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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DEPARTMENT OF JUSTICE,
`Petitioner,
`
`v.
`
`IRIS CORPORATION BEHRAD,
`Patent Owner.
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`
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`
`
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`
`
`Case IPR2016-00497
`Patent 6,111,506 B2
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`
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`EXPERT DECLARATION OF HENRY N. DREIFUS
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`TABLE OF CONTENTS
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`
`I.
`
`INTRODUCTION ........................................................................................... 1
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`II.
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`BACKGROUND AND QUALIFICATIONS ................................................. 1
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`III. MATERIALS REVIEWED ............................................................................ 4
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`IV. DESCRIPTION OF ISSUES ........................................................................... 7
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`V.
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`PERSON OF ORDINARY SKILL IN THE ART .......................................... 9
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`VI. THE ‘506 PATENT ....................................................................................... 11
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`VII. CLAIM CONSTRUCTION .......................................................................... 13
`
`A.
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`“integrated circuit” .............................................................................. 14
`
`B.
`
`"sheet of base material" ....................................................................... 18
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`VIII. THE RF TAG DISCLOSED IN MOSKOWITZ DOES NOT TEACH
`OR SUGGEST A MICROPROCESSOR ...................................................... 22
`
`IX. A POSITA WOULD NOT BE MOTIVATED TO COMBINE THE
`MOSKOWITZ AND TAKAHIRA REFERENCES ..................................... 29
`
`X. A POSITA WOULD NOT BE MOTIVATED TO COMBINE THE
`HOREJS AND MOSKOWITZ REFERENCES ........................................... 34
`
`A.
`
`B.
`
`C.
`
`The Proposed Combination Would Prevent the RF Tag of
`Moskowitz From Achieving Its Intended Purpose ............................. 35
`
`The Proposed Combination Would Change the Principle of
`Operation of the RF Tag of Moskowitz .............................................. 38
`
`The Proposed Combination Is Taught Away From By
`Moskowitz ........................................................................................... 40
`
`XI. THE COMBINATION OF MOSKOWITZ, TAKAHIRA, AND
`OSHIKOSHI .................................................................................................. 42
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`XII. THE COMBINATION OF MOSKOWITZ, OSHIKOSHI, AND
`IRWIN ........................................................................................................... 54
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`XIII. CONCLUSION .............................................................................................. 56
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`I.
`
`I, Henry N. Dreifus, declare as follows:
`
`INTRODUCTION
`1. My name is Henry N. Dreifus. I am over eighteen years of age and
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`am competent to make this declaration, which I submit on behalf of Patent Owner,
`
`IRIS Corporation Berhad (“IRIS”).
`2.
`
`I have been retained on behalf of IRIS (“Patent Owner”) as an
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`independent expert consultant in this Inter Partes Review (“IPR”) of U.S. Patent
`
`No. 6,111,506 to Yap et al. (“the ’506 patent”).
`II. BACKGROUND AND QUALIFICATIONS
`3.
`
`I am the Founder and Managing Director of Dreifus Associates,
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`Limited (DAL), an Identity Technology and Personnel Assurance Solutions
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`Development and Integration organization established in 1991.
`4.
`
`I received a Bachelor of Science in Computer Science and
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`Engineering from the Moore School of Engineering at the University of
`
`Pennsylvania in 1982. I was a member of the Engineering Student Council and the
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`chapter chairman of the Association of Computing Machinery (ACM).
`5.
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`I received a Master of Business Administration degree from
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`Washington University in St. Louis in 1988. I was a member of the Beta Gamma
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`Sigma Honor Society.
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`I have more than 25 years of experience in the advanced card
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`
`
`
`6.
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`technology industry, including extensive work developing systems and devices for
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`magnetic, optical, and smart card technologies for financial, identification, security,
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`consumer marketing, and information applications.
`7.
`8.
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`I was a founding director of the Smart Card Industry Association.
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`I have served as a delegate to both the International Standards
`
`Organization (ISO) and the American National Standards Institute (ANSI). In this
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`capacity, I aided in the establishment of worldwide standards for smart cards.
`9.
`
`I have served as a recognized worldwide advisor in the card
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`technology industry and in the application of enabling technologies to solve
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`business problems.
