UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`WANGS ALLIANCE CORPORATION d/b/a WAC LIGHTING CO.
`Petitioner
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`v.
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`KONINKLIJKE PHILIPS N.V.
`Patent Owner
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`
`
`
`Case IPR2015-01292
`Patent 6,586,890
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`DECLARATION OF REGAN A. ZANE, PH.D.
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`Page 1 of 69
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`PHILIPS EXHIBIT 2006
`WAC v. PHILIPS
`IPR2015-01292
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`U.S. Patent No. 6,586,890
`IPR2015-01292
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`TABLE OF CONTENTS
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`I.
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`Introduction ...................................................................................................... 1
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`II.
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`Qualifications ................................................................................................... 2
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`III. Legal Standards ............................................................................................... 4
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`A.
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`Claim Construction................................................................................ 4
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`B.
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`Invalidity ............................................................................................... 6
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`IV. Person of Ordinary Skill in the Art .................................................................. 7
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`V. Overview of the ’890 Patent ............................................................................ 9
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`VI. Claim Construction ........................................................................................ 12
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`A.
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`B.
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`“means for sensing . . .”; “means for generating . . .”;
`“means for comparing . . .”; “means for modulating . . .” .................. 13
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`“means for supplying power responsive to the drive signal,
`said power supplying means supplying current to the LED
`array” ................................................................................................... 15
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`VII. Overview of Prior Art .................................................................................... 18
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`A.
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`The ST Micro Datasheet ..................................................................... 18
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`B.
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`Biebl .................................................................................................... 20
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`VIII. The ST Micro Datasheet in Combination with Biebl Does Not
`Render Obvious Claims 7 and 31 .................................................................. 23
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`A.
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`The ST Micro Datasheet and Biebl Are Vastly Different ................... 24
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`1.
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`2.
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`The flyback topology in the ST Micro Datasheet is
`different from and incompatible with the DC chopper
`topology in Biebl. ...................................................................... 25
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`The ST Micro Datasheet uses voltage regulation and
`Biebl uses current regulation. ................................................... 31
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`B.
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`C.
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`3.
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`The ST Micro Datasheet and Biebl use different and
`incompatible PWM control mechanisms. ................................. 34
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`Neither the ST Micro Datasheet nor Biebl Discloses “Means
`for Supplying Power” .......................................................................... 44
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`Theory 1: Implementing the ST Micro IC to Drive an LED
`Load as in Biebl ................................................................................... 46
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`1. Mr. Tingler’s First Proposed Implementation .......................... 47
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`a.
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`b.
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`c.
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`d.
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`The ST Micro Datasheet does not disclose
`“means for sensing current to the LED array”
`based on the Error Amplifier Configuration. ................. 47
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`Using Error Amplifier Configuration to sense
`LED current is hindsight from the ’890 Patent. ............. 49
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`The ST Micro circuit is not designed for driving
`LED load. ........................................................................ 52
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`There is no motivation to combine the ST
`Micro Datasheet with Biebl to derive the
`claimed invention............................................................ 53
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`2. Mr. Tingler’s Second Proposed Implementation ...................... 56
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`a.
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`b.
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`The ST Micro Datasheet does not disclose
`“means for sensing current to the LED array”
`based on the Current Sense pin. ..................................... 56
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`The second proposed implementation results in
`no “means for modulating pulse width.” ........................ 58
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`D.
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`Theory 2: Using the ST Micro IC in Place of the Biebl IC ................ 60
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`IX. Conclusion ..................................................................................................... 65
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`U.S. Patent No. 6,586,890
`IPR2015-01292
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`I, Regan A. Zane, Ph.D., under penalty of perjury, declare as follows:
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`I.
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`1.
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`Introduction
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`I have been retained by Finnegan, Henderson, Farabow, Garrett & Dunner,
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`LLP on behalf of Koninklijke Philips N.V. (“Philips”) to serve as a technical
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`expert and provide my expert opinion in this inter partes review (“IPR”)
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`proceeding No. IPR2015-01292 before the United States Patent and Trademark
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`Office regarding U.S. Patent No. 6,586,890 (“the ’890 patent”). Although I am
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`being compensated at my hourly rate for the time I spend on this matter, no part of
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`my compensation depends on the outcome of this proceeding, and I have no other
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`interest in this proceeding.
