UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`LG DISPLAY CO., LTD.
`Petitioner
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`v.
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`SURPASS TECH INNOVATION LLC
`Patent Owner
`_______________
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`Case: IPR2015-00885
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`Patent 7,202,843
`_______________
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`DECLARATION OF RICHARD ZECH, PH.D.
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`LGD_000606
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`LG Display Ex. 1011
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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`LG DISPLAY CO., LTD.
`Petitioner
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`v.
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`SURPASS TECH INNOVATION LLC
`Patent Owner
`_______________
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`Case: IPR2015-00885
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`Patent 7,202,843
`_______________
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`DECLARATION OF RICHARD ZECH, PH.D.
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`LGD_000606
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`LG Display Ex. 1011
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`Declaration of Richard Zech, Ph.D.
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`I.
`INTRODUCTION
`1. My name is Dr. Richard G. Zech, and I have been retained by the law firm of
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`Mayer Brown LLP on behalf of LG Display Co. Ltd. and LG Display America, Inc. as
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`an expert in the relevant art.
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`2.
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`I have been asked to provide my opinions and views on the materials I have
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`reviewed in this case related to Ex. 1001, U.S. Patent No. 7,202,843 (“the ’843
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`Patent”) (“the patent-at-issue”), and the scientific and technical knowledge regarding
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`the same subject matter before and for a period following the date of the first
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`application for the patent-at-issue was filed.
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`3.
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`I am compensated at a rate of $250 per hour for my work, plus reimbursement
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`for expenses. My compensation does not depend on the outcome of this proceeding,
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`nor has it influenced any of my opinions in this matter.
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`4. My opinions and underlying reasoning for this opinion are set forth below.
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`Background And Qualifications
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`A.
`A detailed record of my professional qualifications is set forth in the attached
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`5.
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`Appendix A (my curriculum vitae), including a list of publications, awards, research
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`grants, and professional activities. A list of my previous testimony by deposition and
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`at trial is included in my curriculum vitae (CV).
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`6.
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`I graduated from Lawrence Institute of Technology (now Lawrence University)
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`in 1965 with a B.S. in Electrical Engineering, being a Founder’s Scholar each year of
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`my undergraduate studies. I then graduated from University of Michigan in December
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`1966 with an MSEE degree and in May 1974 with a Ph.D. in Electrical Engineering
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`with Computer Science and Photonics minors. While at the University of Michigan, I
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`studied under leading modern optical science information processing pioneers,
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`including Prof. Dr. E. N. Leith, Dr. A. Kozma, Dr. A. Vander Lugt, and Prof. Dr.
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`Dennis Gabor (1971 Nobel laureate in physics).
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`7.
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`I am currently President and Managing Principal of the ADVENT Group,
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`which provides forensic consumer electronics test and evaluation, market research,
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`product development, R&D, engineering, and technology assessment services in the
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`areas of optical and computer storage, flat panel displays, digital cameras,
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`nanotechnology, microelectromechanical systems (MEMS), and photonics. ADVENT
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`Group’s main areas of expertise include consumer electronic technologies, such as
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`digital cameras and imaging, displays (monitors and TVs), scanners, small computer
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`systems and components, and optical drive and media technologies. I have held VP
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`positions in Engineering, Marketing and Sales, and Strategic Planning. In 1990 I was
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`President and COO of the New Interfile Corporation. I therefore have both a
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`knowledge of and perspective on the industries in which I have expertise, including
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`flat panel displays.
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`8.
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`At the University of Michigan I began a lifetime of research and development
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`Declaration of Richard Zech, Ph.D.
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`in the highly specialized areas of optical data and image storage, processing,
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`computing, and communications, as well as image capture and display. While
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`completing my Masters and Doctorate education at the University of Michigan, I
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`performed research in the areas of holography, optical data processing and storage,
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`light-sensitive materials, lasers, displays, and grating ruling engines. I also worked on
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`research and development of pioneering recording and processing systems for optical
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`storage and image correction and enhancement.
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`9.
