Filed on behalf of: Toyota Motor Corporation
`
`By: Thomas W. Winland
`
`P. Andrew Riley
`
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-4000
`Facsimile: 202-408-4400
`E-mail: tom.winland@finnegan.com
`
`andrew.riley@finnegan.com
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`Toyota Motor Corporation,
`Petitioner
`
`v.
`
`Innovative Display Technologies LLC,
`Patent Owner
`
`
`Case No. Case No. IPR2015-00897
`Patent No. 7,404,660
`
`
`
`DECLARATION OF DR. ZANE COLEMAN
`
`
`
`
`
`
`TOYOTA EXHIBIT 1004
`
`PAGE 1 OF 56
`
`
`
`By: Thomas W. Winland
`
`P. Andrew Riley
`
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-4000
`Facsimile: 202-408-4400
`E-mail: tom.winland@finnegan.com
`
`andrew.riley@finnegan.com
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`Toyota Motor Corporation,
`Petitioner
`
`v.
`
`Innovative Display Technologies LLC,
`Patent Owner
`
`
`Case No. Case No. IPR2015-00897
`Patent No. 7,404,660
`
`
`
`DECLARATION OF DR. ZANE COLEMAN
`
`
`
`
`
`
`TOYOTA EXHIBIT 1004
`
`PAGE 1 OF 56
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`
`
`I.
`
`TABLE OF CONTENTS
`
`Page
`INTRODUCTION .................................................................................................... 1
`
`II. GUIDING LEGAL PRINCIPLES ......................................................................... 1
`
`A.
`
`B.
`
`Person of Ordinary Skill in the Art ............................................................... 1
`
`Anticipation Invalidity .................................................................................... 2
`
`C. Obviousness Invalidity ................................................................................... 3
`
`III. BACKGROUND AND EXPERIENCE ............................................................... 4
`
`IV. MATERIALS REVIEWED ..................................................................................... 6
`
`A.
`
`Claim Construction ....................................................................................... 11
`
`“Deformities” ................................................................................................ 11
`
`VI.
`
`PRIOR ART ANALYSIS ........................................................................................ 12
`
`A.
`
`B.
`
`Claims 1, 3, 10, 16-17, 33, and 34 Are Unpatentable Under 35
`U.S.C. § 102(a) As Being Anticipated By Mino .......................................... 12
`
`Claims 1, 3, 10, 16-17, 25, 33, and 34 Are Unpatentable Under 35
`U.S.C. § 103(a) As Being As Obvious Over Yoshikawa (Ex. 1008)
`In View Of Mino (Ex. 1005) ......................................................................... 26
`
`
`
`i
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`PAGE 2 OF 56
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`I.
`
`1.
`
`I, Dr. Zane Coleman, declare as follows::
`
`INTRODUCTION
`2.
`I have been retained by Toyota Motor Corp. (“Toyota” or “Petitioner”)
`
`as an independent expert consultant in this proceeding before the United States
`
`Patent and Trademark Office. Although I am being compensated at my usual rate of
`
`$400.00 per hour for the time I spend on this matter, no part of my compensation
`
`depends on the outcome of this proceeding, and I have no other interest in this
`
`proceeding.
`
`3.
`
`I understand that this proceeding involves U.S. Patent No. 7,404,660
`
`(“the ’660 patent”) (attached as Ex. 1001 to the petition). I understand that the ’660
`
`patent was filed on June 16, 2006. I also understand that the ’660 patent is part of a
`
`large family of patents and one of several continuations, continuation-in-part, and/or
`
`divisions stemming from U.S. Patent No. 5,613,751, which was filed on June 27, 1995.
`
`4.
`
`I have been asked to render certain opinions regarding the ’660 patent
`
`and whether certain references disclose or suggest certain features in the claims of the
`
`’660 patent.
`
`II. GUIDING LEGAL PRINCIPLES
`A.
`Person of Ordinary Skill in the Art
`
`5.