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`2.
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`I understand that this proceeding was filed by Wangs Alliance Corporation
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`d/b/a WAC Lighting Co. (“Petitioner”) and that the proceeding involves the ’890
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`patent (Ex. 1001). I understand that the application for the ’890 patent was filed on
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`December 5, 2001, as U.S. Patent Application No. 10/012,000. I understand that
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`the ’890 patent issued on June 1, 2003.
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`3.
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`I understand that the Board instituted Petitioner’s validity challenges of
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`claims 7, 15, 23, and 31 based on two grounds: (1) anticipation of claims 15 and 23
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`by U.S. Patent No. 6,400,101 (“Biebl,” Ex. 1003), presented as Ground 1 in the
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`petition; and (2) obviousness of claims 7, 15, 23, and 31 over Biebl and the ST
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`Microelectronics UC2842/3/4/5 and 3842/3/4/5 datasheet (“the ST Micro
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`Datasheet”), presented as Ground 3 in the petition. Institution Decision at 5;
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`Request for Rehearing Decision at 3. I further understand that Patent Owner is not
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`contesting the Board’s findings with respect to claims 15 and 23 in Ground 1,
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`leaving only Ground 3 with respect to claims 7 and 31 in dispute in the proceeding.
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`Accordingly, I discuss only obviousness of claims 7 and 31 based on the ST Micro
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`Datasheet and Biebl in this Declaration.
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`4.
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`I have been asked to consider the claim construction of “means for
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`sensing . . . ”, “means for generating . . .”, “means for comparing . . .”, “means for
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`modulating . . .”, and “means for supplying . . .” recited in claim 7. I have also
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`been asked to consider whether one of ordinary skill in the art of the ’890 patent
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`would understand that certain references disclose or suggest the features recited in
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`the claims of the ’890 patent, or otherwise render the claims obviousness. My
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`opinions are set forth below.
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`II. Qualifications
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`5.
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`I am serving as an expert in the field of power electronics, and more
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`specifically in drivers and control circuits and techniques to provide power to light-
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`emitting diodes (LEDs). My qualifications in these areas, as well as other areas,
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`are established below and by my curriculum vitae, which is attached as Ex. 2007.
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`6.
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`I am a professor of electrical and computer engineering at Utah State
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`University (USU), and I have over 16 years of experience with lighting
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`technologies, including light-emitting diodes (LEDs). As a professor, I research
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`energy efficiency in lighting and building systems, including solid-state lighting
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`such as LEDs, and gas discharge lamps, as well as a wide range of power
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`electronics applications including advanced control techniques for AC-DC, DC-
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`DC and DC-AC power converters, battery management systems, integration of
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`renewable energy sources and energy storage in AC and DC power grids, and
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`electric drive-trains and charging systems for electric vehicles. I am the founder
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`and director of both the USU Power Electronics Laboratory (UPEL) and the
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`Electric Vehicle and Roadway (EVR) research facility and test track at USU.
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`7.
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`Prior to beginning my current position at Utah State, I spent approximately
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`ten years at the University of Colorado at Boulder as an Assistant and then an
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`Associate Professor of Electrical Engineering. During this time, I taught various
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`courses on circuits and controls, including power electronics for DC and AC
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`applications with many examples in lighting technologies. From 1999-2001, I
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`worked as a Senior Research Scientist at General Electric, where I researched
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`custom integrated circuit controllers for energy efficient lighting systems,
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`including AC circuits for fluorescent lighting and DC circuits for LEDs.
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`8.
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`I received my B.S. and M.S. degrees in Electrical Engineering from the
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`University of Colorado Boulder in 1996 and 1998, and I received my Ph.D. degree
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`from the University of Colorado Boulder in the area of power electronics. My
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`Ph.D. thesis presented new current-mode control concepts for single-phase pulse
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`width modulated (PWM) AC-DC power factor corrected (PFC) circuits.
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`9.