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`I have extensive experience with displays of various types. In the 1960s and
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`1970s, I worked with liquid crystal displays for numerous applications. The primary
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`ones being as page composers (input devices) for prototype 3D holographic
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`memories for NASA and large (up to 4x5 foot) monochrome and color displays for
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`data fusion analysis (classified USAF contract; an early part of the 30-minute war
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`scenario project). By today’s standards, this was all very crude. I also worked on head-
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`up displays for USAF fighter aircraft and holographic optical elements (HOE) for
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`FLIR (forward looking infrared) sensors. In the 1980s my interests turned to plasma
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`displays, which were well developed, for example, by IBM. In 1995 at the National
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`Association of Broadcasters (NAB) Show I saw the future thanks to a demonstration
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`at the Toshiba booth: real high-definition TV shown on a large (1920x1080) liquid
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`crystal display (LCD). From that time to the present, LCDs have been an important
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`part of my consulting practice.
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`Declaration of Richard Zech, Ph.D.
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`10.
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`I have nearly 50 years of electrical and computer engineering experience in
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`research and development, product development, systems engineering, and program
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`management, including being principal investigator role. My work experience relates
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`to advanced technologies for capturing, processing, and storing large data sets, such as
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`LandSAT satellite data for NASA and the Department of Defense. I have been
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`involved with pioneering work in the fields of holography, 3D holographic memories,
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`optical data storage on disc, tape, and card, flat panel displays, lasers, materials
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`science, and input/output devices. Since my graduation from the University of
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`Michigan, I have taken numerous courses and seminars to increase my technical
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`knowledge, and I have published nearly 200 papers and reports.
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`11.
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`In the 1980s, as part of my modernization plan while Director of
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`Communications systems (later, VP/Chief Technology Officer) at McGraw-Hill, I
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`introduced personal computers (PCs), local area networks (LANs), document image
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`management systems with an emphasis on displays for electronic information
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`products. Starting in the 1990s, I have been researching ways to improve the
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`performance, reliability, and lower the cost of high-performance of LCD and other
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`types of displays.
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`12.
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`I also have considerable experience with light emitting diodes (LEDs) and
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`CCD and CMOS (complementary metal oxide semiconductor) image sensors through
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`my work in 3D holographic memories (in which the image sensor is the output
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`device, and digital cameras). LEDs are now the preferred light source for backlighting
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`LCDs.
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`Information Considered
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`B.
`In addition to my general knowledge gained as a result of my education and
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`13.
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`experience in this field, I have reviewed and considered, among other things, the ’843
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`Patent, its prosecution history, the prior art of record, and certain other prior art
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`references as discussed in this declaration.
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`14. The full list of information that I have considered in forming my opinions for
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`this report is set forth throughout the report and listed in the attached Appendix B.
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`II. Legal Standards
`15.
`In forming my opinions and considering the patentability of the claims of the
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`’843 Patent, I am relying upon certain legal principles that counsel has explained to
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`me.
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`16.
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`I understand that for an invention claimed in a patent to be found patentable, it
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`must be, among other things, new and not obvious in light of what came before it.
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`Patents and publications which predated the invention are generally referred to as
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`“prior art.”
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`17.
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`I understand that in this proceeding the burden is on the party asserting
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`unpatentability to prove it by a preponderance of the evidence. I understand that “a
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`preponderance of the evidence” is evidence sufficient to show that a fact is more
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`likely than not.
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`18.
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`I understand that in this proceeding, the claims must be given their broadest
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`reasonable interpretation consistent with the specification. The claims after being
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`construed in this manner are then to be compared to information that was disclosed
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`in the prior art.
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`Person of Ordinary Skill in the Art
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`A.
`I have been informed that the claims of a patent are judged from the
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`19.
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`perspective of a hypothetical construct involving “a person of ordinary skill in the
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`art.” The “art” is the field of technology to which the patent is related. I understand
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`that the purpose of using a person of ordinary skill in the art’s viewpoint is objectivity.
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`Thus, I understand that the question of validity is viewed from the perspective of a
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`person of ordinary skill in the art, and not from the perspective of (a) the inventor, (b)
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`a layperson, or (c) a person of extraordinary skill in the art. I have been informed that
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`the claims of the patent-at-issue are interpreted as a person of ordinary skill in the art
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`would have understood them in the relevant time period (i.e., when the patent
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`application was filed or earliest effective filing date).
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`20.