`
`I am informed that a “person of ordinary skill in the art” (“POSITA”)
`
`refers to a hypothetical person who is presumed to have known the relevant art at the
`
`time of the invention. Many factors may determine the level of ordinary skill in the
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`PAGE 3 OF 56
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`art, including: (1) the type of problems encountered in the art, (2) prior art solutions
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`to 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
`
`automaton, meaning that a POSITA may employ inferences and creative steps in their
`
`work. I am informed that the relevant timeframe is prior to June 27, 1995, which is
`
`the earliest priority filing date for the ’660 patent, and the opinions below pertain to
`
`that timeframe.
`
`6.
`
`A POSITA in the art for this patent would have at least an
`
`undergraduate degree in a science or engineering discipline, and a few years of work
`
`experience in a field related to optical technology, a graduate degree in a field related
`
`to optical technology, or a few years of continuing education toward a graduate degree
`
`in a field related to optical technology. Accordingly, I have used this definition in my
`
`analysis below.
`
`B.
`
`7.
`
`Anticipation Invalidity
`
`I understand that a patent claim is “anticipated,” and, therefore, invalid,
`
`if a single prior art reference discloses (expressly or inherently) each and every element
`
`of 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.
`
`8.
`
`I also understand that under certain circumstances, multiple references
`
`may be used to prove anticipation, specifically to: (a) prove that the primary reference
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`2
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`PAGE 4 OF 56
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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.
`
`C. Obviousness Invalidity
`
`9.
`
`I understand that even if a prior art reference fails to anticipate a patent
`
`claim, the claim may nonetheless be invalid as “obvious,” if the differences between
`
`the subject matter claimed and the prior art are such that the subject matter as a whole
`
`would have been obvious at the time the invention was made to a POSITA. I
`
`understand that several factual inquiries underlie a determination of obviousness.
`
`These inquiries include the scope and content of the prior art, the level of ordinary
`
`skill in the art, the differences between the claimed invention and the prior art, and
`
`any objective “secondary considerations”, 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 understand that common sense
`
`and ordinary creativity of one skilled in the art can be relevant to obviousness.
`
`10.
`
`I have been informed that certain objective secondary considerations
`
`may be relevant to a determination of whether an invention was obvious. Such
`
`secondary considerations may include, e.g., (a) whether there was a long-felt and long-
`
`unmet need for the invention, (b) whether the invention achieved unexpected results,
`
`(c) the commercial success of the invention, and (d) whether the invention was copied
`
`or praised within the industry.
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`11. My opinions are set forth below.
`
`3
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`PAGE 5 OF 56
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`III. BACKGROUND AND EXPERIENCE
`12. My curriculum vitae, which includes a more detailed summary of my
`
`background, experience, and publications, is attached as Appendix A.
`
`13.
`
`In 1992, I received a Bachelor of Science degree in Applied Physics,
`
`including a Certificate in Optics from the Georgia Institute of Technology. I received
`
`my doctorate in Physics at Loughborough University in the United Kingdom in 1997,
`
`focusing on applied rigorous coupled wave diffraction theory to model and analyze
`
`recorded edge-lit holograms. My completed thesis was entitled: Modern Holographic
`
`Recording and Analysis Techniques Applied to Edge-Lit Holograms and their Applications.
`
`14.
`
`From 1993-1997, during the time of my PhD I worked as an Optical
`
`Engineer for ImEdge Technology Inc. where I conducted research for the company
`
`developing holographic illumination technology. During this time I also invented new
`
`methods directed to recording edge-lit holograms and edge-lit devices for display and
`
`biometric applications that led to being named an inventor on seven issued patents.
`
`15.
`
`From 1997 to 2002, I worked as a Senior Physicist for Motorola Labs. I
`
`helped design and construct the world’s first personal micro-projector (US Patent
`
`6,637,896). I also designed reflection and transmission micro-structured optical films
`
`for LCDs as well as 3 new optical film products with suppliers, including an optical
`
`film with 3M, which was shipped in over 100 million cellular phones. During my time
`
`at Motorola, I was also responsible for four issued patents and 26 patent disclosures.
