IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`United States Patent No: 7,688,347
`Inventor: Eugene Dolgoff
`Formerly Application No.: 10/115,279
`Issue Date: March 30, 2010
`Filing Date: April 3, 2002
`Former Group Art Unit: 2621
`Former Examiner: Gims S Philippe
`Patent Owner: Eugene Dolgoff
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`Attorney Docket No.:
`108421-0006-651
`Customer No.: 28120
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`Petitioner: NEC Display
`Solutions of America, Inc.
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`For: HIGH-EFFICIENCY DISPLAY SYSTEM UTILIZING AN OPTICAL
`ELEMENT TO RESHAPE LIGHT WITH COLOR AND BRIGHTNESS
`UNIFORMITY
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`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
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`PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 7,688,347
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`Inter Partes Review
`United States Patent No. 7,688,347
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`TABLE OF CONTENTS
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`INTRODUCTION ........................................................................................... 1
`I.
`II. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8 ................................... 3
`III. PETITIONER HAS STANDING .................................................................... 4
`A. Grounds for Standing Under § 42.104(a) .............................................. 4
`B.
`Claims and Statutory Grounds Under §§ 42.22 and 42.104(b) ............. 5
`IV. SUMMARY OF THE ’347 PATENT ............................................................. 5
`A. Overview of the ’347 Patent .................................................................. 5
`B.
`Summary of the ’347 Patent Prosecution .............................................. 6
`C. Overview of the Field of the Claimed Invention .................................. 7
`THERE IS A REASONABLE LIKELIHOOD THAT PETITIONER
`WILL PREVAIL WITH RESPECT TO AT LEAST ONE CLAIM OF
`THE ‘347 PATENT ....................................................................................... 11
`A.
`Claim Construction Under 37 C.F.R. § 42.104(b)(3) ......................... 11
`B.
`Level of Ordinary Skill in the Art and State of the Art ....................... 14
`C. Uehara in View of the Knowledge of a POSITA Renders
`Obvious Claims 1, 17, and 61 (Ground 1) .......................................... 15
`1.
`Overview of Uehara .................................................................. 15
`2.
`Uehara in View of the Knowledge of a POSITA Renders
`Obvious Claim 1 ....................................................................... 16
`Uehara in View of the Knowledge of a POSITA Renders
`Obvious Claim 17 ..................................................................... 27
`Uehara in View of the Knowledge of a POSITA Renders
`Obvious Claim 61 ..................................................................... 31
`Lehureau in View of the Knowledge of a POSITA Renders
`Obvious Claims 1, 17, and 61 (Ground 2) .......................................... 36
`1.
`Overview of Lehureau .............................................................. 36
`2.
`Lehureau in View of the Knowledge of a POSITA
`Renders Obvious Claim 1 ......................................................... 37
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`3.
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`4.
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`V.
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`D.
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`United States Patent No. 7,688,347
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`3.
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`4.
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`Lehureau in View of the Knowledge of a POSITA
`Renders Obvious Claim 17 ....................................................... 48
`Lehureau in View of the Knowledge of a POSITA
`Renders Obvious Claim 61 ....................................................... 53
`VI. CONCLUSION .............................................................................................. 59
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`Exhibit
`Ex. 1001
`Ex. 1002
`Ex. 1003
`Ex. 1004
`Ex. 1005
`Ex. 1006
`Ex. 1007
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`Ex. 1008
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`Ex. 1009
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`Inter Partes Review
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`LIST OF EXHIBITS
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`Description
`U.S. Patent No. 7,688,347
`U.S. Patent No. 7,688,347 File History
`Expert Declaration of Prof. Jose Sasian
`JP H05-72628 (“Uehara”)
`WO 91/18315 (“Lehureau”)
`US 4,915,479 (“Clarke”)
`Plaintiff’s Amended Infringement Contentions, Cascades
`Projection LLC v. NEC Display Solutions of America, Inc., No.