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`I have authored over 120 peer-reviewed publications in the area of power
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`electronics and I am an inventor on 12 issued U.S. patents and additional pending
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`applications, including patents on current-mode control concepts and PWM control
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`of LEDs and LED arrays. I have served as lead faculty advisor and graduated 11
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`Ph.D. students, including 4 Ph.D. students specifically in power circuits for
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`lighting technologies, all of whom now work as leading researchers in the lighting
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`industry. I received the National Science Foundation CAREER Award in 2004 for
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`my work on energy efficient lighting systems (which included 5 years of funding
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`support), the Inventor of the Year Award at the University of Colorado in 2006,
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`and the IEEE Power Electronics Society Richard M. Bass Award in 2008 for
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`outstanding achievement to the field of power electronics based on my work in the
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`lighting and control areas.
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`III. Legal Standards
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`A. Claim Construction
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`10.
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`I have been instructed by counsel on the law regarding claim construction.
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`11.
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`I have been advised that in post-grant review proceedings before the U.S.
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`Patent and Trademark Office, a patent claim receives the broadest reasonable
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`construction in light of the specification of the patent in which it appears. I have
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`also been advised that this means the claim terms are given their ordinary and
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`customary meaning as would be understood by one of ordinary skill in the art at
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`the time of the invention, unless that meaning is inconsistent with the specification
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`of the patent.
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`12.
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`I understand that a person of ordinary skill in the art is deemed to read a
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`claim term not only in the context of the particular claim in which the term
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`appears, but in the context of the entire patent, including the other claims, the
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`specification, and the prosecution history, which is called the “intrinsic evidence.”
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`I understand that claim terms must be construed in a manner consistent with the
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`context of the intrinsic record. I further understand that the specification is highly
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`relevant to claim construction and that, while claims are to be read in light of the
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`specification, limitations should not be imported or read into the claims from the
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`specification.
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`13.
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`I understand that certain types of “extrinsic evidence,” such as general
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`purpose and scientific dictionaries, relevant scientific principles, references
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`illustrating the meaning of technical terms, and the state of the art, may also be
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`relevant to claim construction. Extrinsic evidence should not be considered,
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`however, divorced from the context of the intrinsic evidence.
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`14.
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`I understand that claims of a patent may be written in what is known as a
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`“means-plus-function” form. I understand that a claim element is in means-plus-
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`function form when it is expressed as a means for performing a specified function
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`or functions without the recital of structure in support of the function(s). I
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`understand the first step in construing a means-plus-function limitation is to
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`identify the function(s) explicitly recited in the claim, and the next step is to
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`identify the corresponding structure set forth in the written description that
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`performs the recited function(s). I understand that only the structure necessary to
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`perform the recited function(s) constitutes the corresponding structure.
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`B.
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`Invalidity
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`15.
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`I have been further instructed by counsel on the law regarding validity.
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`16.
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`I have been advised that a patent claim can be invalid if it is anticipated in
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`view of the prior art. I understand that anticipation of a claim requires that every
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`element of a claim be disclosed expressly or inherently in a single prior art
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`reference, arranged as in the claim.
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`17.
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`I have been advised that a patent claim may also be invalid if the differences
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`between the subject matter of the claim and the prior art are such that the subject
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`matter as a whole would have been obvious at the time the invention was made to a
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`person having ordinary skill in the art. I have also advised that several factual
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`inquiries underlie a determination of obviousness. These inquiries include the
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`scope and content of the prior art, the level of ordinary skill in the field of the
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`invention, the differences between the claimed invention and the prior art, and any
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`objective evidence of non-obviousness.
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`18.
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`I have been advised that objective evidence of non-obviousness, known as
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`“secondary considerations of non-obviousness,” may include commercial success,
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`satisfaction of a long-felt but unsolved need, failure of others, copying, skepticism
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`or disbelief before the invention, and unexpected results.
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`19.
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`In addition, I have been advised that the law requires a “common sense”
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`approach of examining whether the claimed invention is obvious to a person
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`skilled in the art. For example, I have been advised that combining familiar
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`elements according to known methods is likely to be obvious when it does no more
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`than yield predictable results.
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`IV. Person of Ordinary Skill in the Art
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`20.
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`In my opinion, a person of ordinary skill in the art of the ’890 patent would
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`have at least a Bachelor’s degree in Electrical Engineering or related field and at
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`least five years of training or additional work experience in the area of power
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`electronics or a related field. More hands-on and design experience would
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`compensate for less formal education, and vice versa. I base this opinion on my
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`years of experience teaching students and working with engineers and
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`professionals in the power electronics field.