`
`4
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`PAGE 6 OF 56
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`16.
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`From 2003-2005, I served as the President of Phostech, where my roles
`
`included the design and analysis of diffusing films, refractive-TIR films, projection
`
`screens & systems, LCD backlights, lightguides, signs, head-up displays and light
`
`fixtures. I also invented new optical films, projection screens, backlights and displays,
`
`including drafting eight patent applications.
`
`17.
`
`From 2005-2006, I was the Manager of Optical Engineering at Fusion
`
`Optix Inc. where I helped to develop and prototype micro-replicated, multi-functional
`
`optical films for displays and light fixtures through optical modeling prototyping,
`
`analysis, ,and specification. I also analyzed the optical properties of over 100
`
`polymers, and the effects of film extrusion; in addition to designing, installing, and
`
`managing the optical film, LED backlight, and light fixture characterization lab. I also
`
`led polymer based optical film research including production and optical
`
`characterization.
`
`18.
`
`From 2006-2009, I was the VP of Technology and Director of
`
`Technology at Fusion Optix Inc. In this role, I lead the research strategy and transfer
`
`of technology to product engineering in a fast paced small company providing
`
`innovation in the display and LED lighting industries. I also developed technology
`
`roadmaps, intellectual property strategy, and competitive benchmarking; inventing
`
`more than 35 unique, patentable products in addition to drafting and prosecuting over
`
`60 patent applications. I also oversaw the research and development of optical films,
`
`5
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`PAGE 7 OF 56
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`LED backlights, and LED light fixture projects. I also co-developed the optical
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`system of a Lightfair 2009 Innovation Award-winning light fixture.
`
`19.
`
`In 2009, I rejoined Phostech as President and am presently responsible
`
`for optical consulting and patent strategy and drafting services.
`
`20. Overall, my experience spans more than 25 years embracing relevant
`
`academia and interdisciplinary team innovation which culminated in bringing the
`
`absolute best products to the highly competitive lighting technology display market.
`
`As a result, I am able to pinpoint optimal design and technology directions based on
`
`complex customer needs and dynamic market factors in concert with overall business
`
`needs, marketing collaborates, and the broader product design and engineering
`
`groups. As noted above, I am a named inventor and/or applicant on a substantial
`
`number of patents and patent applications related to the areas of edge-lit holograms,
`
`edge-lit devices for display and biometric applications, optical film for LCD’s,
`
`personal micro-projector, projection screens, backlights and displays, LED backlights,
`
`and other light fixture devices. I am also a registered patent agent at the U.S. Patent
`
`and Trademark Office (Reg. No. 65,754). My curriculum vitae also include a more
`
`detailed summary of my background and experience.
`
`IV. MATERIALS REVIEWED
`21.
`In forming my opinions, I have relied on my general knowledge gained
`
`as a result of my education and experience in this field, as well as my review and
`
`6
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`PAGE 8 OF 56
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`consideration of the ’660 patent and the materials identified in Appendix B to this
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`declaration.
`
`V. OVERVIEW OF THE ’660 PATENT
`
`22. The ’660 patent describes light emitting panel assemblies. Ex. 1001, title.
`
`I agree with statements in the ’660 patent acknowledging that, when the application
`
`for the ’660 patent was filed, light emitting panel assemblies were generally known,
`
`and that the following functionality and structure of prior art light emitting panel
`
`assemblies were already known: a transparent light emitting panel 2 and one or more
`
`light sources 3 which emit light in a predetermined pattern and a light transition area 4
`
`used to make the transition from the light source 3 to the light emitting panel 2. Id. at
`
`2:24, 60-66, and Fig. 1. The ’660 patent depicts what it describes as a known panel in
`
`Figure 1, which is reproduced below. The ’660 disclosure explains that light is emitted
`
`along the entire length of the panel 2 or from one or more light output areas along the
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`length of the panel 2 as desired to produce a desired light output distribution to fit a
`
`particular application, such as e.g., a back light for an LCD. Id. at 2:66-67; 3:4-9; 8:57-
`
`63; Fig. 1.