`2:15-CV-00273 (C.D. Cal. June 19, 2015)
`Exhibit A to Plaintiff’s Preliminary Infringement Contentions,
`Cascades Projection LLC v. NEC Display Solutions of America,
`Inc., No. 2:15-CV-00273 (C.D. Cal. April 27, 2015)
`Declaration of Matthew J. McDonell
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`iv
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`Pursuant to §§ 311-319 and Rule § 42,1 the undersigned, on behalf of and
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`Inter Partes Review
`United States Patent No. 7,688,347
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`acting in a representative capacity for NEC Display Solutions of America, Inc.
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`(“NECDS” or “Petitioner”) hereby petition for inter partes review of claims 1, 17
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`and 61 (“the Challenged Claims”) of U.S. Pat. No. 7,688,347 (“the ’347 patent”),
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`issued to Eugene Dolgoff, and according to the USPTO, currently assigned to
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`Eugene Dolgoff (“Dolgoff” or “Patent Owner”). Petitioner hereby asserts that
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`there is a reasonable likelihood that at least one of the Challenged Claims is
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`unpatentable for the reasons set forth herein, and respectfully requests review of,
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`and judgment against, claims 1, 17 and 61 as unpatentable under § 103.
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`I.
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`INTRODUCTION
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`The Challenged Claims of the ‘347 patent seek to claim a concept that was
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`well-known long before the April 4, 1994 claimed priority date2: the use of a
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`reflective “light tunnel” in a display system for sending light from a “light source”
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`to an electronic “image-forming element” (IFE) (e.g., LCD, see Ex. 1001 at 53:13-
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`14) where the output aperture of the “light tunnel” has the same aspect ratio as the
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`IFE.
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`1 Section cites are to 35 U.S.C. or 37 C.F.R. as the context indicates. All emphasis
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`and annotations to figures herein is added unless otherwise noted.
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`2 During prosecution, Applicant expressly and unambiguously disclaimed priority
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`to applications filed before April 4, 1994. See Ex. 1002 at 00421, 00432.
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`As set forth in this Petition, the supposed “invention” in each of the
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`Challenged Claims of the ‘347 patent was well-known and obvious. For example,
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`as discussed herein, Japanese Patent Publication No. 05-72628 (“Uehara”)
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`discloses a display system that uses a reflective “rod integrator” for sending light
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`from a “light source” to a “liquid crystal surface,” where the output aperture of the
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`“rod integrator” has the same shape as, and hence an aspect ratio matching, the
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`“liquid crystal surface.” PCT International Publication No. WO 91/18315
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`(“Lehureau”) also discloses a display system that uses a reflective “housing” for
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`sending light from a “light source” to a “liquid crystal screen” where the output
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`aperture of the “housing” has the same shape as, and hence an aspect ratio
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`matching, the “liquid crystal screen.” Likewise, U.S. Patent No. 4,915,479
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`(“Clarke”) discloses a display system that uses a reflective “light guide” for
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`sending light from a “light source” to a “liquid crystal display panel” where the
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`output aperture of the “light guide” has the same shape as, and hence an aspect
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`ratio matching, the “liquid crystal display panel.”
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`Claim 17 of the ‘347 patent further requires a means for magnifying an
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`image of the output aperture and claim 61 further requires the image of the output
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`aperture to be the same size as the IFE. However, these, too, were well-known.
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`For example, Uehara discloses using, e.g., a “condenser lens” to magnify the light
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`exiting the “rod integrator,” so as to form an image on the liquid crystal surface
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`with an “accurately matched” size. Lehureau also discloses using, e.g., an “outlet
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`lens” to magnify the image of the output aperture to have the same size as the
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`liquid crystal screen. Finally, Clarke discloses that the output aperture of the “light
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`guide” “cover[s] the area” of the “liquid crystal display panel.”
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`As demonstrated below, every element of the Challenged Claims has been
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`disclosed or rendered obvious by the prior art and the claims are nothing more than
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`a routine and predictable combination of these well-known elements. Thus,
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`Petitioner respectfully requests that the Board find each of the Challenged Claims
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`invalid under § 103.
