`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`In re Inter Partes Review of:
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`
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`U.S. Patent No. 6,508,563
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`
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`Filed: Dec. 5, 2001
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`Issued: Jan. 21, 2003
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`Trial No.: IPR2015-00895
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`Attorney Docket: 04305.9000-01
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`Inventors: PARKER, Jeffery R., et al.
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`Panel: Not Yet Assigned
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`Assignee: Innovative Display Technologies,
`LLC
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`Title: LIGHT EMITTING PANEL
`ASSEMBLIES FOR USE IN AUTOMOTIVE
`APPLICATIONS AND THE LIKE
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`DECLARATION OF JOHN L. WEST, Ph.D.
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`I, John Lawton West, Ph.D., declare as follows:
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`I have been retained by Toyota Motor Corporation (“Petitioner”) to provide
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`expert opinions in connection with the above-captioned inter partes review being
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`requested by Petitioner. A summary of my opinions appears below.
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`
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`TOYOTA EXHIBIT 1019
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`PAGE 1 OF 54
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`Table of Contents
`Introduction ................................................................................................................. 1
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`Background and Experience ...................................................................................... 1
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`I.
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`II.
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`III. Materials Reviewed ..................................................................................................... 3
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`IV. Guiding Legal Principles ............................................................................................ 3
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`A.
`
`B.
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`Person of Ordinary Skill in the Art ............................................................... 3
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`Anticipation Invalidity .................................................................................... 4
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`C. Obviousness Invalidity ................................................................................... 5
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`V. Overview of the ’563 Patent ...................................................................................... 6
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`VI. Claim Construction ..................................................................................................... 9
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`VII. Explanation of the Prior Art References and Combinations ................................ 9
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`A.
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`B.
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`Johnson, U.S. Patent No. 4,947,293 ............................................................. 9
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`Hitzelberger, French Patent Application Pub. No. FR 1474359 ............ 12
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`C. Decker, German Patent Publication No. 41 29 094 A1 ........................... 15
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`D.
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`E.
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`F.
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`G.
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`Pristash, U.S. Patent No. 5,005,108 ............................................................ 17
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`Takahashi, Japanese Laid Open Utility Model Application
`Publication No. JP S59-43234 ..................................................................... 19
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`Shinkai, Japanese Utility Model Publication No. JP H1-92004U ........... 21
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`Yamada, Japanese Utility Model Publication No. JP S62-167304U ....... 23
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`H. Obviousness Combinations ......................................................................... 25
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`1.
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`2.
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`Obviousness of combining the teachings of Johnson and
`Decker to attach a light source to the input surface and to
`connect the light source to a printed circuit board ........................ 25
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`Obviousness of combining the teachings of Hitzelberger
`and Decker to attach a light source to the input surface and
`connect the light source to a printed circuit board ........................ 27
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`3.
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`4.
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`Obviousness of combining the teachings of Hitzelberger
`and Pristash to provide a lens or film .............................................. 29
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`Obviousness of combining the teachings of Takahashi and
`Shinkai to wrap a light-emitting panel around the corner of
`a vehicle ............................................................................................... 29
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`VIII. Secondary Considerations of Obviousness ........................................................... 31
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`PAGE 3 OF 54
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`I.
`1.
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`Introduction
`I have been retained by Toyota Motor Corporation (“Toyota” or “Petitioner”)
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`as an independent expert consultant in this proceeding before the United States
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`Patent and Trademark Office. Although I am being compensated at my standard rate
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`of $400.00 per hour for the time I spend on this matter, no part of my compensation
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`depends on the outcome of this proceeding, and I have no other interest in this
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`proceeding.
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`2.
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`I understand that this proceeding involves U.S. Patent No. 6,508,563 (“the ’563
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`patent”) (attached as Ex. 1001).
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`3.
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`I have been asked to render certain opinions regarding the ’563 patent and
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`whether certain references would disclose or suggest certain features in the claims of
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`the ’563 patent to a person of ordinary skill in the art. The substance and bases of my
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`opinions appear below.
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`II. Background and Experience
`4. My curriculum vitae, which includes a more detailed summary of my
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`background, experience, and publications, is attached as Appendix A.
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`5.
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`I was awarded a B.S. in chemistry from the College of William and Mary in
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`1976, and an M.S. and Ph.D. in Chemistry from Carnegie Mellon-University in 1979
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`and 1980. I am a University Trustee Professor at Kent State University, where I teach
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`and conduct research in the fields of liquid crystal materials and devices.