`
`7
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`PAGE 9 OF 56
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`’660 Patent, Fig. 1
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`
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`23.
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`Seeking to improve on the control and utilization of light output from
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`admittedly known assemblies (illustrated in Figure 1 of the ’660 patent), the ’660
`
`patent discloses a light emitting panel assembly 32 (Fig. 6) including a panel member
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`33, one or more light sources 3, one or more light output areas 34, and a tray 35
`
`having a cavity or recess 36 in which the panel assembly 32 is received. Id. at 6:53-60,
`
`Fig. 6 (the only patent figure showing a tray).
`
`24. The specification discloses that each light source 3 may be of any
`
`suitable type including, for example, an arc lamp, an incandescent bulb, a lens end
`
`bulb, a line light, a halogen lamp, a light emitting diode (LED), a chip from an LED, a
`
`neon bulb, a florescent tube, a fiber optic light pipe, a laser or laser diode, or any
`
`other suitable light source. Id. at 4:12-25. According to the ’660 patent, “light
`
`sources 3 may be . . . a combination of multiple colored radiation sources.” Id. at 4:22-
`
`25. An example of such a multi-LED light source 3 is illustrated in Figure 7
`
`(reproduced below), in which a light emitting panel assembly 40 includes a panel
`
`8
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`PAGE 10 OF 56
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`member 41, four light transition areas 43, and four light sources 3 (each comprising
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`three separate LEDs). Id. at 7:4-15. Light from the LEDs is then mixed by the
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`transition region, which produce “a desired light output . . . that will be emitted from
`
`the light output area.” Id. at 7:11-15, Fig. 7. Thus, a “light source,” according to
`
`the ’660 patent, may comprise multiple components, e.g., multiple LEDs. The
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`specification also incorporates by reference several prior-art light sources as described
`
`in, inter alia U.S. Patent No. 5,005,108 (“Pristash,” Ex. 1003).
`
`The ’660 Patent, Fig. 7
`
`
`
`25. The ’660 patent also discloses a pattern of light extracting deformities 21,
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`23, 24, and/or 25 being provided on one or both sides of the panel member 14. Ex.
`
`1001 at 5:57-67 and Fig. 4. Figures 4a-4d below show light extracting deformities 21,
`
`23, 24, and 25:
`
`9
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`PAGE 11 OF 56
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`The ’660 Patent, Figs. 4a-4c
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`
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`26. The ’660 patent teaches that “[t]he deformities may also be printed on a
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`sheet or film which is used to apply the deformities to the panel member. This sheet
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`or film may become a permanent part of the light panel assembly for example by
`
`attaching or otherwise positioning the sheet or film against one or both sides of the
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`panel member similar to the sheet or film 27 shown in FIGS. 3 and 5 in order to
`
`produce a desired effect.” Id. at 4:55-61. “Moreover, the pattern of light extracting
`
`deformities 21 may be multiple layers or vary in index of refraction.” Id. at 5:31-32
`
`27. The ’660 patent discloses in another embodiment (Fig. 3, reproduced
`
`below), a light emitting panel assembly 11 including a light transition area 12 at one
`
`end of a light emitting panel 14 having reflective and/or refractive surfaces 15 around
`
`and behind two light sources 3. Id. at 3:46-57, Fig. 3. The ’660 patent discloses
`
`providing reflective materials or coatings on portions of the reflective and/or
`
`refractive surfaces 15 to focus a portion of light emitted from the light sources 3
`
`through the light transition areas 12 into one or more light input surface 19 of the
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`light emitting panel 14. Id. A back reflector 26 is attached or positioned against one
`
`10
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`PAGE 12 OF 56
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`face of the panel member 14 using a suitable adhesive 28. Id. at 6:17-30 and Figs. 3
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`and 5. A transparent film, sheet or plate 27 is attached or positioned against the face
`
`of the panel member 14 from which light is emitted using a suitable adhesive 28. Id.