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`It is my opinion that a one of ordinary skill in the art would be an electrical
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`engineer with at least a BS degree (preferably a MS degree) and 3-5 years of circuit
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`design experience.
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`21.
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`I understand that a “person of ordinary skill is also a person of ordinary
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`creativity, not an automaton” and that would be especially true of anyone developing
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`technology for LCD panels.
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`Anticipation
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`B.
`I understand that the following standards govern the determination of whether
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`22.
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`a patent claim is “anticipated” by the prior art. I have applied these standards in my
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`analysis of whether claims of the ’843 Patent were anticipated at the time of the
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`invention.
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`23.
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`I understand that a patent claim is “anticipated” by a single prior art reference
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`if that reference discloses each element of the claim in a single embodiment. A prior
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`art reference may anticipate a claim inherently if an element is not expressly stated, if
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`the prior art necessarily includes the claim limitations.
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`24.
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`I understand that the test for anticipation is performed in two steps. First, the
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`claims must be interpreted to determine their meaning. Second, a prior art reference is
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`analyzed to determine whether every claim element, as interpreted in the first step, is
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`present in the reference. If all the elements of a patent claim are present in the prior
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`art reference, then that claim is anticipated and is invalid.
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`25.
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`I understand that it is acceptable to examine extrinsic evidence outside the
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`prior art reference in determining whether a feature, while not expressly discussed in
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`the reference, is necessarily present within that reference.
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`C. Obviousness
`I understand that a claim can be invalid in view of prior art if the differences
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`26.
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`between the subject matter claimed and the prior art are such that the claimed subject
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`matter as a whole would have been “obvious” at the time the invention was made to a
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`person having ordinary skill in the art.
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`27.
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`I understand that the obviousness standard is defined at 35 U.S.C. § 103(a). I
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`understand that a claim is obvious over a prior art reference if that reference,
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`combined with the knowledge of one skilled in the art or other prior art references
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`discloses each and every element of the recited claim.
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`28.
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`I also understand that the relevant
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`inquiry
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`into obviousness requires
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`consideration of four factors:
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`a.
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`b.
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`c.
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`The scope and content of the prior art;
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`The differences between the prior art and the claims at issue;
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`The knowledge of a person of ordinary skill in the pertinent art; and
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`d.
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`Objective factors indicating obviousness or non-obviousness may be
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`present in any particular case, such factors including commercial success of products
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`covered by the patent claims; a long-felt need for the invention; failed attempts by
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`others to make the invention; copying of the invention by others in the field;
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`unexpected results achieved by the invention; praise of the invention by the infringer
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`or others in the field; the taking of licenses under the patent by others; expressions of
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`surprise by experts and those skilled in the art at the making of the invention; and that
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`the patentee proceeded contrary to the accepted wisdom of the prior art.
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`29.
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`I understand that when combining two or more references, one should
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`consider whether a teaching, suggestion, or motivation to combine the references
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`exists so as to avoid impermissible hindsight. I have been informed that the
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`application of the teaching, suggestion or motivation test should not be rigidly
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`applied, but rather is an expansive and flexible test. For example, I have been
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`informed that the common sense of a person of ordinary skill in the art can serve as
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`motivation for combining references.
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`30.
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`I understand that the content of a patent or other printed publication should be
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`interpreted the way a person of ordinary skill in the art would have interpreted the
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`reference as of the effective filing date of the patent application for the ’843 Patent. I
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`have assumed that the person of ordinary skill is a hypothetical person who is
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`presumed to be aware of all the pertinent information that qualifies as prior art. In
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`addition, the person of ordinary skill in the art makes inferences and creative steps.
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`He or she is not an automaton, but has ordinary creativity.
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`31.
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`I have been informed that the application that issued as the ’843 patent was
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`filed in 2004. However, the application claims priority to a foreign parent application
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`that was filed on November 17, 2003. As a result, I will assume the relevant time
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`period for determining what one of ordinary skill in the art knew is November 17,
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`2003, the effective filing date for purposes of this proceeding.
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`D. Claim Construction
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`32.