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`II. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8
`Real Party in Interest Under § 42.8(b)(1): The real parties-in-interest are
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`NEC Display Solutions of America, Inc. and NEC Display Solutions, Ltd.
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`Related Matters Under § 42.8(b)(2): The exclusive licensee, Cascades
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`Projection LLC (“Cascades”), has alleged infringement of the ’347 patent against
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`Petitioner. Cascades Projection LLC v. NEC Display Solutions of Am., Inc., No.
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`2:15-CV-00273 (C.D. Cal. Jan. 13, 2015), ECF No. 1, and against other parties in:
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`Cascades Projection LLC v. Epson Am., Inc. et al., No. 2:15-cv-00258 (C.D. Cal.),
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`Cascades Projection LLC v. Barco, Inc. et al., No. 2:15-cv-00271 (C.D. Cal.),
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`Cascades Projection LLC v. Sony Corp. of Am., Inc. et al., 2:15-cv-00274 (C.D.
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`Cal.), and Cascades Projection LLC v. Christie Digital Sys. USA, Inc., 8:15-cv-
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`00050 (C.D. Cal.). Petitioner further identifies the following administrative
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`matters, including patents and applications claiming priority to the ’347 patent:
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`App’n. Nos. 12/749,493 and 13/369,005 (both abandoned). Petitions for inter
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`partes review of the ’347 patent were filed by Epson (IPR2015-01206), Christie
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`(IPR2015-01342) and Barco (IPR2015-01827). The aforementioned C.D. Cal.
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`cases have been stayed pending resolution of petitions for inter partes review filed
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`by Epson and Christie. Cascades Projection LLC v. NEC Display Solutions of Am.,
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`Inc., No. 2:15-CV-00273 (C.D. Cal. July 9, 2015), ECF No. 51. Finally, Petitioner
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`has concurrently filed another IPR petition for the ‘347 patent challenging different
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`claims based on different references.
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`Lead and Back-Up Counsel Under Rule 42.8(b)(3) and Service
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`Information under Rule 42.8(b)(4): Designated in the signature block.
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`III. PETITIONER HAS STANDING
`A. Grounds for Standing Under § 42.104(a)
`Petitioner certifies pursuant to 37 C.F.R. § 42.104(a) that the ’347 patent is
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`eligible for inter partes review and that Petitioner is not barred or estopped from
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`requesting same. Petitioner was served with a Complaint asserting infringement of
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`the ’347 patent on or after January 30, 2015, and neither Petitioner nor any other
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`real party-in-interest or privy of Petitioner was served with a complaint before that
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`date, or has initiated a civil action challenging validity of the ’347 patent.
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`B. Claims and Statutory Grounds Under §§ 42.22 and 42.104(b)
`Petitioner requests inter partes review of claims 1, 17, and 61 and asserts
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`that these claims are unpatentable based on one or more grounds under 35 U.S.C. §
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`103: Ground 1: Claims 1, 17 and 61 are obvious under § 103 over Uehara in view
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`of the knowledge of a POSITA; Ground 2: Claims 1, 17 and 61 are obvious under
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`§ 103 over Lehureau in view of the knowledge of a POSITA.
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`None of the art cited in these grounds was considered by the Office during
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`prosecution of the ’347 patent. Further, none of the art cited in these grounds is
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`cited in the Petitions filed by Epson (IPR2015-01206), Christie (IPR2015-01342)
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`or Barco (IPR2015-01827). Sections V.B-V.D below provide, e.g., claim charts
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`specifying how the cited art renders obvious each of the Challenged Claims, as
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`confirmed by the knowledge and understanding of a person of ordinary skill in the
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`art (“POSITA”), as evidenced in Ex. 1003, the Declaration of Prof. Jose Sasian.
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`IV. SUMMARY OF THE ’347 PATENT
`A. Overview of the ’347 Patent
`The ’347 patent discusses a “High-Efficiency Display System Utilizing an
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`Optical Element to Reshape Light With Color and Brightness Uniformity.” Ex.