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`6. My teaching includes a graduate-level course titled “Chemical Physics of
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`Electro-Optic Polymers,” which covers subjects ranging from the basics of
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`polymerization to the optics of polymer films, including edge-illuminated panels and
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`light-emitting diodes (LEDs). I also teach an honors-level course titled “Be Smarter
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`than Your Phone,” which surveys the technologies that make the smart phone
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`possible and assesses the impact on business and communications.
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`7. My research includes developing a novel means of producing transparent
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`conducting electrodes on plastic substrates required for displays and touch screens,
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`developing responsive fibers used to integrate displays and electronics in clothing and
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`medical sensors, and exploring the mechanism of chiral induction in liquid crystals.
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`8.
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`I am named as an inventor on 19 separate patents and patent applications,
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`which cover various technologies relating primarily to liquid crystal applications.
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`9.
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`Since 1984, I have served as a Senior Research Fellow at the Liquid Crystal
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`Institute (“LCI”) at Kent State University, also serving as Associate Director from
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`1990-1996, and as Director from 1997-2003. The LCI is recognized as the world’s
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`leading research center in the field of liquid crystals. The LCI includes over 50 faculty
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`members from departments across Kent State University, including chemistry,
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`physics, biology, mathematics, and computer science. I concurrently served as
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`Director of the Chemical Physics Interdisciplinary Program (“CPIP”) at Kent State
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`from 1997-2003, and of the NSF Science and Technology Center for Advanced
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`Liquid Crystalline Optical Materials (“ALCOM”) from 1997 to 2002. During my
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`tenure as Director of the LCI, CPIP, and ALCOM, I established and oversaw an
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`industrial partnership that engaged over 60 companies from across the nation and
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`around the world, fostered the transfer of technology from lab to market, supervised
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`the design of a 65,000 square-foot research and education facility and received an
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`NSF Pioneer Award in 2003 for my leadership of ALCOM.
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`10. My work with the LCI covered a broad range of subjects, including subjects
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`relating to automotive applications. For example, I collaborated with scientists from
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`General Motors on research from June 1986 to May 1989 on a significant sponsored
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`program. The research studied certain optics issues generally related to sun roofs for
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`vehicles, and resulted in at least three papers coauthored by me and General Motors
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`scientists.
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`III. Materials Reviewed
`11. The opinions set forth in this declaration are based on my education, my
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`experience and the documents listed in Appendix B, which I reviewed in forming my
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`opinions.
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`IV. Guiding Legal Principles
`A.
`Person of Ordinary Skill in the Art
`I am informed that a “person of ordinary skill in the art” (“POSITA”) refers to
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`12.
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`a hypothetical person who is presumed to have known the relevant art at the time of
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`the invention. Many factors may determine the level of ordinary skill in the art,
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`including: (1) the type of problems encountered in the art, (2) prior art solutions to
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`those problems, (3) the rapidity with which innovations are made, (4) the
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`sophistication of the technology, and (5) the educational level of active workers in the
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`field. I understand that a POSITA is a person of ordinary creativity, not an
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`automaton, meaning that a POSITA may employ inferences and creative steps in their
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`work. I am informed that the relevant timeframe is prior to January 16, 1996, which is
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`the earliest priority filing date for the ’563 patent, and the opinions below pertain to
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`that timeframe.
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`13. A POSITA for this patent would have had at least an undergraduate degree in a
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`science or engineering discipline, and a few years of work experience in a field related
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`to optical technology, a graduate degree in a field related to optical technology, or a
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`few years of continuing education toward a graduate degree in a field related to optical
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`technology.
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`B.
`Anticipation Invalidity
`I understand that a patent claim is “anticipated,” and, therefore, invalid, if a
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`14.
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`single prior art reference discloses (expressly or inherently) each and every element of
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`the claimed invention in a manner sufficient to enable a POSITA to practice the
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`invention, thus placing the invention in possession of the public.
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`15.
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`I also understand that under certain circumstances, multiple references may be
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`used to prove anticipation, specifically to: (a) prove that the primary reference
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`contains an enabled disclosure, (b) explain the meaning of a term used in the primary
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`reference, or (c) show that a characteristic not disclosed in the reference is inherent.
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`C. Obviousness Invalidity
`I understand that even if a prior art reference fails to anticipate a patent claim,
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`16.