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`21.
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`I agree with Mr. Tingler that “a person of ordinary skill in the art is one who
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`is presumed to be aware of all pertinent art, thinks along conventional wisdom in
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`the art, and is a person of ordinary creativity.” Ex. 1006, ¶ 9. However, I disagree
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`with the level of a person of ordinary skill in the art defined by Mr. Tingler.
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`According to Mr. Tingler, “a person of ordinary skill in the art would have at least
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`(i) a bachelor degree in electrical engineering and/or physics with at least 3 years
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`of industrial experience designing power supply circuitry, or (ii) the equivalent
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`relevant industrial experience, including circuit design experience, for a person
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`lacking a formal degree, which would be about 3-5 years in the industry, or (iii) a
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`person of substantially higher graduate education in optoelectronics, such as a
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`Masters or a Doctoral degree.” Id. ¶ 10. In my opinion, the level of skill of a
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`person of ordinary skill in the art defined by Mr. Tingler is lower than the level of
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`skill required to be aware of all pertinent art and to think in light of the
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`conventional wisdom in the art. In addition, graduate education in optoelectronics
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`does not usually provide training or experience in power electronics or a related
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`field.
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`22. Nonetheless, applying Mr. Tingler’s standard for the level of ordinary skill
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`in the art would not affect my analysis and conclusion regarding the patentability
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`of any challenged claim.
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`V. Overview of the ’890 Patent
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`23. The ’890 patent discloses driver circuits that supply power to light-emitting
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`diodes (“LEDs”) using pulse width modulation (PWM) and current feedback.
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`Ex. 1001 at abstract, 1:63-67. One aspect of the disclosed driver circuit provides
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`good regulation and efficiency. Id. at 1:39-40. Another aspect of the disclosed
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`driver circuit maintains operation at the LEDs’ nominal current. Id. at 1:41-43.
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`24. Figure 1, shown below, illustrates an exemplary circuit for providing power
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`to LED array 54. Id. at 2:1-11, Fig. 1. The circuit, among other things, includes a
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`current sensor 60, a reference current source 62, a comparator 58, a power supply
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`52, and PWM control IC 56. Id. at 2:1-16, Fig. 1.
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`Id. at Fig. 1.
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`25. The circuit includes current sensor 60 (“I SENSE”), which provides a
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`sensing signal. Id. at 2:14-16. Comparator 58 provides a feedback signal to PWM
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`control IC 56 by comparing the sensed current signal from current sensor 60 and a
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`reference signal from reference current source 62. Id. In response to the feedback
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`signal, PWM control IC 56 provides a high frequency periodic drive signal of
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`varying pulse width to power supply 52. Id. at 2:8-11. Power supply 52 supplies
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`power to LED array 54 and is controlled by PWM control IC 56 to supply the
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`power that LED array 54 requires. Id. at 2:6-11. Power supply 52 is a DC/DC
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`converter selected from a buck-boost, boost, buck, or flyback power supply
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`converter. Id. at 2:4-6.
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`26. Figures 2A-2D illustrate an exemplary schematic diagram of a driver circuit
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`for an LED array. Id. at 1:57-59, Figs. 2A-2D. Among other things, the driver
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`circuit includes a power supply 112 supplying current to LED array 114. Id. at
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`3:11-12, Fig. 2A. The power supply 112 operates in PWM mode control to
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`regulate the current in the first LED array 114 to the required value. Id. at 3:14-16,
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`Fig. 2A. The power supply 112 is controlled by PWM control IC 118, which
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`varies the pulse width of the drive signal in response to a feedback signal. Id. at
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`3:16-21, Figs. 2A and 2B. The output of op amp 120 represents a scaled version of
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`the LED array 114 current, which is compared to an internal reference of the PWM
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`control IC 118 by an internal op amp of PWM control IC 118. Id. at 3:25-27, Fig.
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`2B. The internal op amp of PWM control IC 118 generates the feedback signal
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`based on the comparison.
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`Id. at Figs. 2A and 2B.