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`1001. The ‘347 patent describes that an alleged inefficiency to conventional
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`projection systems is “‘spillover loss’, which is found in conventional projection
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`systems in which a circular beam illuminates a rectangular aperture.” Id. at 34:52-
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`54. Illuminating a rectangular image with a circular beam can, according to the
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`‘347 patent, “result in the loss of up to approximately 40% of the light.” Id. at
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`38:2-3.
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`The ’347 patent proposes and claims previously-known solutions to this
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`problem. For example, the ‘347 patent describes using “light tunnels” which “can
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`be used to obtain several important advantages in display systems such as
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`obtaining more uniform illumination of the image forming element and the shaping
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`of the light beam to conform to the shape of the IFE.” Id. at 34:15-19. The ‘347
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`patent further describes that “matching the shape of the tunnel, and especially its
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`output aperture shape…to that of the image-forming element can cause the light to
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`fill the image-forming element” and therefore “minimize ‘spillover loss’” and
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`improve “efficiency” and “brightness.” Id. at 34:48-55. But as detailed further
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`herein, the solution of using a “light tunnel” with a matching “output aperture
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`shape” to that of the “image-forming element” was, like the remainder of the
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`Challenged Claims, well-known prior to April 4, 1994, and the Challenged Claims
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`are all unpatentable as obvious.
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`Summary of the ’347 Patent Prosecution
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`B.
`The ’347 patent issued from Application No. 10/115,279, filed April 3, 2002.
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`At the outset of prosecution, the Applicant claimed priority to a Feb. 21, 1991
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`application, but subsequently disclaimed priority to applications filed before the
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`April 4, 1994 date of filling of Application No. 08/223,479 (“the ’479 application”).
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`Ex. 1002 at 00008, 00421, 00432.
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`After the disclaimer of priority, the Examiner rejected pending claims 1, 3-
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`12, 14-19, 22-34, 36-43, 45-47, 49-55, 61-62, 65, 67-72, and 77-79 under § 102(e)
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`as being anticipated by another Dolgoff patent, U.S. Patent No. 5,602,679 to
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`Dolgoff et al. (“the ’679 Dolgoff patent”). Ex. 1002 at 00439. The ’679 Dolgoff
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`patent also claimed priority to the ’479 application, and the Applicant successfully
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`argued that the § 102(e) date of the ’679 patent was April 4, 1994 because the
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`applications preceding the ’479 application in the priority chain did not disclose
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`the subject matter of the instant application’s pending claims. Ex. 1002 at 00468.
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`Therefore, the ’679 Dolgoff patent was not prior art to the instant application
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`because it had the same earliest effective filing date. Ex. 1002 at 00467-68. The
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`Applicant also submitted a declaration that the subject matter cited by the
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`Examiner from the ’679 Dolgoff patent was solely invented by Eugene Dolgoff,
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`and, therefore, was not invented by “another.” Ex. 1002 at 00470, 00472-73.
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`The Examiner, however, did not consider any other patents or publications
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`of Eugene Dolgoff preceding the effective filing date of April 4, 1994, and did not
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`consider any of the prior art references relied on in this Petition.
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`C. Overview of the Field of the Claimed Invention
`Prior to April 4, 1994, the “light tunnel” solution claimed in the ’347 patent
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`was, like the remainder of the Challenged Claims, already well-known. See Ex.
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`1003 at ¶¶ 36-46. For example, Uehara (Ex. 1004), published on March 26, 1993,
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`also recognized the problem of, e.g., “illuminance loss” that can occur where the
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`circular light flux from a light source must cover a rectangular liquid crystal
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`surface. See Ex. 1004 at [0007]. To solve such problem, Uehara discloses a
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`display system that uses a “rod integrator” made of, e.g., solid polished glass with
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`inner reflective side surfaces. See Ex. 1004 at [0020], [0025], Fig. 1. The “rod
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`integrator 5,” which is located between a “light source 1” and “liquid crystal
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`surface 10,” converts the shape of the light flux from the light source (a circular
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`shape) to “match” the shape of the “liquid crystal surface 10” (a rectangular shape).