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`I have been informed that a claim subject to Inter Partes Review is given its
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`“broadest reasonable construction in light of the specification of the patent in which
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`it appears.” I have been informed that this means that the words of the claim are
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`given their plain meaning from the perspective of one of ordinary skill in the art
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`unless that meaning is inconsistent with the specification. I understand that the “plain
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`meaning” of a term means the ordinary and customary meaning given to the term by
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`those of ordinary skill in the art at the time of the invention and that the ordinary and
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`customary meaning of a term may be evidenced by a variety of sources, including the
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`words of the claims, the specification, drawings, and prior art.
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`33.
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`I understand that in construing claims “[a]ll words in a claim must be
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`considered in judging the patentability of that claim against the prior art.” (MPEP §
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`2143.03, citing In re Wilson, 424 F.2d 1382, 1385 (CCPA 1970)).
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`34.
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`I understand that extrinsic evidence may be consulted for the meaning of a
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`claim term as long as it is not used to contradict claim meaning that is unambiguous in
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`light of the intrinsic evidence. Phillips v. AWH Corp., 415 F.3d 1303, 1324 (Fed. Cir.
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`2005) (citing Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1583-84 (Fed. Cir. 1996)).
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`35.
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`I also understand that in construing claim terms, the general meanings gleaned
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`from reference sources must always be compared against the use of the terms in
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`context, and the intrinsic record must always be consulted to identify which of the
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`different possible dictionary meanings is most consistent with the use of the words by
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`the inventor. See, e.g., Ferguson Beauregard/Logic Controls v. Mega Systems, 350 F.3d 1327,
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`1338 (Fed. Cir. 2003) (citing Brookhill-Wilk 1, LLC v. Intuitive Surgical, Inc., 334 F.3d
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`1294, 1300 (Fed. Cir. 2003)).
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`III. THE ’843 PATENT
`A.
`Specification Of The ’843 Patent
`36. The ’843 Patent generally relates to circuits and methods for driving a liquid
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`crystal display (“LCD”) panel. The LCD panel 30 described in the ’843 Patent
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`includes a number of well-known components common in prior art LCD panels,
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`including a plurality of scan lines 32 (also called gate lines), a plurality of data lines 34,
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`and a plurality of pixels 36. Ex. 1001, at 1:27-31, 3:37-40.
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`37. Each pixel 36 includes a switching device 38 (e.g., a thin-film transistor, also
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`known as a “TFT”) and a liquid crystal device 39 (also called a “pixel electrode”). Id.
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`at 3:40-43. These components are shown in Fig. 4 of the ’843 Patent (annotated and
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`reproduced below), which also shows that the gate of the switching device 38 in each
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`pixel is connected to the corresponding scan line 32, while the source of the switching
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`device in the pixel is connected to the corresponding data line 34. Id. at 3:43-47.
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`38. The LCD panel 30 is driven by applying scan line voltages to the scan lines 32
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`to turn on the switching devices 38 and applying data impulses to the data lines 34 to
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`charge the liquid crystal devices 39 via the switching devices 38. Id.
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`The time that the pixel electrode needs to react to a driving voltage is called “response
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`time.” As was well known prior to November 17, 2003 (the effective filing date for
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`the ’843 Patent), the quality of a video image shown on an LCD panel is dependent, in
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`part, on this response time; the faster the response time, the better the image quality.
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`In this regard, the ’843 Patent explains that a delay in the response time in an LCD
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`panel causes image defects such as blurring, and describes the need for improving the
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`LCD response speed. Id. at 1:21-26, 1:62-2:2.
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`39. The ’843 Patent discusses and claims two previously known techniques for
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`improving the response time – and resultant image quality – of LCDs: (1)
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`“overdriving” the signal data; and (2) increasing the refresh rate (e.g., doubling the
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`refresh rate) of the individual pixels.
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`40. As the ’843 Patent explains, “overdriving” involves “applying a higher or a
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`lower data impulse to the pixel electrode to accelerate the reaction speed of the liquid
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`crystal molecules, so that the pixel can reach the predetermined gray level in a
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`predetermined frame period.” Id. at 2:2-7.
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`41.
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`In simple terms, overdriving enables a pixel to change from one gray level (i.e.,
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`shade of color) to another more quickly by either boosting or decreasing the
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`requested pixel value (i.e., voltage). The intended effect is to increase the difference in
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`signal between the before and after pixel values such that the boosted signal will
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`achieve the actual desired level of change (i.e., the non-boosted difference) more
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`quickly.