`
`The ’660 Patent, Fig. 3
`
`
`
`Challenged Claims
`
`28. My analysis will focus on claims 1, 3, 10, 16-17, 25, 33, and 34 of the
`
`’660 Patent.
`
`A.
`
`29.
`
`Claim Construction
`“Deformities”
`I have been advised that the first step of assessing the validity of a patent
`
`claim is to interpret or construe the meaning of the claim.
`
`30.
`
`I have been advised that in inter partes review proceedings before the
`
`U.S. Patent and Trademark Office, claim terms of an expired patent are given their
`
`ordinary and accustomed meaning as understood by a POSITA.
`
`31. The specification of the ’660 patent expressly defines the term
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`“deformities,” as follows: “As used herein, the term deformities or disruptions are
`
`11
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`PAGE 13 OF 56
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`used interchangeably to mean any change in the shape or geometry of the panel
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`surface and/or coating or surface treatment that causes a portion of the light to be
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`emitted.” Id. at 4:45-49. I understand Toyota proposed that this term be construed to
`
`mean “any change in the shape or geometry of a surface and/or coating or surface
`
`treatment that causes a portion of the light to be emitted.” I agree that this is a
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`reasonable construction for this term.
`
`VI.
`
`PRIOR ART ANALYSIS
`
`32.
`
`I now turn to the references applied in the grounds for rejections
`
`discussed in Petition for inferpar/‘es review. In my analysis, I will specifically address
`
`the following references:
`
` 1005
`
`P H06—242731 “Mi/70”
`
`1006
`
`P H06—025802 (“Yo.r/7i.émm”)
`
`A.
`
`Claims 1, 3, 10, 16-17, 33, and 34 Are Unpatentable Under 35 U.S.C.
`§ 102(a) As Being Anticipated By Alina
`
`33. Mina discloses a backlight apparatus for applying light to an LCD surface
`
`or the like for illumination from behind. Ex. 1005 1] [0001]. The objective of Mina was
`
`to increase uniformity of brightness over the display surface without increasing the
`
`thickness of the backlight apparatus. In’. 1] [0003].
`
`Clairn 1
`
`34.
`
`Claim 1 of the ’66O Patent recites:
`
`1.
`
`A ligl1t emitting panel assembly comprising:
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`PAGE 14 OF 56
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`12
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`PAGE 14 OF 56
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`[a] a generally planar optical conductor having at least one
`input edge with a greater cross-sectional width than
`thickness; and
`[b] a plurality of light sources configured to generate light
`having an output distribution defined by a greater width
`component than height component, the
`light sources
`positioned adjacent to the input edge, thereby directing light
`into the optical conductor;
`[c]
`the optical conductor having at least one output region
`and a predetermined pattern of deformities configured to
`cause light to be emitted from the output region,
`[d]
`the optical conductor having a transition region
`disposed between the light source and the output region.
`35. Elements of independent claims 1 and 33 of the ’660 Patent are shown
`
`in the annotated figure below, composed of Fig. 21 of Mino labeled with claim
`
`elements:
`
`
`36. Mino discloses “a light emitting panel assembly” in the form of an
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`apparatus for backlighting a display surface such as an LCD. Mino discloses that “[t]he
`
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`1 Any citation to a figure in Ex. 1005 (the translation of Mino) refers to the figures
`
`found in the original Japanese document, located at Ex. 1006.
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`13
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`present invention relates to a backlight apparatus for applying light to a liquid crystal
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`display surface, a photo film/drawing see-through plate, etc. for illumination from
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`behind.” Ex. 1005 ¶ [0001]; see Figs. 1, 2.