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`See id. at [0007], [0012], [0020], Fig. 1:
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`Similarly, Lehureau (Ex. 1005), published on Nov. 28, 1991, also
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`recognized the problem of, e.g., light loss from mismatched shape between the
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`light source and the object to be projected. See Ex. 1005 at 1:19-22. To overcome
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`this problem, Lehureau discloses a display system that uses a “housing 7a” located
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`between the “light source 6a” and the “liquid crystal screen 2.” See, e.g., Ex. 1005
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`at 6:11-20, Fig. 3:
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`In one embodiment, the “housing” comprises multiple “outlet openings” that each
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`have the same shape as, and hence an aspect ratio (e.g., “16/9 format”) matching,
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`the “liquid crystal screen 2.” See id. at 6:33-7:2.
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`Likewise, Clarke (Ex. 1006), issued on April 10, 1990, discloses a display
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`system that uses a “light guide 6 [] placed between the [light] source 3 and the
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`[liquid crystal display] panel 1” (Ex. 1006 at 3:66-4:16) for sending light from the
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`“light source” to the “liquid crystal display panel.” See id. at 1:7-16, 1:55-65,
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`3:57-67, Fig. 1:
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`Light from the “light source” is fed to an “input face” of the “light guide” (id. at
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`4:20-24) and emerges from an “output face” of the “light guide,” which includes a
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`“positive lens” that “provide[s] a general collimating effect on divergent light
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`emerging from the guide” and passes the collimated light to the “liquid crystal
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`display panel.” Id. at 2:8-16, 4:40-49, 11:22-23; see also Ex. 1003 ¶ 43. Clarke
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`further discloses that the “walls 11 of the guide…are reflective to light inside the
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`guide.” Ex. 1006 at 4:12-16. Moreover, Clarke discloses that the “liquid crystal
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`display panel 1” is divided into “sixteen separate pixels” and shown to have a 4x4
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`aspect ratio (i.e., square). Id. at 3:40-46, Fig. 1. Clarke further discloses that in
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`this embodiment, the “light guide” also has a “square cross-section” and has “an
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`output face…covering the area of the panel 1.” Id. at 4:5-8, Fig. 1. Thus, a
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`POSITA would have understood from Clarke’s disclosure—including, e.g., Fig. 1
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`of Clarke that shows the LCD panel 1 with the same size and aspect ratio as the
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`output aperture of the “light guide”—that the output aperture of Clarke’s light
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`guide has the same size and shape as, and hence an aspect ratio matching, the LCD
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`panel. See Ex. 1003 ¶ 43.
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`These examples show that the “invention” of the Challenged Claims was
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`widely described before the priority date. The Challenged Claims are invalid
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`under § 103.
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`V.
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`THERE IS A REASONABLE LIKELIHOOD THAT PETITIONER
`WILL PREVAIL WITH RESPECT TO AT LEAST ONE CLAIM OF
`THE ‘347 PATENT
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`Petitioner submits there is at least “a reasonable likelihood that the
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`petitioner[ ] would prevail with respect to at least 1 of the claims challenged in the
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`petition.” § 314(a). Indeed, all of the Challenged Claims of the ‘347 patent are
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`unpatentable as invalid under the requirements of 35 U.S.C. § 103 because they are
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`obvious in light of the prior art, as explained below.
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`A. Claim Construction Under 37 C.F.R. § 42.104(b)(3)
`Pursuant to 37 C.F.R. § 42.100(b), for the purposes of this review, Petitioner
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`construes the claim language such that each term is “given its broadest reasonable
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`construction in light of the specification of the patent in which it appears.” 37
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`C.F.R. § 42.100(b). For terms not specifically listed and construed below,
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`Petitioner interprets them for purposes of this review in accordance with their plain
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`and ordinary meaning under the required broadest reasonable construction
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`consistent with the specification of the ’347 patent. Because the standard for claim
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`construction at the PTO is different than that used in litigation, see In re Am. Acad.
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`of Sci. Tech Ctr., 367 F.3d 1359, 1364, 1369 (Fed. Cir. 2004), MPEP § 2111,
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`Petitioner expressly reserves the right to argue in litigation constructions for any
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`term in the ’347 patent, as appropriate to that proceeding.