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`42.
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`In other words, by pushing (or pulling) the gray level harder (boosting the
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`signal), the desired pixel value is obtained faster. The faster change in pixel value,
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`because it takes less time, reduces the amount of time required for the pixel to change
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`state, meaning the LCD has a faster response time.
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`43. The ’843 Patent admits that the overdriving was known in the prior art.
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`According to the ’843 Patent, “[s]ame as the prior art, the larger the value of the
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`pixel data is [i.e. overdriving], the higher the voltage of the corresponding data
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`impulse is, and the larger the gray level value is.” See id. at 4:17-19 (emphases
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`added). In this regard, the ’843 Patent acknowledges that the “conventional
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`overdriving method” taught in the prior art could be used to increase LCD response
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`speed. Id. at 1:60-2:11.
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`44. The ’843 Patent identified U.S. Patent Application Publication No. 2002-
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`0050965 A1 to Oda et al. as “one of the references of the conventional overdriving
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`method.” Id. Generally, an overdrive value – i.e., the amount to boost or decrease the
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`data value – is computed by comparing a given pixel’s previous gray level (also
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`referred to as “transmission rate”) with the pixel’s current gray level in order to
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`predict whether and how much the gray level is increasing or decreasing. Id. at 5:34-
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`44. The ’843 Patent does not add anything new to this already known method for
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`computing the overdrive value.
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`45. The ’843 Patent alleges that, while capable of improving response time to a
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`certain extent, overdriving alone does not achieve adequate performance, namely
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`reaching a desired transmission rate within a single frame period. See id. at 2:7-12, Fig.
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`2. As shown in Figure 2 of the ’843 Patent (reproduced below), a single overdriven
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`signal C2 is purportedly unable to reach a target transmission rate T2 within a single
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`frame period N. Rather, according to this Figure, in the prior art, C2 would only reach
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`T2 in the next frame period, N+1. According to the disclosure, since the pixels are
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`unable to reach predetermined grey levels within a given frame period, the image
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`could experience blurring. Id. at 1:21-37.
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`46. To enable a signal to reach a target transmission rate T2 within a single frame
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`period, the ’843 Patent suggests applying two or more overdriven impulses to each
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`pixel within the given frame period. Id. at 4:20-40. For example, as shown in Figure 6
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`of the ’843 Patent (reproduced below), each single frame period is divided into two
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`segments. The Frame N+1 is divided into the segments n+2 and n+3. Two
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`overdriven data impulses are then applied to these two segments (e.g., one impulse
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`during n+2 and a second during n+3) to the pixel within the given frame period (e.g.,
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`N+1). This method allegedly allows the signal to reach a target transmission rate (T2)
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`within a single frame period (e.g., N+1). Id. at 1:39-41, 3:15-4:43, 5:45-55.
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`47.
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`Figure 3 (reproduced below, left) schematically illustrates an embodiment of
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`the circuit for driving the LCD panel 30. The driving circuit 10 includes a blur clear
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`converter 14, a source driver 18, and a gate driver 20. The blur clear converter 14
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`continuously receives, through a signal controller 12, a plurality of frame data G. The
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`frame data includes the data necessary to drive all of the pixels of the panel 30. The
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`blur clear converter 14 then generates the overdriven pixel data for each pixel within
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`each frame period based on the frame data. Id. at 3:24-28. Figure 5 (reproduced
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`below, right) shows two overdriven pixel data GN+1 and GN+1(2) generated by the
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`blur clear converter 14 for each pixel in the frame period N+1.
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`48. The source driver 18 then converts the overdriven pixel data (e.g., GN+1 and
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`GN+1(2)) into the corresponding data impulses. Id. at 3:28-36. The data impulses are
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`applied to the liquid crystal device 39 of a pixel within the frame period (e.g., at each
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`half of the frame period N+1) via the data line 34 in order to control the transmission
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`rate of the liquid crystal device 39. Id. at 4:8-14. The gate driver 20 generates the
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`LGD_000623
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`Declaration of Richard Zech, Ph.D.
