UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MERCEDES-BENZ USA, LLC,
`Petitioners
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner
`
`Patent No. 7,434,974
`
`Issue Date: October 14, 2008
`
`Title: LIGHT EMITTING PANEL ASSEMBLIES
`
`DECLARATION OF THOMAS L. CREDELLE
`Case No. IPR2015-01115
`
`Mercedes-Benz USA, LLC, Petitioner - EX. 1004
`
`Page 1 of 61
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`

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`I.
`
`INTRODUCTION ...............................................................................................................1
`
`A.
`
`B.
`
`Summary of Opinions..............................................................................................1
`
`Background & Qualifications ..................................................................................2
`
`II.
`
`THE ’974 PATENT .............................................................................................................5
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`Overview of LCD Backlighting Principles..............................................................5
`
`Overview of the ’974 Patent ....................................................................................8
`
`Level of Ordinary Skill in the Art............................................................................9
`
`Challenged Claims.................................................................................................10
`
`Claim Construction................................................................................................11
`
`III.
`
`ANALYSIS AND OPINION ON ISSUES OF INVALIDITY .........................................12
`
`A.
`
`B.
`
`Summary................................................................................................................12
`
`Ground 1: Anticipation by Niizuma ......................................................................13
`
`1.
`
`2.
`
`3.
`
`4.
`
`Niizuma anticipates claim 7.......................................................................13
`
`Niizuma anticipates claim 8.......................................................................21
`
`Niizuma anticipates claim 9.......................................................................22
`
`Niizuma anticipates claim 13.....................................................................23
`
`C.
`
`Ground 2: Obviousness in view of Niizuma..........................................................26
`
`1.
`
`2.
`
`3.
`
`4.
`
`Claim 1 is obvious in view Niizuma..........................................................26
`
`Claim 3 is obvious in view Niizuma..........................................................29
`
`Claim 4 is obvious in view Niizuma..........................................................30
`
`Claim 5 is obvious in view Niizuma..........................................................31
`
`D.
`
`Ground 3: Claims 7, 8, and 9 are Anticipated by Kisou........................................31
`
`1.
`
`2.
`
`3.
`
`Kisou anticipates claim 7...........................................................................32
`
`Kisou anticipates claim 8...........................................................................40
`
`Kisou anticipates claim 9...........................................................................40
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`E.
`
`Ground 4: Obviousness in view of Kisou..............................................................41
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Claim 1 is obvious in view Kisou..............................................................41
`
`Claim 3 is obvious in view of Kisou..........................................................43
`
`Claim 4 is obvious in view of Kisou..........................................................44
`
`Claim 5 is obvious in view of Kisou..........................................................44
`
`Claim 13 is obvious in view of Kisou........................................................45
`
`IV.
`
`CONCLUSION..................................................................................................................47
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`Page 3 of 61
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`I, Tom Credelle, hereby state and declare that:
`
`I.
`
`INTRODUCTION
`A.
`Summary of Opinions
`1.
`Mercedes-Benz USA, LLC (MBUSA) has engaged me in this matter to
`
`review U.S. Patent No. 7,434,974 (the ’974 patent) (Ex. 1001) and to provide my
`
`opinion on whether certain claims of the ’974 patent are anticipated or rendered
`
`obvious by one or more of the following prior art references:
`
`
`
`
`
`Japanese Published Patent Application No. JP H5-45651(U) to
`Niizuma (“Niizuma”)(Ex. 1002);
`
`Japanese Unexamined Patent Application No. JP H7-064078A to
`Kisou et al. (“Kisou”)(Ex. 1003);
`
`2.
`
`As is explained in detail below, it is my opinion that:
`
`
`
`
`
`
`
`
`
`Claims 7, 8, 9, and 13 are anticipated under 35 U.S.C. § 102(b) by
`Niizuma (“Ground 1”);
`
`Claims 1, 3, 4, and 5 are obvious under 35 U.S.C. § 103 over
`Niizuma (“Ground 2”);
`
`Claims 7, 8, and 9 are anticipated under 35 U.S.C. § 102(a) by
`Kisou (“Ground 3”);
`
`Claims 1, 3, 4, 5, and 13 are obvious under 35 U.S.C. § 103 over
`Kisou (“Ground 4”).
`
`3.
`
`My opinions and underlying reasoning for those opinions are set forth
`
`below.