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`“means for magnifying an image of said output aperture positively or
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`negatively” (Claim 17): For review purposes, this term should be construed as a
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`means-plus-function element in accordance with § 112 ¶ 6. See, e.g., Sage Prods.,
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`Inc. v. Devon Indus., Inc., 126 F.3d 1420, 1427 (Fed. Cir. 1997).3
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`The specification does not ascribe an express meaning to “magnifying,”
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`“positively” or “negatively” in connection with the image of the output aperture,
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`and, indeed, does not use the terms at all. 4 The specification does refer to
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`“magnification factor” (see below), and uses the term “magnify” in its ordinary
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`meaning – i.e., “enlarge.” See Ex. 1001 at 24:38-47 (“A lens array 801…could be
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`used to magnify each pixel…. Then optionally either a collimating lens array…or
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`a large collimating optic…could be used to recollimate the now enlarged…pixels
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`3 Cascades has identified this claim term as a means-plus-function limitation in its
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`district court litigation against Petitioner. See Ex. 1007 at 00005.
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`4 The specification’s mentions of “demagnifying” and “positive-negative” are not
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`in the context of magnifying an image of the output aperture. See Ex. 1001 at
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`48:61-64, 45:14.
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`for projection…”). It is well-known that, in forming the image of an object using a
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`lens, the concept of magnification can convey the orientation of the image where
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`“negative” magnification implies that the magnified image is inverted and
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`“positive” magnification implies that the magnified image is in the same
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`orientation as the object. See Ex. 1003 ¶ 33. However, this concept is not
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`discussed in the ‘347 patent. Accordingly, the claimed function is the ordinary
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`meaning of “magnifying an image of said output aperture positively or negatively.”
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`See Ex. 1003 ¶ 33.
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`The corresponding structure includes a lens, which the specification
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`describes as being used to “focus[] an image of the output of the tunnel” and
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`“expand[] the light from the tunnel” resulting in a “magnification factor.” See Ex.
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`1001 at 39:6-29 (“Lens 6620 focuses an image of the output of the tunnel (which
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`has the same shape as the IFE 6660) into the plane of an array of lenses 6630
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`(which may be Fresnel lenses). . . . By expanding the light from the tunnel to a
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`large area at 6630, divergence is decreased and collimation is increased by the
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`magnification factor. . . . Alternatively, lens 6620 can focus the output of the
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`tunnel 6610 onto the IFE 6660 directly (eliminating 6630, 6640, and 6650).
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`Knowing the output angle of the light emanating from the tunnel and knowing the
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`acceptance angle of the input lens array (explained elsewhere, herein) determines
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`the required magnification factor. Then, considering the size of the IFE, using that
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`magnification factor in reverse determines the required size of the output exit of
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`the tunnel.”), Fig. 66:
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`See also Ex. 1003 ¶ 34; Ex. 1008 (Cascades Amended Infringement Contentions)
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`at 19 (“This means takes the form of a lens for magnifying an image of the
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`output aperture”).
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`Level of Ordinary Skill in the Art and State of the Art
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`B.
`Petitioner submits that the applicable POSITA would have had a bachelor’s
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`degree in optics or optical engineering and at least two years experience working
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`with the optical engineering of projection display or related optical systems; or a
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`bachelor’s in physics, engineering physics, electrical engineering or mechanical
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`engineering or equivalent and at least five years of such work experience. See Ex.
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`1003 ¶¶ 29-31. Additional graduate education could substitute for professional
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`experience, or significant experience in the field could substitute for formal
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`education. A POSITA is presumed to have knowledge of all relevant prior art, and
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`thus would have been familiar with each of the references cited herein and the full
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`range of teachings they contain. See id.
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`14
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`Inter Partes Review
`United States Patent No. 7,688,347
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`C. Uehara in View of the Knowledge of a POSITA Renders Obvious
`Claims 1, 17, and 61 (Ground 1)
`1.