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`corresponding scan line voltage and applies it to the scan line 32 to turn on the
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`switching device 38 of the pixel so that the data impulses from the source driver 18
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`can be applied to the liquid crystal device 39 of the pixel. Id. at 3:28-36.
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`B.
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`Claims 1, 4, 8, and 9 Of The ’843 Patent
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`49.
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`Independent Claim 1 of the ’843 Patent is an apparatus claim directed to a
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`driving circuit for driving an LCD panel. The claimed driving circuit “generat[es] a
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`plurality of overdriven pixel data within every frame period for each pixel.” (Id. at
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`Claim 1) (emphasis added). Thus, Claim 1 (and Claims 2 and 3 depending therefrom)
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`requires circuitry for applying two or more overdriven impulses to each pixel within
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`a frame period, as shown in Figures 5 and 6 above.
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`50.
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`Independent Claim 4 is a method claim directed to driving an LCD display. In
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`contrast to Claim 1, Claim 4 (and claims 5-9 depending therefrom) merely require
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`“generating a plurality of data impulses for each pixel within every frame period
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`according to the frame data.” (Id. at Claim 4) (emphasis added). Thus, Claims 4-9 do
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`not require performing the overdrive technique.
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`IV. PRIOR ART ANALYSIS
`51.
`I now turn to the references applied in the grounds for rejections discussed in
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`the Petition for inter partes review. In my analysis, I will specifically address the
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`following references:
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`18
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`LGD_000624
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`Declaration of Richard Zech, Ph.D.
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`Exhibit
`Nos.
`1010
`1008
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`1009
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`Reference
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`Referred To As
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`Korean Patent Application No. 2000-0073673 (“Lee”)
`U.S. Patent Application Publication No. 2002/0044115
`(“Jinda”)
`Laid Open Application
`Japanese
`JPH0662355A (“Miyai”)
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`Publication
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`Lee
`Jinda
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`Miyai
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`52.
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`I also provide the following table to demonstrate how terms used in the prior
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`art relate to the terms used in the ’843 Patent. For example, as I mentioned above, a
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`gate line is also called a scan line and a switching device is also called a TFT.
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`’843 Patent Terms
`Scan line
`Data line
`Switching device
`Liquid crystal device
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`Overdrive
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`Gate driver
`Source driver
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`Lee Terms
`Gate line/scanning signal
`Data line/picture signal
`Thin-film transistor (TFT)
`Liquid crystal capacitor (Cl)
`and storage capacitor (Cst)
`Overshoot
`and/or
`undershoot
`Gate driver
`Data driver
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`Jinda Terms
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`Data line/Image signal
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`Liquid crystal display
`device
`Voltage increase
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`
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`A.
`Korean Patent Application No. 2000-0073673 (“Lee”)
`53. Lee discloses a liquid crystal display device including an LCD panel, data and
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`gate driver portions, and a data grey level signal compensation portion. Ex. 1010, at
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`pp. 5-6; Fig. 8. The gate driver portion “supplies scanning signals sequentially” (id. at
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`35:14) and the data driver portion “data driver portion 300 changes the compensated
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`19
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`LGD_000625
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`Declaration of Richard Zech, Ph.D.
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`grey level signal Gn’…into the corresponding grey level voltage (data voltage) and
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`applies the voltage to the data line” (id. at 21:4-6). “Regions surrounded by the gate
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`lines and the data lines each form a pixel,” each of which includes “a thin film
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`transistor 110, a gate electrode and a source electrode of which are connected to the
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`gate line and the data line, respectively, and a pixel capacitor Cl and a storage
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`capacitor Cst that are connected to a drain electrode of the thin film transistor 110.”
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`Id. at 20:6-12.
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`54. The data grey level signal compensation portion “divides a grey level data frame
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`of a picture signal supplied from a data grey level signal source into at least two sub
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`frames, and outputs to the liquid crystal display panel a compensated grey level data
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`through an overshoot or undershoot driving according to comparing a grey level
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`signal of a previous frame and a grey level signal of a current frame, thereby making a
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`response speed of liquid crystal high.” Id. at 40:12-17; see also Figs. 13a and 13b.