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`37. As to claim element [1.a], Mino also discloses a light-guiding member 7
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`(optical conductor) which is generally planar and includes an input edge with a greater
`
`cross-sectional width than thickness as shown in Figs 1A, 1B, and 2:
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`
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`38. Mino explains: “Light projected into a light-guiding plate 7 from a light
`
`source 3 gets refracted and reflected repeatedly inside the light-guiding plate 7 by
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`impinging on an irregular surface or a reflection surface 8, or directly, and is finally
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`oriented by furrows 11 to pass through a light control plate 9 to exit toward the front
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`perpendicularly to the light control plate 9, with uniform brightness, for illumination
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`at the front side of the light control plate 9.” Ex. 1005 ¶ [0005]. In terms of
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`dimensions, Mino also states: “A light-guiding plate 7 (thickness: 1.5 mm), which is
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`made of a transparent acrylic plate and has a rectangular shape (60 mm x 20 mm) in
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`plan view, is fitted in the groove 2 of the light source holder 1.” Id. ¶ [0007].
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`14
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`39. As to claim element [1.b], Mino discloses a linear array of a plurality of
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`LED light sources 3 adjacent to the input edge, which even according to the Patent
`
`Owner’s admission, would generate light having an output distribution defined by a
`
`greater width than height component. Ex. 1005 Figs. 1-3; see also Ex. 1012, at 7 (Patent
`
`Owner: “Because the LEDs have a greater width than height, they are configured to
`
`generate light having an output distribution defined by a greater width component
`
`than height component”).
`
`40.
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`In particular, Fig. 3 of Mino, an enlarged perspective view that illustrates
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`the structure of a light source holder, shows an elongated groove 2 that holds
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`elongated, rectangular LED light sources 3:
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`
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`41. Mino states: “A light-guiding plate 7, which is made of an acrylic plate or
`
`the like, is mounted in/on a light source holder 1, on which a light source 3 made up
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`of plural light emission elements (LED), etc. as illustrated in Figs. 3 and 4 is fixed.”
`
`Ex. 1005 ¶ [0002].
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`15
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`PAGE 17 OF 56
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`42. Mino also explains that “A light source holder 1 (overall length: 60 mm)
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`is made of white polycarbonate, etc. and has a shape like a square bracket or turned U
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`in cross-sectional view. A recessed groove portion 2, which extends from one end to
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`the opposite end in the length direction of the light source holder 1, is formed in the
`
`light source holder 1. Plural light emission elements (light source) 3 such as LEDs are
`
`provided inside the groove 2.” Ex. 1005 ¶ [0006].
`
`43. A POSITA would have understood that the use of a linear array of
`
`rectangular LEDs having greater width than height and that have about the same
`
`thickness or height as the input edge provide a plurality of (LED) light sources
`
`arranged or configured to generate light having an output distribution defined by a
`
`greater width component than height component.
`
`44.
`
`Further, a POSITA would also have understood that the use of
`
`rectangular recessed groove 2, along with the reflective surface therein, discussed
`
`below, and the rectangular shape of the LEDs having a greater width than height, all
`
`serve to enhance the output light distribution of the light sources to have a greater
`
`width component than height component. Mino explains: “In order to solve the above
`
`problems, as a first feature of the present invention, a display surface backlighting
`
`apparatus comprises: a light source holder 1; a groove 2 that is formed as a recessed
`
`peripheral surface of the light source holder 1; a light source 3 that is mounted in the
`
`groove 2; a light-guiding member 7 that has transparency to light and has a shape like
`
`a plate, . . .” Ex. 1005 ¶ [0004].
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`16
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`PAGE 18 OF 56
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`45. Mino also explains: “For condensed orientation, toward the front, of
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`light emitted from the light source 3, preferably, the reflection surface 8 should be
`
`formed additionally at both sides next to each light emission element 3 inside the
`
`groove 2 in the same manner as above. If a white material is chosen for the light
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`source holder 1 as in the present embodiment, however, the inner surface of the
`
`groove 2 of the light source holder 1 itself serves as a reflection surface.” Ex. 1005
`
`¶ [0010].
`
`46.
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`Furthermore, a POSITA would have understood that the very shape of
`
`the rectangular LEDs of Mino—having a greater width than height—inherently and
`
`necessarily radiate light outward more in the width direction due to each LED’s
`
`greater width than height.