`10. My experience in smart card-based solutions includes consulting and
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`advisory work for parties in the financial transaction and identification solutions
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`supply chain, including card manufacturers, system component manufacturers, and
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`system operators (including sovereign governments). My clients have included
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`American Express, MasterCard International, Rand McNally Corporation, Visa,
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`Arthur Blank & Company, the United States Department of Defense, and AT&T.
`
`11. During my more than 25 years of industry experience, I have been
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`involved in the development of many security identification devices, and am well-
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`versed in the types of security features that are included in such products.
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`12.
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`I have served as a senior project advisor and consultant in the
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`development of need assessments and specifications for large-scale identification
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`card programs and solutions, including the following.
`x The United States Department of Defense Common Access Card
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`
`
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`(CAC) Military and Civilian Geneva Conventions ID Card (which
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`serves as a basis for all Federal ID Cards issued to federal employees
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`and contractors across the U.S. Government)
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`x The National ID Card program (NIDS) for the Country of Jamaica
`x The National ID Card program (MPID) for the Organization of
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`Eastern Caribbean States (OECS)
`x The National ID Card program for the Sultanate of Oman
`13. My responsibilities in connection with these large-scale identification
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`card programs
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`included developing
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`identity security document and card
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`specifications, drafting the technical portions of the Request For Proposals,
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`participating in the evaluations of the proposals, supporting the conformance
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`review of the identification card specifications, supporting acceptance testing, and
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`supporting installation and implementation of finished solutions.
`14. My experience has also included supporting the development of a
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`needs assessment and
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`the detailed design
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`for
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`internationally-accepted,
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`interoperable, and secure citizen’s identification documents to enable multiple
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`countries participating in an economic union to identify and provide common
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`services to citizens across sovereign countries, including border crossing, social
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`security, healthcare, driving, and voting identification.
`15.
`
`I am the sole inventor of a patent on advanced smart cards and
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`portable electronic transaction technology that issued in 1986. This patent is
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`directed to a secure portable electronic financial transaction card.
`
`16.
`
`I am a co-author of the book Smart Cards: A Guide to Building and
`
`Managing Smart Card Applications, published by John Wiley & Sons in 1998.
`17. My curriculum vitae, which is attached to my Declaration, provides
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`more detail of my work in these fields. (Exhibit 2016).
`18.
`
`I am being compensated for my services in this case at my consulting
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`rate of $400 per hour. My compensation is not dependent on the outcome of this
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`proceeding, and I have no other interest in this proceeding.
`III. MATERIALS REVIEWED
`19.
`In forming my opinions, I have reviewed the following.
`x Exhibit 1001: the ’506 patent
`
`x Exhibit 1002: File History for the ‘506 patent
`
`x The Petition for Inter Parties Review of U.S. Patent No 6,111,506
`filed by the DOJ
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`x Decision to Institute Inter Parties Review dated July 25, 2016
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`
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`x Exhibit 1029: Substitute Expert Declaration of Gilles Lisimaque
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`x Exhibit 1030: Substitute Expert Declaration of Gerald Smith
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`x Exhibit 1003: U.S. Patent No. 5,528,222 to Moskowitz et al.
`x Exhibit 1027: U.S. Patent No. 5,337,063 to Takahira
`
`x Exhibit 1004: U.S. Patent No. 5,106,719 to Oshikoshi et al.
`
`x Exhibit 1005: U.S. Patent No. 5,581,445 to Horejs, Jr. et al.
`x Exhibit 1013: U.S. Patent No. 5,457,747 to Drexler et al.
`
`x Exhibit 1015: Canadian Patent Application No. 2,091,109 to Irwin
`
`x Exhibit 1023: INTERNATIONAL ORGANIZATION FOR
`STANDARDIZATION (ISO)/IEC No. 7816-1:1987 (Identification
`cards – Integrated circuit(s) cards with contacts - Physical
`Characteristics)
`
`x Exhibit 1024: INTERNATIONAL ORGANIZATION FOR
`STANDARDIZATION (ISO)/IEC No. 7810:1996 (Identification
`cards - Physical characteristics)
`
`x Exhibit 1028: Excerpts from Motorola 1992 textbook
`
`x Exhibit 2017: U.S. Patent No. 5,071,825 to Iiyama et al.