`Japanese Patent Publication No. 05-72628 (“Uehara”) (Ex. 1004) was
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`Overview of Uehara
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`published on March 26, 1993, more than one year before the earliest priority date
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`claimed by Applicant (April 4, 1994), making it prior art to the ’347 patent under
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`at least §§ 102(a) and (b). See discussion, supra, at IV.B.
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`Uehara recognizes the problem of, e.g., “illuminance loss,” the same type of
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`problem the ‘347 patent purportedly sought to address. See Ex. 1004 at [0007]; Ex.
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`1001 (‘347 Patent) at 34:48-55; Ex. 1003 ¶ 48. For example, Uehara describes that
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`“illuminance loss” can occur, e.g., where the circular light flux from a light source
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`must cover a rectangular liquid crystal surface. See Ex. 1004 at [0007].
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`To solve this problem, Uehara discloses a display system that uses a “rod
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`integrator 5” made of, e.g., solid polished glass with inner reflective side surfaces.
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`See id. at [0001], [0020], [0025], Fig. 1. The “rod integrator,” which is located
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`between a “light source 1” and “liquid crystal surface 10,” converts the shape of
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`the light flux from the light source (a circular shape) to “match” the shape of the
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`“liquid crystal surface” (a rectangular shape). See id. at [0007], [0012], [0020], Fig.
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`1. As further discussed below, a POSITA would have understood the “rod
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`integrator” of Uehara to be the claimed “light tunnel” in the ‘347 patent. See Ex.
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`1003 at ¶¶ 58-60. Uehara further discloses using “the condenser lens 7 and the
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`15
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`field lens 9” to “enlarge[]” (i.e., magnify) the light flux exiting the “rod integrator,”
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`Inter Partes Review
`United States Patent No. 7,688,347
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`so as to “form an image…on the liquid crystal surface 10 with an accurately
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`matched shape and size…” See id. at [0022], [0026], Fig. 1.
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`As detailed herein, Uehara, in view of the knowledge of a POSITA, at
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`minimum renders obvious each of the Challenged Claims based on the disclosures
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`identified below. See Ex. 1003 at ¶¶ 47-84, 122.
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`2.
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`Uehara in View of the Knowledge of a POSITA Renders
`Obvious Claim 1
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`To the extent that the preamble—“A display system”—is considered a
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`limitation of Claim 1, Uehara discloses this element. See Ex. 1003 at ¶ 52. For
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`example, Uehara discloses a “light source apparatus for use in a liquid crystal
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`projector, a projector, an overhead projector, or the like.” See, e.g., Ex. 1004 at
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`[0001], Fig. 1. A POSITA would have understood the system disclosed in Uehara,
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`as shown in e.g., Fig. 1, is a display system as it includes the basic elements of a
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`display system (as further discussed in connection with the claim elements below),
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`such as a “light source 1,” illumination optics such as “condenser lens 7 and the
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`field lens 9,” a “liquid crystal surface 10,” “projection lens 11,” and “a screen (not
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`shown)” where the image is projected for display. See Ex. 1004 at Fig. 1, [0026];
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`Ex. 1003 ¶ 52; discussion, infra.
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`JP H05-72628 (“Uehara”)
`Claim 1
`1. A display Uehara discloses a display system (e.g., “light source apparatus
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`16
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`Inter Partes Review
`United States Patent No. 7,688,347
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`
`
`Claim 1
`system,
`comprising:
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`JP H05-72628 (“Uehara”)
`for use in a liquid crystal projector, a projector, an overhead
`projector, or the like”). See, e.g., Ex. 1004 at [0001], Fig. 1; see
`also id. at [0026].
`
`“[Industrial Field of Application] The present invention relates to a
`favorable light source apparatus for use in a liquid crystal projector, a
`projector, an overhead projector, or the like.” Id. at [0001].
`
`
`Uehara further discloses Element [1-1] of Claim 1, which recites “a light
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`source.” See Ex. 1003 at ¶ 53. For example, Uehara discloses “a light source
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`constituted by a metal halide lamp.” See, e.g., Ex. 1004 at [0016], Fig. 1.