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`the claim may nonetheless be invalid as “obvious,” if the differences between the
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`subject matter claimed and the prior art are such that the subject matter as a whole
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`would have been obvious at the time the invention was made to a POSITA. I
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`understand that several factual inquires underlie a determination of obviousness.
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`These inquiries include the scope and content of the prior art, the level of ordinary
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`skill in the art, the differences between the claimed invention and the prior art, and
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`any objective “secondary consideration,” discussed below. I understand that a
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`combination of familiar elements according to known methods may be obvious when
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`it does no more than yield predictable results. I also have been advised that common
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`sense and ordinary creativity of one skilled in the art can be relevant to obviousness.
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`17.
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`I have been informed that certain objective secondary considerations may be
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`relevant to a determination of whether an invention was obvious. Such secondary
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`considerations may include, e.g., (a) whether there was a long-felt and long-unmet
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`need for the invention, (b) whether the invention achieved unexpected results, (c) the
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`commercial success of the invention, and (d) whether the invention was copied or
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`praised within the industry.
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`PAGE 8 OF 54
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`V. Overview of the ’563 Patent
`18. The ’563 patent, is titled “Light Emitting Panel Assemblies for Use in
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`Automotive Applications and the Like.” I understand that the earliest priority filing
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`date to which the ’563 patent may be entitled is January 16, 1996.
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`19. The ’563 patent relates to light emitting panel assemblies for use in automotive
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`applications. Ex. 1001, ’563 patent at 1:16-18. The ’563 patent acknowledges, and I
`
`agree, that “[l]ight emitting panel assemblies are generally known.” Id. at 1:22-25.
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`20. The ’563 patent describes a broad range of light emitting panel applications
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`using similar optics principles, including steering wheels, LCD displays, control
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`switches and keypads, dome lighting, and instrument panels. Id. at 1:33-3:27. The ’563
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`patent also describes examples of “light emitting panel assemblies 24 [that] are
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`mounted in body panels 25 along the rear, front and/or sides of a vehicle to provide
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`vehicle running lights or accent lights or to light a logo, step, running board, or other
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`surface area of a vehicle,” as illustrated in Figure 4 (reproduced below). Id. at 8:31-38.
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`According to the patent, “light sources” (9) [highlighted below in red] may be
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`positioned “along the back edges of the panel members 29 [highlighted below in
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`yellow] used to provide running taillights for a vehicle.” Id. at 8:56-63. According to
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`the patent, the light sources may be “embedded, potted or bonded in the light
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`transition regions of the panels,” “mechanically held in place by a holder . . . in a slot
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`in an edge of the panel member,” or “a fiber optic light pipe 64 [may be used] for
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`transmitting light to the panel member from a remote light source 65.” Id. at 9:10-19.
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`’563 Patent, Fig. 4 (annotated)
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`
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`21. The ’563 patent states that “these panel members 29 may form the exterior
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`surface of the body panel 25 as shown at the left hand side of FIG. 4 or a lens or
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`film 34 may cover the panel members as shown at the right hand side of FIG. 4.” Id.
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`at 9:5-9.
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`22. The ’563 patent also describes that “[a]n additional array of light sources 31
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`such as LEDs or incandescent or halogen lamps . . . may be strategically mounted
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`inwardly (i.e., behind) the inner surface of the light emitting panel members 29 and/or
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`30 to cause a more intense light to shine through the panel members and a trans
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`reflector 32 if provided on the panel members or through one or more clear areas or
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`holes 33 where no print pattern, back reflector or trans reflector is provided on the
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`panel members . . . .” Id. at 9:21-29.
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`23.
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`Independent claims 1, 11, and 22 of the ’563 patent share substantially
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`overlapping subject matter. Exemplary claim 1 recites a light emitting panel assembly
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`mounted on a body portion of a vehicle, comprising: at least one solid light emitting
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`panel member having top and bottom surfaces and a greater cross sectional width
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`than thickness, said panel assembly having at least one light input surface for receiving
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`light from at least one light source and directing the light through said panel assembly
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`from an edge of said panel assembly for emission of the light from one of said top
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`and bottom surfaces of said panel member, and said panel member being located on
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`an exterior surface of said body portion with said panel member wrapped around a
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`corner of said vehicle to provide illumination around said corner. In claims 11 and 22,
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`the panel member is “conforming to a curved profile of said vehicle,” rather than
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`“wrapped around a corner,” and in claim 22, the “light source [is] attached to said
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`light input surface.”