`
`x Exhibit 2018: http://www.rsc.org/education/eic/issues/2009Jan/
`printing-plastic-dye-polymer.asp (dye diffusion thermal transfer, or
`D2T2, printing)
`
`x Exhibit 2019: http://www.functionalmaterials.com/icma-annual-card-
`manufacturing-expo-in-hollywood-florida (Presentation on Receptor
`Coatings for the Manufacture & Personalization of Cards)
`
`x Exhibit 2020: The Polaroid Security Card: An unalterable success
`story, CC-20508X-0, PID#1AM912A, Polaroid, October 1998
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`x Exhibit 2021 "Smart Card Content Security: Defining 'tamperproof'
`for portable smart media," S. Zanero, Dipartimento di Elettronica e
`Informazione, Politecnico di Milano, Version 1.0
`x Exhibit 2022: mifare: Standard Card IC, MF1 IC SC50 Product
`Specification, Rev. 4.0, Philips Semiconductors, July 1998
`
`x Exhibit 2023: Security and Chip Card IC’s: SLE 4406/06E, Short
`Product Information, Ver. 07.99, Infineon Technologies AG, 1999
`
`x Exhibit 2024: Microcomputer Systems: The 8086/8088 Family
`(Architecture Programming, and Design), 2d Ed., Y. Liu et al.,
`Prentice-Hall, 1986, pp. 1-6
`
`
`
`
`
`
`
`x Exhibit 2025: Computer Architecture and Organization, 2d Ed., J.
`Hayes, McGraw-Hill, 1988, pp. 1-3, 57-72, and 79-80
`
`
`
`x Exhibit 2026: Smart Cards: A Case Study, J. Ferrari et al., IBM Corp.,
`1st Ed., October 1998
`
`x Exhibit 2027: INTERNATIONAL ORGANIZATION FOR
`STANDARDIZATION (ISO)/IEC No. 14443-1:Final Committee
`Draft, 1997 (Identification cards - Contactless integrated circuit(s)
`cards - Proximity cards, Part 1: Physical characteristics)
`
`x Exhibit 2028: Smart Card Technology: Past, Present, and Future, L.
`Mohammed, International Journal of the Computer, the Internet and
`Management, Vol. 12, No. 1, January-April 2004, pp. 12-22
`x Exhibit 2029: Design Principles for Tamper-Resistant Smartcard
`Processors, O. Kommerling et al., Proceedings of the USENIX
`Workshop on Smartcard Technology (Smartcard '99), Chicago,
`Illinois, May 10-11, 1999, pp. 9-20
`20. My opinions in this declaration are based on these materials that I
`
`reviewed, my knowledge of the subject matter, my years of experience, my
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`expertise in the fields of smart cards and electronic security documents, and my
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`professional judgment. Further, my opinions are based on the information and
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`evidence in my possession up to the date of this declaration. I reserve the right to
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`supplement or amend my opinions as any new facts or issues arise in this IPR.
`IV. DESCRIPTION OF ISSUES
`21.
`
`I understand that in this IPR, the Petitioner, the U.S. Department of
`
`Justice ("DOJ"), contends that all claims of the ‘506 patent are unpatentable and
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`that, therefore, the patent is invalid. In response, the patent owner, IRIS, contends
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`that the ‘506 patent is valid.
`22.
`
`I have been asked by Patent Owner to act as an expert witness in this
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`IPR. Specifically, I have been asked by Patent Owner to provide my own opinion
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`as to whether the combinations of certain references described below would have
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`made the invention recited in the claims of the ’506 patent obvious to a POSITA at
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`the time of invention.
`23.
`
`I understand that obviousness may be based on the prior art and that
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`determining obviousness requires consideration of whether two or more pieces of
`
`prior art could be combined, or whether a single piece of prior art could be
`
`modified, to produce the claimed invention. I also understand, however, that
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`obviousness requires more than showing that each reference together would cover
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`each limitation of the claims.
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`I understand that the obviousness analysis must be made from the
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`
`
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`24.
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`perspective of a person of ordinary skill in the art (“POSITA”) at the time of filing
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`the patent application and that it is inappropriate to rely on hindsight to arrive at a
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`given combination of prior art elements.
`25.
`
`I understand that four factual issues are relevant to nonobviousness:
`
`(a) the scope and content of the prior art; (b) the level of ordinary skill in the field
`
`of the invention at the time of the invention; (c) the differences between the
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`claimed invention and the prior art; and (d) the presence of certain objective,
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`secondary considerations of non-obviousness, such as commercial success, long-
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`felt but unmet need, and evidence of failure of others.
`26.