`
`Page 4 of 61
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`B.
`4.
`
`Background & Qualifications
`I have more than 40 years of industry experience in research and
`
`development in the areas of Liquid Crystal Display (LCD) technology and in other flat
`
`panel displays. My full curriculum vitae is attached hereto as Appendix A.
`
`5.
`
`I received my M.S. degree in Electrical Engineering from the
`
`Massachusetts Institute of Technology in 1970, with an emphasis on Electro-optics
`
`and Solid State Materials. I received my B.S. degree in Electrical Engineering in
`
`1969 from Drexel University.
`
`6.
`
`I was employed by RCA at Sarnoff Labs in Princeton, NJ from
`
`1970 through 1986 at first as a Member of the technical Staff and later as a Group
`
`Manager in charge of all Active Matrix LCD research. During my time at RCA, I
`
`participated in research and development projects relating to optical materials and flat
`
`panel displays, including LCD devices. In 1983, I established the Thin-Film
`
`Transistor (TFT) LCD Program at Sarnoff Labs. As a Group Manager, I led a project
`
`that resulted in the development of the first poly-Silicon TFT LCD at Sarnoff Labs. I
`
`received the Sarnoff Outstanding Achievement Award for Large-Area Flat Panel TV
`
`Developments.
`
`7.
`
`From 1986 to 1991, I was employed by GE as the Manager of TFT LCD
`
`Research and Development at the GE Research and Development Center in
`
`Schenectady, NY. My duties included managing research and development efforts
`
`relating to TFT and LCD technology for avionics applications. While employed by
`
`Page 5 of 61
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`GE, I led the team that built the world’s first 1 million pixel color LCD device. I also
`
`led development of numerous other display devices utilizing LCD technology. A key
`
`part of this effort was the development of high-brightness backlighting systems for
`
`outdoor applications. We succeeded in engineering full sunlight-readable displays.
`
`8.
`
`From 1991 to 1994, I was employed by Apple Computer as the Manager
`
`of Display Engineering. In my role at Apple, I supervised all LCD design,
`
`engineering, and qualification for the first Powerbook notebook computers
`
`introduced to market in the United States. A key part of my effort was the
`
`development of low-power backlighting systems for use in notebook computers.
`
`These designs involved edge lighting systems with various focusing structures and
`
`light extraction patterns to improve uniformity.
`
`9.
`
`From 1994 to 1996, I was employed as the Director of Advanced
`
`Product Marketing by Allied Signal, where I was involved with the design and
`
`engineering of optical films and custom focusing backlight designs for improving the
`
`viewing angle performance of LCD devices.
`
`10. From 1996 to 1999, I was employed as the Director of Product
`
`Marketing for Motorola’s Flat Panel Display Division, where I worked in the
`
`development of new flat panel technology, and I also worked closely with Motorola
`
`groups responsible for integrating LCD technology into mobile phone products.
`
`These designs exclusively used LED light sources.
`
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`11. From 1999 to 2001, I served as the Vice President of Operations of Alien
`
`Technology Corporation. During my time at Alien Technology, I was involved with
`
`the design and architecture of drive-electronics packaging technology suitable for
`
`flexible LCD devices.
`
`12. From 2001 to 2007, I served as the Vice President of Engineering for
`
`Clairvoyante, Inc. My responsibilities as the VP of Engineering included managing
`
`research, development, engineering, and marketing of technologies for improving the
`
`resolution and power consumption of color flat panel displays. During my time at
`
`Clairvoyante, I was heavily involved with the design of LCD driving circuitry and
`
`image processing circuitry, including image processing algorithms. LED backlights
`
`were adapted for use with the new technology developed by Clairvoyante. My work
`
`resulted in the issuance of multiple patents relating to display technology.
`
`13. From 2007 to 2008, I served as the Senior VP of Engineering for
`
`Puredepth, Inc. My responsibilities included the design of hardware and software to
`
`create 3D images on LCDs.
`
`14. From 2012 through 2015, I served as the Vice President of Application
`
`Engineering and Device Performance for Innova Dynamics, Inc., a nanotechnology
`
`company developing materials to be used in LCDs and touch sensors. In 2008, I
`
`founded TLC Display Consulting, a company that provides technical consulting in the
`
`areas of flat panel displays, liquid crystal displays, and related electronics. I currently
`
`serve as the President of TLC Display Consulting.
