannon
`Resume
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`
`
`WILLIAM K. BOHANNON
`
`
`
`SUMMARY
`
`
`Worked in the commercial-industrial electronics and professional audio-visual industry
`for the last twenty-five years. Prior to work in commercial industry, worked in the
`aerospace industry for another approximately 10 years. Responsibilities included a
`number of highly sophisticated, government classified sensor and imaging projects. Prior
`to government and aerospace work, was involved with analytical, scientific research
`regarding spectroscopy for a number of years.
`
`
`
`Has been involved with electronic systems, detectors, measurements, sensors, projectors,
`displays and imaging apparatus for close to twenty-five years. Has been involved with
`all phases of the development of various kinds of electronic systems, including
`conception, invention, development, marketing and sales. Prepared specifications,
`negotiated with various customers over system or component requirements and
`specifications, and prepared or negotiated over tests and measurements of these systems
`or their separate components to insure that the specifications or requirements have been
`or will be meet. Also, prepared and negotiated development contracts and subcontracts
`for such systems or for their electronic components.
`
`
`
`SPECIFIC AREAS OF EXPERTISE
`
`Automated Test Equipment (ATE) and Electronics for IC test: Drivers, Comparators, Loads,
`DUT Power Supplies, Buffers, Amplifiers, Precision Measurement Unit (PMU) for F/M of I/V,
`ADC, DAC, Clocks, FPGA and other related electronics. (see: Semtech, Intersil, Edge, Planet
`ATE etc.)
`
`LCD, Plasma, CRT and Large Screen Display Equipment: LCD manufacturing, substrates,
`drivers and other related components for rear screen displays including Avionics and cockpit
`displays. Technology expertise includes projector design, optical components, LC optics and LC
`lens technology (see: Sandel, Lensvector, Proxima etc.)
`
`
`
`PROFESSIONAL EXPERIENCE
`
`1994 to Present
`
`
`Independent Consultant – Manx Research
`
`IPR2015-00863
`Exhibit 2022
`Page 23 of 31
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`Page 3.
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`
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`William K. Bohannon
`Resume
`
`Provides litigation support and qualified expert witness services for the electronics and
`display industry. Services include testing, evaluation and reporting of electronics, LCDs,
`Plasmas, electronic projectors and other types of display systems. Has extensive
`
`experience with Asian manufacturers of electronics and displays as well as with foreign
`business and patent issues. Clients include:
`
`U.S. Corporate:
`
`IP Value and 3D Vision (IP investigations), Sandel Avionics (LCD
`Displays), LensVector (LC lens), Texas Instruments, 3M, IBM,
`Kodak, Rockwell, Edge (Semtech) Semiconductor, Epson America, In
`Focus Systems and Prox