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`24.
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`Independent claim 5 recites at least one solid light emitting panel member with
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`at least one light input surface, but does not require that the panel be located on an
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`“exterior surface,” “wrapped around a corner,” or “conforming to a curved profile”
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`of the vehicle. In claim 5, an “other light source” is located directly behind the panel
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`member for shining light through the panel member independently of the light
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`emitted by the panel member from the (first) light source.
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`25. Dependent claims 2, 7-9, 18, and 23 recite additional features, including that:
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`the panel member is “located at least at one of a rear corner and a front corner of said
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`vehicle” (claim 2); the “other light source” is a “light emitting diode, an incandescent
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`lamp, [or] a halogen lamp” (claim 7) or “produces sufficient illumination to provide
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`. . . a brake light, a turn signal light, a turning light [or] a backup light” (claim 8); or
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`that the assembly further includes a “trans reflector” (claim 9), a “lens or film”
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`(claim 18), or a “printed circuit board” (claim 23).
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`VI. Claim Construction
`26. Dependent claim 9 recites a “trans reflector on said panel assembly through
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`which a portion of light from said other light source passes.”
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`27. The ’563 patent generally refers to “trans reflectors” as a type of back reflector
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`or reflective coating. See Ex. 1001 at 7:14-20. Light from light sources 31 provided
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`behind panel members 29, 30 shown in FIG. 3 is described as “shin[ing] through the
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`panel members and a trans reflector 32.” See Ex. 1001 at 9:24-25.
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`28. The term “transflector” is more commonly used in the art, and refers generally
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`to a component that both transmits and reflects light. Based on the disclosure in the
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`’563 patent and the understanding of a term “transflector,” a “trans reflector” would
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`have been understood to refer to a component that both transmits and reflects light.
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`VII. Explanation of the Prior Art References and Combinations
`
`A.
`
`Johnson, U.S. Patent No. 4,947,293
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`29.
`
`I understand that U.S. Patent No. 4,947,293 (“Johnson”) issued on August 7,
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`1990. Johnson is titled “Cargo Vehicle Perimeter Clearance Lighting System.”
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`Johnson states that its invention involves “an elongated light-conducting strip clad
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`about its cross-section with a translucent material,” and that “[a] light source with
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`light focusing reflectors is adapted to end-illuminate [the] light guides.” Ex. 1003,
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`Johnson, Abstract.
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`30. As shown in annotated FIGS. 1 and 8 below, Johnson’s clearance lighting
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`system includes a “light source enclosure 26” with a light source 28 inside, and a pair
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`of light guides 13 and 14 having input ends positioned within the light source
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`enclosure. The light guides 13 and 14 are recessed into a conventional elongated
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`indentation within a container body 11 of the vehicle. See Ex. 1003, Johnson at 2:54-
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`58. As shown in FIG. 8, the light guides 13 and 14 are flexible to facilitate corner
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`bends 29 and 30 along corners of the container body 11. See Ex. 1003 at 3:35-40.
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`The lighting system of Johnson is aimed at developing flat light guides 13 and 14 in
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`accordance with optic fiber principles and optimizing light transmission in a
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`longitudinal direction (i.e. along a length of the light guides 13 and 14) as well as light
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`transmission in a lateral direction (i.e. along a thickness of the light guides 13 and 14).
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`See Ex. 1003, Johnson at 1:33-61.
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`Johnson, Fig. 1 (annotated) and Fig. 8
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`
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`31. As illustrated in FIGS. 3 and 6, reproduced below, Johnson teaches that light
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`flux (shown with arrows) generated from a light source 28 is reflected by a double
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`concave reflector 27 and focused to enter through an inward end of the light guides
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`13 and 14. See Ex. 1003, Johnson at 3:21-30. The light flux is transmitted through the
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`light guides 13 and 14 in the longitudinal direction (FIG. 6) and emitted out of the
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`light guides 13 and 14 in the lateral direction as illustrated by arrows 23 in FIG. 3.
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`Johnson, Figs. 3 and 6
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`
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`32. As shown in FIG. 3 of Johnson, annotated below, the light guides 13 and 14
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`include at least two flat surfaces, a first (bottom) surface facing the container body 11
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`and a second (top) surface opposing the first surface through which the light flux 23
`
`exits the light guides 13 and 14. As illustrated, the light guides 13 and 14 have a
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`“cross sectional width” that is greater than a “thickness.”