`
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`15.
`
`I have been a member of the Society for Information Display for over
`
`40 years. I was a member of the Society for Information Display’s Program
`
`Committee for 15 years, and the Director of the Society for Information Display’s
`
`Symposium Committee for 10 years. In 1984, I was awarded the title of Society for
`
`Information Display Fellow in recognition of my achievements and contributions to
`
`flat panel display technology.
`
`16.
`
`I am a named inventor on over 70 patents relating to flat panel display
`
`and LCD technology. I have also authored a number of articles relating to LCD
`
`technology and flat panel displays that were published by industry periodicals such as
`
`Information Display and peer-reviewed journals such as the Society for Information
`
`Display’s Digest of Technical Papers.
`
`17.
`
`I am compensated at the rate of $350/hour for my work, plus
`
`reimbursement for expenses. My compensation has not influenced any of my
`
`opinions in this matter and does not depend on the outcome of this proceeding or
`
`any issue in it.
`
`II.
`
`THE ’974 PATENT
`A.
`Overview of LCD Backlighting Principles
`18. By the time of the patent application to which the ‘974 patent claims
`
`priority (June 1995), liquid crystal display (“LCD”) technology had progressed to
`
`commercial status and was used in products ranging from mobile phones and pagers
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`to notebook computers and PC monitors. Small TVs based on LCD technology were
`
`also appearing in the market.
`
`19. An LCD is not a light emitting device, in contrast to plasma displays or
`
`CRTs used in many products. To create an image, the transmission of light through
`
`each picture element, or pixel, of the display is adjusted through an applied voltage to
`
`the LCD. In order to see an image, there are two modes of operation: reflective and
`
`transmissive. The majority of devices used in products are of the transmissive type
`
`and a source of light is needed to see an image. The backlight assembly of the subject
`
`patent is an example of a backlight that can be used in various products.
`
`20. The two types of backlights in use in the 1995 time frame are shown in
`
`the figure above. The upper portion of the diagram shows a “direct-lit” backlight and
`
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`the lower diagram shows an “edge-lit” backlight. The ‘974 patent describes various
`
`edge-lit assemblies. In the above illustration, the light sources are LEDs, which is
`
`common today. In the 1995 time frame, cold cathode fluorescent lamps (CCFL) were
`
`also commonly used in either type of backlight unit. To achieve a small overall
`
`thickness, thin CCFL lamps or small LED packages were typically used. Depending
`
`on the brightness requirements, two lamp assemblies were often used for edge-lit
`
`backlight assemblies, one on either end of the light guide panel.
`
`21. Prior to 1995, it was well-known that edge-lit backlight assemblies
`
`generally have three key parts: (1) the light source, (2) the light guide panel, and
`
`(3) the extraction means so that the light in the light guide can exit towards the LCD
`
`with appropriate uniformity and directionality. The light source was typically the
`
`same size as one edge of the light guide. To improve efficiency of the backlight
`
`assembly, reflectors were typically added behind the light source, especially for CCFL
`
`lamps. The light guide panel always included an area or region in which light from the
`
`source could better “homogenize” before being extracted by the extraction means.
`
`The extraction means were typically protrusions or depressions or painted scattering
`
`dots with variable density so as to extract light uniformly over the area of the light
`
`guide panel. Reflectors were usually added below the light guide panel and along the
`
`edges to improve efficiency.
`
`22. A typical extraction pattern for an edge-lit backlight assembly is shown
`
`below. The referenced prior art patents in this Declaration show other examples. In
`
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`this top view illustration, light from a light source enters the light guide panel and is
`
`extracted less (lower density of dots) near the light source where the light intensity is
`
`higher and is extracted more (higher density of dots) away from the light source where
`
`the light intensity is lower.
`
`B.
`23.
`
`Overview of the ’974 Patent
`The ’974 patent is entitled “Light emitting panel assemblies.” Jeffery R.
`
`Parker is the single named inventor of the ’974 patent. The patent issued on
`
`October 14, 2008. The patent was filed on March 17, 2006, but claims priority to a
`
`series of related applications that each originate from application No. 08/495,176,
`
`filed on June 27, 1995, now U.S. Patent No. 5,613,751.
`
`24.