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`27. To accomplish feedback regulation of the LED load current, the ’890 patent
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`utilizes the internal components of the PWM control IC 118 in a unique
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`configuration and operation by (1) bypassing the current-mode transistor current
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`sensing function all together and converting the current sense comparator into a
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`direct duty cycle control PWM by generating a ramp signal from the reference pin
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`“VREF” and the oscillator timing pin “RT/CT” and passing the generated ramp
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`signal into the current sense pin “Isense”, and (2) replacing the traditional voltage
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`feedback loop that connects to the voltage feedback pin “VFB” with a new LED
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`output current feedback loop that connects through the “VFB” and “COMP” pins.
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`See id. at Fig. 2B.
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`VI. Claim Construction
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`28.
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`I have reviewed the constructions proposed by the Patent Owner. In my
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`opinion, these constructions are supported by the prosecution history, and I do not
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`believe anything in the prosecution history alters my opinion on the claim
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`constructions set forth below. In addition, I have relied on my education,
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`experience, and knowledge of engineering practices and principles in the field of
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`optics and my understanding of the applicable legal principles described in this
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`declaration.
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`A.
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`“means for sensing . . .”; “means for generating . . .”;
`“means for comparing . . .”; “means for modulating . . .”
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`29. Claim 7 recites these terms. I understand that the Board agreed with the
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`Patent Owner that these terms do not need to be construed. In my opinion, a
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`person of ordinary skill in the art at the time of the invention would have
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`understood that the terms are in a means-plus-function format. The claimed
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`function and the corresponding structure of each term are summarized in the table
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`below. The constructions are supported by the specification of the ’890 patent
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`(Ex. 1001), and its prosecution history (Ex. 1002).
`
`Term
`“means for sensing
`current to the LED
`array, said current
`sensing means
`generating a sensed
`current signal”
`
`Function
`“sensing current to
`the LED array,” and
`“generating a
`sensed current
`signal”
`
`“Means for
`generating a
`reference signal”
`
`“generating a
`reference signal”
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`
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`13
`
`Corresponding Structure
`current sensor 60; resistor(s), e.g.,
`R1A1, R1A2, and/or R1A3 in Fig.
`2A; or resistor R1B1, R1B2, and/or
`R1B3 in Fig. 2C. Ex. 1001 at Figs. 1,
`2A, 2B, 2C, 2D, 2:14-16 (“The
`comparator 58 provides the feedback
`signal by comparing the sensed
`current signal from current sensor 60
`and the reference signal from
`reference current source 62.”), 3:30-
`35 (“In the embodiment shown [in
`Fig. 2A], resistors [R1A1, R1A2, and
`R1A3] between the first power supply
`112 and the first LED array 114 are
`used for LED current sensing; . . . .”).
`
`reference current source 62; or the
`internal reference in PWM control IC
`118 or 134. Id. at Figs. 1, 2A, 2B,
`2C, 2D, 2:14-16 (“The comparator 58
`provides the feedback signal by
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`Term
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`Function
`
`“Means for
`comparing the
`sensed current
`signal to the
`reference signal,
`said comparing
`means generating a
`feedback signal”
`
`“comparing the
`sensed current
`signal to the
`reference signal and
`generating a
`feedback signal”
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`“modulating pulse
`width responsive to
`the feedback signal
`and generating a
`drive signal”
`
`“Means for
`modulating pulse
`width responsive to
`the feedback signal,
`said pulse width
`modulating means
`generating a drive
`signal”
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`Corresponding Structure
`comparing the sensed current signal
`from current sensor 60 and the
`reference signal from reference
`current source 62.”), 3:23-30 (“The
`output of op amp 120 represents a
`scaled version of the first LED array
`114 current, which is compared to an
`internal reference of the PWM control
`IC.”).
`
`comparator 58; or the internal op-amp
`in PWM control IC 118 or 134. Id. at
`Figs. 1, 2A, 2B, 2C, 2D, 2:14-16
`(“The comparator 58 provides the
`feedback signal by comparing the
`sensed current signal from current
`sensor 60 and the reference signal
`from reference current source 62.”),
`3:23-35 (“The first PWM control IC
`118 varies the pulse width of the drive
`signal in response to a feedback
`signal from first op amp 120.”).