`
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`Johnson, Fig. 3 (annotated)
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`33. As illustrated in Figure 6, each of the light guides 13 and 14 includes at least
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`one light input surface provided at an edge of the light guides for receiving the light
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`flux shown with arrows from the light source 28. Ex. 1003, Johnson at 3:22-27 (light
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`focused on the “inward end of light guide 13”). The light source 28 and the edges of
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`light guides 13 and 14 corresponding to the light input surface are attached to each
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`other (albeit indirectly) via the enclosure 26.
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`34. The flat light guides 13 and 14 are made from a monolithic core 13a encased by
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`a “cladding” 13b. Ex. 1003, Johnson at 2:63-67; see also Fig. 3 (above). A POSITA
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`would recognize the cladding of Johnson as a “lens or film,” as recited in claim 18 of
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`the ’563 patent.
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`B. Hitzelberger, French Patent Application Pub. No. FR 1474359
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`35.
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`I understand that Hitzelberger is a French patent application document, which
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`was published on March 24, 1967, as FR 1,474,359. My opinions are based on review
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`of a certified English language translation of Hitzelberger, which has been marked as
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`Exhibit 1005.
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`36. Hitzelberger is titled “Illumination device, in particular an exterior lamp for
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`motor vehicles.” More specifically, Hitzelberger states that its invention consists “of a
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`light source in the form of at least one incandescent lamp or similar apparatus, an
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`illumination body translucent to light, and means for attaching the whole illumination
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`device, e.g., to the exterior body of a motor vehicle.” Ex. 1005, Hitzelberger at 1,
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`col. 1:1-7.
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`37. As shown in FIG. 1 below, the illumination device of Hitzelberger includes an
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`“incandescent lamp 11 mounted at [an] end” of an illumination body 10. Ex. 1005,
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`Hitzelberger at 2, col. 2:42-51.
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`38. Hitzelberger discloses that conventional illumination devices for vehicles—
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`typically made of glass—are sensitive to shock and require complex manufacturing
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`and maintenance processes to conform to the body of a motor vehicle. Id. at 1,
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`col. 1:8-21. Hitzelberger overcomes these disadvantages by providing an “illumination
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`device [that] is made of a flexible synthetic material, which receives . . . an illumination
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`source, whose light illuminates the full extent of the body.” Id. Due to that flexibility,
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`Hitzelberger’s illumination device may propagate light “around curved parts or
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`angles,” and may be used “for indication or warning.” Id. at 1, col. 2:4-8.
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`39. As illustrated in Figures 3 and 4, reproduced below, Hitzelberger discloses
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`illumination bodies (16 and 21), each of which includes at least two surfaces, a first
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`flat surface facing decorative molding 15 or bumper 18, and a second surface
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`opposing the first surface through which light from the incandescent lamp 11 exits
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`bodies 16 and 21. As shown, the body of the illumination device has a greater width
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`than thickness. See id. at 1, col. 2:15-18 (“provide the body of the illumination device
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`with a longitudinal extension substantially greater than its transverse extension or
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`depth”).
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`Hitzelberger, Figs. 3 (left) and 4 (right)
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`40. Hitzelberger discloses that the light source (i.e. incandescent lamp 11) “may be
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`mounted in any manner” (id. at 2, col. 1:16-17); however, FIG. 1 shows a particular
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`embodiment in which the body 10 includes a recess 12 at one end where light source
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`11 is “inserted into” the recess extending in the longitudinal direction. Id. at 3,
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`col. 1:1-6. As illustrated in the annotated figure below, the recess 12 of body 10
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`includes at least one light input surface, which receives light from the incandescent
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`lamp 11, and to which (as illustrated) the incandescent lamp 11 is attached. Light is
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`then directed through body 10 longitudinally from the edge and emitted therefrom.
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`Hitzelberger, Fig. 1 (annotated)
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`C. Decker, German Patent Publication No. 41 29 094 A1
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`41.
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`I understand that Decker is a German Patent Application published on March
`
`4, 1993. My opinions are based on my review of a certified English-language
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`translation of Decker, which has been marked as Exhibit 1012.