`
`The ’974 patent discloses a light emitting assembly that is received in a
`
`cavity or recess of a tray or housing. The panel includes a pattern of light extracting
`
`deformities on at least one of its surfaces that cause the light received from at least
`
`one LED light source to be emitted from the panel assembly. The tray or housing in
`
`which the panel member is received acts as end edge and/or side edge reflectors to
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`reflect light back into the panel that would otherwise exit the panel. (Ex. 1001,
`
`Abstract)
`
`25.
`
`The tray or housing in which the light emitting panel is entirely received
`
`additionally provides structural support and has posts, tabs, or other structural
`
`features that provide a mount for mounting the light emitting panel assembly into a
`
`larger assembly or device. (Ex. 1001, claim 1.)
`
`26. The light emitting panel assembly is designed to generate and direct rays
`
`of light in a manner to best illuminate a display, e.g., a liquid crystal display (“LCD”).
`
`Typical design considerations include producing light with sufficient uniformity and
`
`brightness, while minimizing the assembly’s profile thickness and electrical power
`
`consumption.
`
`27. The light emitting panel assembly contains reflective or refractive
`
`surfaces for changing the path of a portion of the light emitted from the light source.
`
`The light is reflected and refracted by various internal features that spatially
`
`homogenize and control the angular distribution of the reflected/refracted light.
`
`Level of Ordinary Skill in the Art
`C.
`28. MBUSA has requested that I opine on the education and/or
`
`professional experience levels necessary for a person to be considered one of ordinary
`
`skill in the art with respect to the technology disclosed in the ’974 patent. To that
`
`end, MBUSA’s counsel has advised me that I should consider: (i) the education of the
`
`inventors at the time of the filing; (ii) the character of the problems confronted in the
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`prior art; (iii) the previous solutions to those problems; (iv) the rate of technological
`
`advancement in the art; (v) the complexity of the invention; and (vi) the typical
`
`education level of workers in the field.
`
`29.
`
`As noted above, the ’974 patent claims priority to an earlier patent
`
`application filed by Parker and others on June 27, 1995. I have thus considered, the
`
`’974 patent and the prior art references from the perspective one of ordinary skill in
`
`the art considering those same references in June 1995 would have possessed.
`
`30.
`
`A person of skill in the art with respect to the ’974 patent would have
`
`held at least a Bachelor’s degree in electrical engineering, physics, optics, or a related
`
`field as well as approximately three or more years of experience in the field of light
`
`panel design and assembly, or a related field. Additional graduate degrees may
`
`substitute for experience in the field, while additional experience in the field could
`
`substitute for formal education.
`
`31.
`
`The professional and educational qualifications I have detailed above
`
`demonstrate that I am a person of at least ordinary skill in the art with respect to the
`
`’974 patent.
`
`D.
`32.
`
`Challenged Claims
`The ’974 patent has 24 claims, of which four claims are independent.
`
`Counsel for MBUSA has informed me that this petition for inter partes review
`
`concerns claims: 1, 3, 4, 5, 7, 8, 9 and 13 (collectively, the “Challenged Claims”). For
`
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`convenience, I have reproduced claim 7, which is emblematic of the features disclosed
`
`by each of the claims, below:
`
`7[c]
`
`7[f]
`
`7[a] A light emitting panel assembly comprising at least:
`7[b] a light emitting panel member having a light entrance surface and
`a light emitting surface,
`at least one LED light source positioned near or against the light
`entrance surface, and
`7[d] a tray or housing having a cavity or recess in which the panel
`member is entirely received,
`7[e] wherein the panel member has a pattern of light extracting
`deformities on or in at least one surface to cause light to be
`emitted from the light emitting surface of the panel member, and
`the tray or housing includes end walls and side walls that act as
`end edge reflectors and side edge reflectors for the panel member
`to reflect light that would otherwise exit the panel member
`through an end edge and/or side edge back into the panel
`member and toward the pattern of light extracting deformities for
`causing additional light to be emitted from the light emitting
`surface of the panel member,
`7[g] wherein the tray or housing has posts, tabs or other structural
`features that provide a mount or structural support for at least
`one other part or component, and
`the tray or housing provides structural support to the panel
`member.
`Claim Construction
`E.
`33. MBUSA’s counsel has notified me that, in evaluating whether elements
`
`7[h]
`
`of the above claims are anticipated or obvious based on prior art, I should construe
`
`the claim terms to have their plain and ordinary meaning. I have also been informed
`
`that the words of each claim should be given their plain meaning unless the plain
`
`meaning is inconsistent with the ‘974 patent’s specification.