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`55. Lee discloses that the frame memory “can be configured totally with 3 frame
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`memories, a picture signal input in the current frame is wrote on the first frame
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`memory 426 at 60Hz, a picture signal wrote 1 frame before is stored in the second
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`memory 427, and a picture signal wrote 2 frames before is stored in the third
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`memory 428.” Id. at 32:8-11.
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`20
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`LGD_000626
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`Declaration of Richard Zech, Ph.D.
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`1.
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`Claim 1 Is Anticipated By Lee
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`Claim 1
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`56. Claim 1 of the ’843 Patent recites:
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`1. A driving circuit for driving an LCD panel, the LCD panel
`comprising:
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` a
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` plurality of scan lines;
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` 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,
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`the driving circuit comprising: a blur clear converter for receiving frame
`data every frame period, each frame data comprising a plurality of pixel
`data and each pixel data corresponding to a pixel,
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`the blur clear converter delaying current frame data to generate delayed
`frame data and generating a plurality of overdriven pixel data within
`every frame period for each pixel;
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` a
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` source driver for generating a plurality of data impulses to each pixel
`according to the plurality of overdriven pixel data generated by the blur
`clear converter and applying the data impulses to the liquid crystal device
`of the pixel via the scan line connected to the pixel within one frame
`period in order to control transmission rate of the liquid crystal device;
`and
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` a
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` gate driver for applying a scan line voltage to the switch device of the
`pixel so that the data impulses can be applied to the liquid crystal device
`of the pixel.
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`57.
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`It is my opinion that Lee discloses each and every element of Claim 1 of the
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`21
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` a
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` plurality of data lines; and
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` a
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`LGD_000627
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`Declaration of Richard Zech, Ph.D.
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`’843 Patent.
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`58. Lee discloses the scan lines of Claim 1, referring to them as “gate lines.” Lee
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`discloses a liquid crystal display and driving device. Ex. 1010, at 4:2-3. More
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`specifically, Lee discloses a liquid crystal display device panel 100 that includes a
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`plurality of gate lines S1-Sn for supplying scanning signals provided by gate driver
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`200. Id. at 20:6-7, 35:13-15. Thus, Lee discloses an LCD panel comprising “a plurality
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`of scan lines,” as required by Claim 1.
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`59. Next, Lee discloses data lines. Lee discloses that the liquid crystal display device
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`panel 100 includes a plurality of data lines D1-Dm, which transfer data or picture
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`signals. Id. at 20:6-7; 35:13-15; Fig. 8. Thus, Lee discloses an LCD panel comprising
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`“a plurality of data lines,” as required by Claim 1.
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`60. Lee discloses that the scan lines and data lines are connected to pixels
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`Specifically, Lee discloses “[r]egions surrounded by the gate lines and the data lines
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`each form a pixel.” Id. at 20:8-12; Fig. 8. Each pixel includes “a thin film transistor
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`110 [switching device], a gate electrode and a source electrode of which are
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`connected to the gate line and the data line, respectively, and a pixel capacitor Cl and
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`a storage capacitor Cst [collectively, liquid crystal device] that are connected to a
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`drain electrode of the thin film transistor 110.” Id. at 20:9-12. Thus, Lee discloses “a
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`plurality of pixels, each pixel being connected to a corresponding scan line and a
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`LGD_000628
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`Declaration of Richard Zech, Ph.D.
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`corresponding data line, and each pixel comprising a liquid crystal device and a
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`switching device connected to the corresponding scan line, the corresponding data
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`line, and the liquid crystal device,” as required by Claim 1.
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`61. Lee discloses that the liquid crystal display device includes a data grey level
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`compensation portion 400 (i.e., picture signal compensation circuit) that provides
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`data for the data driver 300. As shown in Figures 13a and 13b, the data
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`compensation signal portion 400 includes a frame memory portion 420 (including
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`first and second frame memories 422 and 424), synthesizer 410, controller 430, data
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`grey level signal converter 442, and a separator 450. Id. at 26:15 – 28:17. The frame
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`memory portion 420 stores grey level signals for a plurality of pixels during each
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`frame period. Id. at 27:1-7. Thus, Lee discloses a “driving circuit comprising: a blur
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`clear converter for receiving frame data every frame period, each frame data
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`comprising a pl
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