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`42. Decker is titled “Signal lamp for motor vehicles,” and discloses a vehicle signal
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`lamp that simply and economically provided even illumination at a low current
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`consumption. Ex. 1012, Decker at 2, col. 1:44-50. To do so, Decker invented a system
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`that used fewer LEDs than prior designs, yet evenly lighted a large surface area. Id. at
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`2, col. 2:34-49 Prior embodiments had used many closely spaced LEDs to provide
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`even illumination, but the large number of LEDs increased production cost and
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`current consumption. Id. at 2, col. 1:24-43. Decker reduced the number of LEDs by
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`incorporating light guide elements that transmit light across larger surface areas,
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`thereby dispersing the light and ensuring even and economical illumination. Id. at 2,
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`col. 2:34-49.
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`43. Each of Decker’s signal lamps included LEDs and light guide elements L. Each
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`light guide L is a long, thin element with an LED at one end, as shown by annotated
`
`Fig. 3 below. As shown in Fig. 3, the LED emits light into light guide element L,
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`which has deformities in the form of prisms P on one side. Id. at 5, col. 1:30-36. If the
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`light hits one of these deformities, it is reflected in such a way that it exits the light
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`guide on the opposite side. Id. at 5, col. 2:12-21. The amount of light emitted along
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`the length of the light guide element L can be controlled by modifying the prism
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`angle, division, and/or depth. Id.
`
`Decker, Fig. 3 (annotated)
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`
`
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`Decker, Fig. 9 (annotated)
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`44. Decker discloses groups (GP), formed by a number of LEDs associated with
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`light guides L, arranged parallel to one other, and placed behind an end plate A, as
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`illustrated in Figure 1 (below). The group GP illuminates the transparent end plate A,
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`which, thus, acts as a transparent substrate overlying and covering (and thus
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`necessarily protecting) the groups GP. Id. at 4, col. 2:19-22, 6, col. 1:7-10. Figure 1,
`
`below, shows a housing G holding four end plates A, each having a group GP for
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`illumination.
`
`Ex. 1004, Decker, Fig. 1
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`
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`45. Decker discloses that “said light source is connected to a printed circuit board”
`
`as required in dependent claim 23. Further, as for claim 22, Decker expressly
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`discloses the advantageous effects of mechanically and directly connecting a surface of
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`the light source to a surface of the panel members. See id. at 5, col. 1:43-49 (“For an
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`optimal utilization of the light emitted by the light-emitting diode (LED), the form of
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`the light-coupling surface (LK) of the light guide element (L) is adapted to the form
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`of the light-emitting surface and the light-radiating characteristic of the light-emitting
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`diode (LED).”).
`
`D.
`Pristash, U.S. Patent No. 5,005,108
`I understand that U.S. Patent No. 5,005,108 (Ex. 1010, “Pristash”) issued on
`
`46.
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`April 2, 1991. Pristash is titled “Thin Panel Illuminator,” and lists Jeffery Parker (the
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`named inventor of the ’563 patent) as a co-inventor.
`
`47.
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`Pristash describes a number of features later described in the ’563 patent, such
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`as a solid transparent panel member for conducting light and an extractor means (e.g.,
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`prismatic film, coating, or lens) for causing light conducted by the panel member to
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`be emitted along the length thereof. See Ex. 1010, Pristash at 1:6-10; Fig. 7 (below).
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`The panel member directs light in a direction determined by its boundaries, whereas
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`the extractor means causes the light to be emitted from the wave guide. See id. at 6:64-
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`7:8. These are the same features described in the ’563 patent. See Ex. 1001, ’563
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`patent at FIG. 4 (depicting a lens or film covering a panel member).
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`PAGE 20 OF 54
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`48. Referring to FIG. 7 (reproduced above), Pristash discloses a light emitting
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`panel 50 including a panel prismatic surface 52 (i.e., light transmitting panel member)
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`and a prismatic film 60 (i.e., lens or film) that covers the panel prismatic surface 52
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`and is attached to an upper surface of the panel prismatic surface 52 by epoxy 61.
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`Ex. 1010, Pristash at 5:22-33. The prismatic film 60 is used to “shift the angular
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`emission of light toward a particular application.” See id. at 5:22-25.
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`Pristash, Fig. 8
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`
`
`49.
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`In another embodiment, Pristash at FIG. 8 (reproduced above) discloses a thin
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`panel illuminator 61 including “a light emitting panel 62 and a transition device 63 for
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`transmitting light from a light source 64 . . . to [a] panel input surface (end edge) 66.”