`
`47. As to claim element [1.c], the light-guiding member 7 (optical
`
`conductor) has at least one output region on its upper surface, and it also includes an
`
`array or furrows of convex/concave portions 11 having a serrated shape, which forms
`
`a predetermined pattern of deformities: “In order to solve the above problems, as a
`
`first feature of the present invention, a display surface backlighting apparatus
`
`comprises: . . . a light control plate 9 that is provided at a front-surface side of the
`
`light-guiding member 7 and is made of a film or a plate-like material serving as a light
`
`emission surface, wherein an irregular surface is formed at back of the light control
`
`plate 9. A second feature is that the irregular surface is an array 11 of convex portions
`
`and concave portions, which constitute a serrated shape in cross-sectional view. A
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`17
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`PAGE 19 OF 56
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`
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`third feature is that an inner surface of the groove 2 is formed as a reflection surface.”
`
`Ex. 1005 ¶ [0004].
`
`48. Mino discloses that: “Light projected into a light-guiding plate 7 from a
`
`light source 3 gets refracted and reflected repeatedly inside the light-guiding plate 7 by
`
`impinging on an irregular surface or a reflection surface 8, or directly, and is finally
`
`oriented by furrows 11 to pass through a light control plate 9 to exit toward the front
`
`perpendicularly to the light control plate 9, with uniform brightness, for illumination
`
`at the front side of the light control plate 9.” Ex. 1005 ¶ [0005].
`
`49. Mino also states: “The light control plate 9 has an alternate array 11 of
`
`ridge/convex portions and valley/concave portions, at its back. The furrows 11
`
`constitute a serrated shape in cross-sectional view. The furrows 11 have a depth of
`
`0.05 to 0.1 mm and an array pitch of 0.1 to 0.2 mm. The sectional shape of each ridge
`
`and each valley is an isosceles triangle having a vertex angle of 90°. The furrows 11
`
`extend in parallel to the length-directional side edges.” Ex. 1005 ¶ [0008].
`
`50. As to claim element [1.d], a POSITA would have understood that the
`
`light-guiding member 7 (optical conductor), which is made of light transparent acrylic
`
`or the like, includes a transition region (shown in light green) disposed between the
`
`light source and the output region:
`
`18
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`PAGE 20 OF 56
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`
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`51. A POSITA would have understood that this transition region is an area
`
`between the LED light sources 3 and optical conductor 7 used to make the transition
`
`from the light sources to the light emitting panel, and includes an area of the optical
`
`conductor between the light sources 3 and the edge of the deformities on the light
`
`emitting panel 7. Ex. 1005 Fig. 2; see also Figs. 5A-C:
`
`
`52. Mino explains: “a groove 2 . . . is formed as a recessed peripheral surface
`
`of the light source holder 1,” that “light source 3 that is mounted in the groove 2,” a
`
`reflection surface 8 is “formed at back of the light-guiding member 7,” “an end of the
`
`19
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`PAGE 21 OF 56
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`
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`
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`light-guiding member 7 being fixed inside the groove 2,” and that “an inner surface of
`
`the groove 2 is formed as a reflection surface.” Ex. 1005 ¶ [0004]. Also, “For
`
`condensed orientation, toward the front, of light emitted from the light source 3,
`
`preferably, the reflection surface 8 should be formed additionally at both sides next to
`
`each light emission element 3 inside the groove 2 in the same manner as above. If a
`
`white material is chosen for the light source holder 1 as in the present embodiment,
`
`however, the inner surface of the groove 2 of the light source holder 1 itself serves as
`
`a reflection surface.” Id. ¶ [0010].
`
`53. Accordingly, Mino discloses the combination of features in claim 1 of the
`
`’660 Patent.
`
`Claim 3
`
`54. Claim 3 of the ’660 Patent recites:
`
`The assembly of claim 1 wherein the transition
`3.
`region is integral with the optical conductor.
`
`55.