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`34.
`
`Independent claims 1, 7, and 13 each contain the term “deformities.”
`
`Claims 3, 4, and 5, each of which depend from claim 1, and claims 8 and 9, each of
`
`which depend from claim 7, all incorporate this phrase by reference. The
`
`specification of the ‘974 patent defines “deformities” as a “change in the shape or
`
`geometry of the panel surface and/or coating or surface treatment that causes a
`
`portion of the light to be emitted.” (Ex. 1001 at 4:36-40). This is the definition I shall
`
`apply when analyzing this element.
`
`III. ANALYSIS AND OPINION ON ISSUES OF INVALIDITY
`A.
`Summary
`35.
`In my opinion, claims 1, 3, 4, 5, 7, 8, 9 and 13 of the ’974 patent are
`
`either anticipated or obvious in light of prior art.
`
`36.
`
`I understand that a patent claim is anticipated under 35 U.S.C. § 102
`
`when a single piece of prior art describes every element of the claimed invention,
`
`either expressly or inherently, arranged in the same way as in the claim.
`
`37.
`
`I understand that a patent claim is obvious under 35 U.S.C. § 103 if the
`
`subject matter of the claim as a whole would have been obvious to a person of
`
`ordinary skill in the art as of the date of the invention. I understand that, unlike
`
`anticipation, obviousness may be shown by considering more than one prior art
`
`reference in combination. I have been informed that objective indicia of non-
`
`obviousness, sometimes referred to as “secondary considerations,” should be
`
`considered when assessing obviousness, including: (1) commercial success; (2) long
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`felt but unresolved needs; (3) copying of the invention by others in the field; (4) initial
`
`expressions of disbelief by experts in the field; (5) failure of others to solve the
`
`problem that the inventor solved; and (6) unexpected results.
`
`B.
`38.
`
`Ground 1: Anticipation by Niizuma
`In my opinion, Niizuma anticipates claims 7, 8, 9 and 13 of the ’974
`
`patent.
`
`39. Niizuma, a published Japanese Patent Application JP H5-45651(U) is
`
`entitled “Liquid Crystal Display Device.” Niizuma was published on June 18, 1993.
`
`Niizuma names Fumiyasu Niizuma as it sole inventor.
`
`40. Niizuma discloses a means for producing a light emitting display
`
`assembly that is capable of providing sufficient illumination to serve as the backlight
`
`to a LCD assembly. (Ex. 1002 ¶ 5.) Niizuma further discloses an assembly that is
`
`comprised of multiple light sources in order to provide greater luminosity and better
`
`spatial homogenization of light across a larger LCD surface area.
`
`1. Niizuma anticipates claim 7
`
`41.
`
`In my opinion, the teachings of Niizuma disclose each and every
`
`element of claim 7 of the ’974 patent and thus claim 7 of the ’974 patent is anticipated
`
`under 35 U.S.C. § 102.
`
`42.
`
`The preamble of claim 7 requires a “light emitting panel assembly.” In
`
`anticipation of this element, Niizuma discloses a liquid crystal display device in Fig. 1
`
`(below) (Ex. 1002 ¶ 1). Niizuma notes that this liquid crystal display device is used
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`“in all types of electronic equipment, and is particularly related to the illumination
`
`structure with liquid crystal display devices.” (Ex. 1002 ¶ 1.)
`
`43.
`
`The second element of claim 7 requires the assembly include “a light
`
`emitting panel member having a light entrance surface and a light emitting surface.”
`
`Fig. 1 of Niizuma (reproduced above) discloses this element by depicting a light
`
`conductor (4). Light from the light source enters and “is guided into the light
`
`conductor (4) from the grooves (4a, 4a) at both ends of the light conductor (4)” and is
`
`“reflected out towards the LCD (1)” from the top surface of light conductor (4). (Ex.
`
`1002 ¶ 19.) Grooves (4a, 4a) are light entrance edges and the top surface of the light
`
`conductor (4) represents a light emitting surface. These features are all depicted in
`
`Fig. 3 below.
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`44.