`
`pulse width modulation (PWM)
`control IC 56, PWM control IC 118,
`or PWM control IC 134. Id. at Figs.
`1, 2A, 2B, 2C, 2D, abstract, 1:6-8,
`1:60-65, 2:4-13 (“The power supply
`52 supplies power for LED array 54
`and is controlled by PWM control IC
`56. The PWM control IC 56 provides
`a high frequency periodic drive signal
`of varying pulse width to direct the
`power supply 52 to supply power as
`required by the LED array 54 in
`response to a feedback signal.”), 3:11-
`34 (“First FET 116 switches the first
`power supply 112 rapidly in response
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`Term
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`Function
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`U.S. Patent No. 6,586,890
`IPR2015-01292
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`Corresponding Structure
`to a drive signal from a first PWM
`control IC 118.”), 3:55-56, 4:1-12,
`4:33-53 (The second transistor 142
`also synchronizes the second PWM
`control IC 134 with the low frequency
`oscillator 144 as the low frequency
`oscillator 144 output switches from
`high to low, activating the second
`PWM control IC 134 and energizing
`the second LED array 126.”).
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`
`
`
`B.
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`“means for supplying power responsive to the drive signal,
`said power supplying means supplying current to the LED
`array”
`
`30. Claim 7 recites “means for supplying power responsive to the drive signal,
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`said power supplying means supplying current to the LED array.” In my opinion,
`
`a person of ordinary skill in the art at the time of the invention would have
`
`understood the term as in a means-plus-function format. The claimed functions are
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`“supplying power responsive to the drive signal” and “supplying current to the
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`LED array,” and the corresponding structure should include “a buck-boost power
`
`supply or other alternatives, such as a boost, buck, or flyback converter.”
`
`31. This construction is supported by the language of the claims as a whole and
`
`the specification of the ’890 patent. For example, the specification discloses a
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`“power supply uses current feedback to adjust power to the LEDs.” Id. at 1:65-67,
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`abstract. The specification further discloses, in connection with Figure 1, that
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`“[t]he power supply 52 supplies power for LED array 54,” and “[t]power supply 52
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`can be a DC/DC converter such as a buck-boost power supply or other alternatives,
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`U.S. Patent No. 6,586,890
`IPR2015-01292
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`such as a boost, buck, or flyback converter.” Id. at 2:1-13, Figs. 1, 2A-D;
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`Ex. 1009, ¶ 86. I did not find anything in the prosecution history that is
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`inconsistent with this meaning.
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`32. Mr. Tingler agrees with the function stated above, but disagrees with the
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`corresponding structure. Ex. 1006, ¶ 36. Mr. Tingler identifies “power supply
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`with at least one transistor or switch for receiving a drive signal” as the
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`corresponding structure. Id. Mr. Tingler’s construction is not limited to the
`
`structures disclosed in the specification and equivalents thereof. As explained, the
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`specification of the ’890 patent discloses “a buck-boost power supply or other
`
`alternatives, such as a boost, buck, or flyback converter” as the structure that
`
`performs the function of “supplying power responsive to the drive signal and
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`supplying current to the LED array.”
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`33. Exemplary topologies of these disclosed types of converters are shown
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`below:
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`
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`
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`Fig. 3-5(a): Basic Buck Topology
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`Fig. 3-6(a) Basic Boost Topology
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`U.S. Patent No. 6,586,890
`IPR2015-01292
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`Fig. 3-7(a) Basic Buck-Boost Topology
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`Fig. 3-9(a) Basic Flyback Topology
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`
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`
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`Ex. 2001 at 61-62, 64.
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`34. Mr. Tingler’s proposed corresponding structure would cover power circuits
`
`beyond those that are disclosed or intended in the specification of the ’890 patent,
`
`including DC chopper circuits that have a single transistor by itself. The
`
`corresponding structure could even include linear amplifiers, which waste energy.
`
`See Ex. 2009 at Fig. 1.7b (where Vref represents the drive signal). Neither the DC
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`chopper circuits nor the linear amplifiers are switched-mode power supplies. They
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`are distinctly different from the high efficiency power supplies disclosed in the
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`specification of the ’890 patent.