`
`Claim 1
`[1-1] a light
`source;
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`JP H05-72628 (“Uehara”)
`Uehara discloses a light source (e.g., “light source” such as “a
`metal halide lamp”). See, e.g., EX1004 at [0016], Fig. 1.
`
`“In this figure, 1 indicates a light source constituted by a metal
`halide lamp. This light source 1 is a discharge lamp having two
`electrodes placed on an optical axis, and has an annular light
`distribution characteristic with an angle of approximately 30° to 150°
`relative to the optical axis. Specifically, the light source 1 does not
`emit light flux at a solid angle of ±30° rearward of the optical axis or
`at a solid angle of ±30° forward of the optical axis, an opening is
`provided in the central portion (intersection with the optical axis) of a
`below-described elliptical mirror 2, and the light source 1 is supported
`by a support member (not shown) that is inserted through the
`opening.” Id. at [0016].
`
`Uehara further discloses Element [1-2] of Claim 1, which recites “an
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`electronic image-forming element capable of having an image formed thereon.”
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`See Ex. 1003 at ¶¶ 54-57. For example, Uehara discloses a “liquid crystal surface”
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`capable of having an “image” formed thereon, which a POSITA would have
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`17
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`
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`understood to be the claimed “image-forming element.” See, e.g., Ex. 1004 at
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`Inter Partes Review
`United States Patent No. 7,688,347
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`[0026] (“[T]he liquid crystal surface 10 is projected onto a screen (not shown)
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`by a projection lens 11.”); [0001], Ex. 1003 at ¶¶ 54-55; see also id. at [0007],
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`[0022], [0027], Fig. 1. In addition, Uehara discloses that a “liquid crystal surface”
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`is “a rectangle that has a length-to-width ratio of 4:3 in the case of an ordinary TV
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`image and 16:9 in the case of a high-definition image.” Ex. 1004 at [0007]. A
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`POSITA would have also understood the “liquid crystal surface” of Uehara to be
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`electronic because Uehara discloses that it is used in, e.g., “liquid crystal projector,
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`a projector, an overhead projector, or the like” (Ex. 1004 at [0001]), which are
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`well-known to be electronic systems. See Ex. 1003 at ¶ 56. The ‘347 patent
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`similarly discloses that the “image-forming element” can be a liquid crystal display.
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`See Ex. 1001 at 53:13-14 (describing “image-forming element (such as an LCD)”).
`
`Claim 1
`[1-2] an
`electronic
`image-
`forming
`element
`capable
`of having
`an image
`formed
`thereon;
`
`JP H05-72628 (“Uehara”)
`Uehara discloses an electronic image-forming element (e.g., “a
`liquid crystal surface”) capable of having an image formed thereon.
`See, e.g., Ex. 1004 at [0001], [0026], [0007]; see also id. at Pg. 1
`[Configuration], [0003], [0022], Fig. 1.
`
`“The present invention relates to a favorable light source apparatus for
`use in a liquid crystal projector, a projector, an overhead projector, or
`the like.” Id. at [0001].
`
`“Accordingly, the light flux that exits the exit end surface 6 has been
`converted into a shape similar to the liquid crystal surface 10, and
`since this light flux exits at the same angle as the angle of incidence on
`the entrance end surface 4, it spreads out uniformly while maintaining
`its rectangular shape. This exiting light flux is adjusted by the
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`Claim 1
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`Inter Partes Review
`United States Patent No. 7,688,347
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`JP H05-72628 (“Uehara”)
`condenser lens 7 and the field lens 9 so as to form an image of the exit
`end surface 6 on the liquid crystal surface 10 with an accurately
`matched shape and size, and is then projected onto a screen (not
`shown) by the projection lens 11.” Id. at [0026].
`
`“(3) The shape of the liquid crystal surface 43 is a rectangle that has a
`length-to-width ratio of 4:3 in the case of an ordinary TV image and
`16:9 in the case of a high-definition image. In contrast, the light flux
`from the light source 42 is circular, and therefore th