`
`The third element of claim 7 requires “at least one LED light source
`
`positioned near or against the light entrance surface.” In anticipation of this element,
`
`Figs. 1 and 3 of Niizuma (above) disclose “multiple lamps (6, 6) … comprising of, for
`
`example, LEDs” that are positioned near light guide 4 against grooves (4a, 4a). These
`
`LED light sources “are fixed in position so that the clearance interval between them is
`
`equal to that between the grooves (5b, 5b, …) on the holder (5) and the grooves (4a,
`
`4a, …) on the light conductor (4).” (Ex. 1002 ¶ 14.)
`
`45.
`
`Element four of claim 7 requires “a tray or housing having a cavity or
`
`recess in which the panel member is entirely received.” The housing described in
`
`Niizuma, comprising “frame 8” and “holder 5,” has a “recess (locking part) (5a)” in
`
`which “light conductor (4) is fixed in place by being inserted and locked into this
`
`recess (5a)” that satisfies this element of claim 7. (Ex. 1002 ¶¶ 12, 15, and 18, Figs. 1,
`
`3.) The highlighted version of Fig. 1 below illustrates this feature: light conductor (4),
`
`diffusing film (3), color filter (2), and LCD (1), highlighted in blue, are entirely
`
`received by frame (8) and holder (5), highlighted in yellow. Niizuma describes that
`
`the frame (8) is “fitted to the outer perimeter of the holder (5)” and thus they
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`encapsulate light conductor (4), diffusing film (3), color filter (2), and LCD (1). (Ex.
`
`1002 ¶ 18.)
`
`46.
`
`Collectively, holder (5) and frame (8) receive and protect light conductor
`
`(4), diffusing film (3), color filter (2), and LCD (1): “once the frame (8) is attached, it
`
`is fine to push the front of the LCD (1) against the inside of front of the frame (8) so
`
`that the holder (5) and the LCD (1) etc. do not rattle.” (Ex. 1002 ¶ 18.) As further
`
`shown in highlighted Fig. 3 below, the housing, highlighted in yellow, forms a cavity
`
`in which the panel member, highlighted in green, is entirely received:
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`47.
`
`Element five of claim 7 requires the light emitting panel have “a pattern
`
`of light extracting deformities on or in at least one surface to cause light to be emitted
`
`from the light emitting surface of the panel member.” Niizuma discloses that “finely
`
`serrated or ridged grooves cover the entirety of the back surface (4c) of the light
`
`conductor (4)” that cause light that enters light conductor (4) to “reflect[] out towards
`
`the LCD (1)” and thus anticipates this element. (Ex. 1002 ¶¶ 11, 19, Fig. 3.) The
`
`finely serrated or ridged grooves constitute changes in the shape or geometry of light
`
`conductor (4)’s surface that causes a portion of the light to be emitted from light
`
`conductor (4).
`
`48.
`
`The sixth element of claim 7 requires that “the tray or housing includes
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`end walls and side walls that act as end edge reflectors and side edge reflectors for the
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`panel member to reflect light that would otherwise exit the panel member through an
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`end edge and/or side edge back into the panel member and toward the pattern of
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`light extracting deformities for causing additional light to be emitted from the light
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`emitting surface of the panel member.” In anticipation of this element, Niizuma
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`discloses that the walls of holder (5) are “formed from a white compound resin”
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`which enables holder (5) “to reflect light leaked from the light conductor (4) to the
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`holder (5) back into the light conductor (4), making it possible to reduce the
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`attenuation of light emitted from the lamps (6, 6, …) and to efficiently illuminate the
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`LCD (1).” (Ex. 1002 ¶20.) The end walls and side walls described serve as end edge
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`reflectors and side edge reflectors and thus reflect light back into the panel assembly
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`to mitigate light loss and improve light efficiency. The re-directed light travels back
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`towards the panel member towards the finely serrated or ridged grooves, which causes
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`the light to be emitted from the top surface of light conductor (4).
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`49.
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`Element seven of claim 7 states that “the tray or housing has posts, tabs
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`or other structural features that provide a mount or structural support for at least one
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`other part or component.” Niizuma also anticipates this element of claim 7. Niizuma
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`discloses a housing comprising frame (8) and holder (5) that is mounted to “printed
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`circuit board (7) by the insertion of its latching pieces (8b, 8b, …) through the
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`latching holes (7b, 7b, …) on the printed circuit board (7) and the bending of its
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`latching pieces (8b, 8b, …) at the back of the printed circuit board (7).” (Ex. 1002 ¶
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`18.) The highlighted reproduction of Figure 1 below (where frame 8 and holder 5 are
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`highlighted in yellow and printed circuit board 7 is highlighted in purple), depicts
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`“multiple latching pieces (8b, 8b, …) that fit into the latching holes (7b, 7b, …) on the
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`printed circuit board (7) described above, protrude from the perimeter of the back of
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`the frame (8).”