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`Id. at 5:36-40. The light emitting panel 62 includes a laminated structure with a solid
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`transparent wave guide 67 and extractor 68 joined together by an adhesive layer 69.
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`See id. at 5:40-44. The extractor 68 may be joined to the wave guide 67 by various
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`PAGE 21 OF 54
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`other methods including clamping, fastening, heat sealing and solvent gluing. See id. at
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`5:51-56.
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`50. Light (shown with an arrow in FIG. 8 above) that enters the wave guide 67
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`from the transition device 63 is internally reflected until the light strikes the wave
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`guide-extractor interface 70 and is emitted from the thin panel illuminator 61. See id.
`
`at 5:44-48. The extractor 68 may consist of one or more coatings applied directly to
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`selected areas of the top or bottom surfaces of the wave guide 67. Id. at 5:51-56.
`
`E. Takahashi, Japanese Laid Open Utility Model Application
`Publication No. JP S59-43234
`I understand that Takahashi is a Japanese patent application document
`
`51.
`
`published on March 21, 1984, in the Japanese language. My opinions are based on my
`
`review of a certified English-language translation of Takahashi, marked as
`
`Exhibit 1007.
`
`52. Takahashi is titled “Lamp Cover,” and relates specifically “to lamp covers of
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`vehicle headlamps and vehicle tail lamps.” Ex. 1007, Takahashi at 2:11-12. Takahashi
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`describes known vehicle lamps as having “a light source behind the lens, [wherein]
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`light passes through the lens.” Id. at 2:13-15. Takahashi purports to improve the
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`known design by providing a covering “semitransparent plate.” Id. at 3:1-3. More
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`particularly, Takahashi discloses a “semitransparent plate (1) [which] has a light
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`transmitting property” and a “light source (5) . . . provided at the edge portion (6)” of
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`PAGE 22 OF 54
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`the plate, with another “lamp light source (7)” provided “rearward of the
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`semitransparent plate (1).” Id. at 3:4-14, 23-26.
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`53. Examples of Takahashi’s use of a plate (1), light source (5), and a lamp light
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`source (7) are illustrated in Figures 5-6 (reproduced below). As illustrated, the bulbs 5
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`and 7 have a filament—i.e., they are incandescent bulbs.
`
`
`Takahashi, Fig. 5 (left) and Fig. 6 (right) (both annotated)
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`54. Takahashi further discloses that the semi-transparent nature of the plate (1)
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`may be achieved by forming “vapor deposition of aluminum, silver or carbon on an
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`inner surface of the glass surface,” or “such materials may be applied by coating, or a
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`semi-light-blocking body (3) such as a semi-light blocking film may be attached to the
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`inner surface of the glass surface as shown in Fig. 5.” Id. at 3:10-14. A POSITA would
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`have understood that the deposited aluminum, silver or carbon, or the semi-light
`
`blocking body (3) would be both reflective (particularly in the case of silver) and
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`PAGE 23 OF 54
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`transmissive (to allow light from lamp (7) to be transmitted through)—i.e., the
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`component is a trans reflector, in the terminology of claim 9 of the ’563 patent.
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`55. The plate of Takahashi may transmit light around a corner, as illustrated in
`
`Figure 6 (above). See id. at 3:16-18 (“the upper end of the semitransparent plate (1)
`
`may be bent rearward (rightward in the drawing), and a light source (5) may be
`
`provided at the edge portion (6) at the rear end thereof”).
`
`56. The trans reflector of Takahashi (whether deposited or coated aluminum, silver
`
`or carbon, or a semi-light-blocking body) would have been understood by a POSITA
`
`to be a “trans reflector” as described in the ’563 patent and as recited in claim 9,
`
`because it both reflects light (e.g., to conceal the rear of the lamp (2) when not
`
`illuminated) and transmits light (e.g., to allow light from the lamp light source (7) to
`
`be emitted when illuminated).
`
`Shinkai, Japanese Utility Model Publication No. JP H1-92004U
`F.
`I understand that Shinkai is a Japanese utility model application document
`
`57.
`
`published on June 16, 1989, in the Japanese language. My opinions are based on my
`
`review of a certified English-language translation of Shinkai, marked as Exhibit 1009.
`
`58.
`
`Shinkai is titled “Vehicle lamp,” and relates specifically to “a vehicle lamp in
`
`which a light guiding space of a substantially L-shaped sectional