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`VII. Overview of Prior Art
`
`A. The ST Micro Datasheet
`
`35. The ST Micro Datasheet discloses an integrated circuit that “provides the
`
`necessary features to implement off-line or DC to DC fixed frequency current
`
`mode control schemes.” Ex. 1005 at 1. A block diagram of the UC2842/3/4/5
`
`family of controllers is shown below.
`
`
`
`Id. at 1.
`
`36. The ST Micro Datasheet discloses a “Current Mode PWM Controller,”
`
`providing the “current mode PWM” feature that limits the peak inductor current
`
`flowing through the transistor switch by a current comparator and PWM latch. The
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`primary benefits as described in the datasheet are “pulse by pulse current limiting”
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`and “enhanced load response characteristics.” Id. UC2842 has a separate voltage
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`regulation feature provided by the “VFB” pin. An error amplifier is also provided
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`
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`to compare the signals at the voltage feedback “VFB” pin and feedback
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`compensation “COMP” pin. Id. at 5, Fig. 1.
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`37. The ST Micro Datasheet discloses only one power supply implemented
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`using the controller chip, an “Off-line Flyback Regulator,” illustrated in Figure 11
`
`below.
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`
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`Id. at 8, Fig. 11.
`
`38. As shown in Figure 11, the off-line flyback regulator uses a flyback
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`converter including transformer T1, a MOSFET switch Q1 connected to the
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`primary side of transformer T1, and three output circuits connected to the
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`secondary sides of transformer T1 for regulated +5 V and +/-12 V output voltages.
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`Q1 is driven by a drive signal provided by the OUTPUT pin (pin 6) of the UC3844
`
`controller to generate an AC voltage on the primary side of the transformer T1.
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`The AC voltage is coupled to the secondary side of transformer T1 for the three
`
`outputs, where each output includes a diode rectifier and output filter to convert the
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`AC voltage to a DC voltage to be supplied to the load. The output voltage on the
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`secondary side is regulated using an additional winding on the transformer T1 and
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`a voltage feedback circuit connected to the VFB and COMP pins of the IC. The
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`peak primary side current through the transistor Q1 is limited using the current-
`
`mode PWM feature of the IC using the transistor current sensing circuit connected
`
`to pin 3.
`
`B.
`
`Biebl
`
`39. Biebl discloses a “drive circuit . . . suitable for an LED array.” See Ex. 1003
`
`at abstract. Recognizing that series resistors used for current limiting when driving
`
`LEDs usually cause power loss and heating problems, the “object” of Biebl “is to
`
`provide a drive circuit for an LED . . . , which produces as little emitted heat and
`
`power loss as possible.” Id. at 1:9-33, 2:17-20. To achieve the objective, “[a]
`
`pulsed LED drive is used in order to eliminate the series resistor R.” Id. at 2:21-
`
`23. Specifically, a “semiconductor switch is arranged in series between the LED
`
`and the supply voltage and allows the LED current to be supplied in a pulsed
`
`manner.” Id. at abstract, 1:6-8. Also, a “measurement resistor for measuring the
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`LED current is arranged in series between the LED and ground, with a control loop
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`
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`20
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`controlling the semiconductor switch such that a constant mean value of the LED
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`U.S. Patent No. 6,586,890
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`current is achieved.” Id. at abstract.
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`40. For example, Figure 8, reproduced below, shows a diagram of an integrated
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`circuit (“IC”) connected to a direct current (“DC”) battery on the input and an LED
`
`string or “cluster” on the output. See id. at 5:51, Figs. 4a, 6.
`
`
`
`Id. at Fig. 8.
`
`41.
`
`In the driver circuit, “[t]he LEDs are connected in series with a means for
`
`measuring the current,” such as a measurement resistor Rshunt. Id. at 2:57-62. The
`
`mean value of the current is then formed and “is provided as an input value to a
`
`regulator.” Id. at 2:63-3:2. A reference voltage is provided as a second input value
`
`to the regulator. Id. at 3:2-4. The regulation voltage at the output of the regulator
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`
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`is set corresponding to the nominal value of the reference voltage. Id. at 3:4-8.
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`The regulation voltage is input to a comparator, and compared with a signal from a
`
`frequency generator (such as a sawtooth signal). Id. at 2:37-44.
`
`42. The drive c