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`50.
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` These latching piece (8b, 8b, …) constitute posts, tabs, or other
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`structural features that provide a mount for mounting the housing, comprising frame
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`8 and holder 5, and its encapsulated components to printed circuit board 7.
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`51.
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`The highlighted reproduction of Figure 3 below (where frame (8) and
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`holder (5) are highlighted in yellow, light conductor (4) is highlighted in green, and
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`LCD (1) is highlighted in brown), provides that “both end parts of the LCD (1) are
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`locked by the extruding pieces (5f, 5f, …) of the holder (5), as shown in Figure 3, and
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`its movement in the direction of both ends (to the left and right of the diagram) is
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`controlled.” (Ex. 1002 ¶ 17.) The extruding pieces (locking parts) (5f) cause the
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`LCD (1), as well as light conductor (4), to be securely held in holder (5). Extruding
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`pieces (locking parts) (5f) are posts, tabs, or other structural features that provide a
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`mount or structural support for at least one other component, LCD (1).
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`52.
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`The eighth and final element of claim 7 requires that “the tray or
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`housing provides structural support to the panel member.” Niizuma anticipates this
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`element of the claim as well. Niizuma states that holder (5) is shaped to hold and lock
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`light conductor (4) and LCD (1) in place:
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`Furthermore, on the rear face 5b of holder 5 are formed a pair of
`inclined portions 5e, 5e that are bent towards the interior of holder 5
`and have a radius of curvature identical to that of the pair of inclined
`faces 4d, 4d of light guide 4, so that when light guide 4 is fitted into
`recess 5a of holder 5, the rear face 4c of light guide 4 and the rear face
`5b of holder 5 become flush overall.
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`53.
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`(Ex. 1002 ¶ 13.) In the highlighted version of Fig. 3 above (where
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`frame (8) and holder (5) are highlighted in yellow and light conductor (4) is
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`highlighted in green), holder (5) provides a pair of sloped structures (5e, 5e), that
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`support light conductor (4). The curvature angle of these sloped parts (5e, 5e) is the
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`same as the curvature angle of sloped surfaces (4d, 4d) of light conductor (4), which
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`enables holder (5) to support light guide (4) directly without any intermediary
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`structure. (Id.)
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`54.
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`The highlighted reproduction of Figure 3 above also shows extruding
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`pieces (locking parts) (5f) which are in place to provide structural support to light
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`conductor (4), preventing its dislocation from the liquid crystal display device. These
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`extruding pieces (locking parts) (5f) help hold light conductor (4) and LCD (1) into
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`place and thus serve to “ensur[e] that there will be no change in the relative positions
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`of both ends of the LCD (1) and the light conductor (4). . . even when subjected to
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`external shocks.” (Ex. 1002 ¶ 17.)
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`55.
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`Also of note, frame (8) “fit[s] to the outer perimeter of the holder (5),”
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`and uses an “opening (8a) somewhat smaller than the abovementioned LCD (1) is
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`formed on its front.” This feature helps to ensure that light conductor (4) (as well as
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`diffusing film (3), color filter (2), and LCD (1)) is supported by the housing and does
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`“not rattle.” (Ex. 1002 ¶¶ 15 and 18) Based on the foregoing, Niizuma discloses that
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`its housing, holder (5) and tray (8), provides structural support to the panel member,
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`light conductor (4).
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`56.
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`Considering the above, Niizuma discloses all limitations of claim 7.
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`2. Niizuma anticipates claim 8
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`57.
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`In my opinion, Niizuma discloses each and every element of claim 8 of
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`the ’974 patent and therefore anticipates claim 8 under 35 U.S.C. § 102.
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`58.
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`Claim 8 depends from claim 7 and further requires that the tray or
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`housing have structural features that provide a mount or structural support for “a
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`liquid crystal display.” As explained above,, the extruding pieces (locking parts) (5f)
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`serve as posts, tabs, or other structural features that provide a mount or structural
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`support for LCD (1). Figure 3 above demonstrates how the extruding pieces (locking
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`parts) (5f) lock LCD (1) into place