`
`In Mino, the transition region is integral with light-guiding plate 7. This
`
`can be seen in Fig 2:
`
`
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`20
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`PAGE 22 OF 56
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`
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`56. Mino explains that Fig. 2 is preferable to Figs. 5A-5C: “We conducted an
`
`experiment on backlighting effects by using structures illustrated in Figs. 5(A), 5(B),
`
`and 5(C) … and found that the performance of the structure of the embodiment
`
`illustrated in Fig. 2 is superior to the performance of all of the structures illustrated in
`
`Figs. 5(A), 5(B), and 5(C) both in terms of brightness level and in terms of uniformity.
`
`This is probably because, firstly, it is possible to project light farther into the light-
`
`guiding plate 7 if the projection is from inside a narrow groove 2 at an end of the
`
`light-guiding plate 7, and, secondly, the inner walls of the groove 2 produces reflection
`
`effects.” Ex. 1005 ¶ [0011].
`
`57. Accordingly, Mino discloses the additional features of claim 3 of the ’660
`
`Patent.
`
`Claim 10
`
`58. Claim 10 of the ’660 Patent recites:
`
`10. The assembly of claim 1 wherein the transition
`region and the output region of the optical conductor have
`substantially the same thickness.
`
`59.
`
`Fig. 2 shows that the output region of the optical conductor have
`
`“substantially” the same thickness:
`
`21
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`PAGE 23 OF 56
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`
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`60. However, if the thicknesses shown in Fig. 2 are asserted by the patent
`
`owner to not be substantially the same, then Figs. 5A and 5C show identical
`
`thicknesses of a transition region and an output region of an optical conductor:
`
`
`
`61. Accordingly, Mino discloses additional features of claim 10 of the ’660
`
`Patent. It would be obvious for a POSITA to use a lightguide with the same thickness
`
`at the input edge as the rest of the lightguide in order to efficiently collect light from a
`
`
`
`larger LED to increase the brightness.
`
`Claim 16
`
`62. Claim 16 of the ’660 Patent recites:
`
`16. The assembly of claim 1 wherein the light sources
`are focused light sources.
`
`22
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`PAGE 24 OF 56
`
`
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`
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`63. The light sources of Mino are LEDs, which a POSITA would have
`
`understood are focused light sources based on their rectangular shape having a greater
`
`width than height, as shown in Fig. 3 and the fact that recessed groove 2 also focuses
`
`the light, as noted above in ¶¶ 39-46. See Ex. 1005 ¶¶ [0002], [0004], [0006], [0010],
`
`[0011], [Construction], Figs. 1-3.
`
`64. Accordingly, Mino discloses the additional features of claim 16 of the
`
`’660 Patent.
`
`Claim 17
`
`65. Claim 17 of the ’660 Patent recites:
`
`17. The assembly of claim 16 wherein the focused light
`sources are LEDs.
`66. As noted above with respect to claim 16 in ¶¶ 63-64, a POSITA would
`
`have recognized that the light sources in Mino are focused light sources.
`
`67. Mino discloses that the focused light sources are LEDs: “A light-guiding
`
`plate 7, which is made of an acrylic plate or the like, is mounted in/on a light source
`
`holder 1, on which a light source 3 made up of plural light emission elements (LED),
`
`etc. as illustrated in Figs. 3 and 4 is fixed.” Ex. 1005 ¶ [0002]. Also, “Plural light
`
`emission elements (light source) 3 such as LEDs are provided inside the groove 2.
`
`Each of the light emission elements 3 is connected to an electric wire 6, which is
`
`inserted in and through a hollow guide member 4. The hollow guide member 4 is
`
`23
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`PAGE 25 OF 56
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`
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`
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`attached to the outer side face of the light source holder 1.” Id. ¶ [0006]. This is also
`
`shown in the figures, and especially Fig. 3:
`
`
`68. Accordingly, Mino discloses the additional features of claim 17 of the
`
`’660 Patent.
`
`Claim 33
`
`69. Claim 33 of the ’660 Patent recites:
`
`33. A light emitting panel assembly comprising:
`[a]
`a generally planar optical conductor having at least one
`input edge with a greater cross-sectional width than
`thickness; and
`[b] a plurality of LED light sources each having a greater
`width than height positioned adjacent to the input edge,
`thereby directing light into the optical conductor, each light
`source be
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