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`I understand that a claimed invention is obvious if the differences
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`between it and the prior art are such that the subject matter as a whole would have
`
`been obvious at the time the invention was made to a POSITA. Obviousness
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`requires that a POSITA must have selected and combined the elements found in
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`the prior art in the normal course of research and development to produce the
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`claimed invention. A POSITA must base the modification or combination of
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`references on evidence. Evidence considered in an obviousness inquiry consists of
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`literal teachings, suggestions from the prior art, and/or motivations from the store
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`of common knowledge, flexibly viewed and applied.
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`I understand that an invention is not obvious if a POSITA would not
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`
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`27.
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`select and combine prior art references to reach the claimed method or device. The
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`prior art must collectively guide a POSITA toward a particular solution. Vague
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`guidance will not suffice. I understand that an invention is not obvious to try if the
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`prior art provides no indication of the critical parameters or which possible choices
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`are likely to be successful.
`28. Counsel for Patent Owner has informed me that the ’506 patent has a
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`priority date of Oct. 15, 1996. Accordingly, I treat Oct. 15, 1996 as the relevant
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`date to evaluate a POSITA’s understanding – including the state of the art at the
`
`time – and to inform my opinions.
`V.
`
`PERSON OF ORDINARY SKILL IN THE ART
`29. Counsel for Patent Owner has informed me that I should consider the
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`following factors to determine the POSITA: (a) problems encountered in the art;
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`(b) prior art solutions to those problems; (c) rapidity with which innovations are
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`made; (d) sophistication of the technology; and (e) educational level of active
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`workers in the field.
`30. The security identification document industry is a unique and discrete
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`field that provides products and services for designing, developing, and
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`manufacturing credentials that are used to identify people and things. The purpose
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`of a security identification document is inherently to provide to a relying third
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`party some level of assurance that the individual or thing being represented is
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`authentic.
`31. Such security identification documents, due to their purpose and how
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`they are utilized, require methods and mechanisms over and above non-security
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`documents in order to provide additional assurance to the relying third party that
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`the security identification document is authentic, not altered, and not counterfeit.
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`Whilst nothing is 100% fool-proof, security identification documents incorporate a
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`number of ever improving features that provide a threshold of confidence that each
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`document is valid and real. Such methods include specialized manufacturing and
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`printing methods and features, as well as incorporating electronic components such
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`as integrated circuits, all of which provide additional measures of assurance.
`32.
`
`In my opinion, a POSITA at the time of invention is a person with a
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`Bachelor of Science degree in electrical or computer engineering or computer
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`science (or similar field), and at least two years of work experience in the fields of
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`security identification documents and integrated circuit cards and smart cards.
`33.
`
`ISO/IEC 7816 as it existed on October 14, 1996 is an international
`
`standard relating to electronic identification cards with contacts, while the ‘506
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`Patent is directed to an improved security identification document that includes a
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`contactless communication insert unit and methods for making the same.
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`VI. THE ‘506 PATENT
`34. The ’506 patent issued on August 29, 2000 from U.S. Patent
`
`
`
`
`Application No. 08/950,057, which was filed on October 14, 1997 and claims
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`priority from U.S. Provisional Patent Application No. 60/028,351, which was filed
`
`on October 15, 1996.
`35.
`
`I understand that all claims of the ‘506 patent have been challenged in
`
`this IPR and alleged to be unpatentable as obvious.
`36.
`
`In general, the ‘506 patent describes an improved electronic security
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`identification document that transmits data without the need for galvanic contacts.
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`The device includes a microprocessor coupled to a coil (antenna) that provides
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`both contactless communications and an induced power source when the device is
`
`operating. Encryption is used to protect the stored data.
`37. The ‘506 patent further
`
`teaches
`
`that
`
`the
`
`improved security
`
`identification document has a sturdy multi-layer construction. This is especially
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`important because a security identification document such as a passport can have a
`
`long anticipated lifetime, such as 10 years. The construction features include a
`
`rigid cover and stitching.
`38.
`
`I understand that the claims of the patent define the scope of
`
`invention. Claim 1, which is set forth below, is directed to a method of making an
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`identification document.
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`1.
`
`A method of making an identification document comprising the
`
`steps of:
`
`
`
`forming a contactless communication insert unit by electrically
`
`connecting an integrated circuit including a microprocessor, a
`
`controller, a memory unit, a radio frequency input/output device and
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`an antenna, and disposing a metal ring to surround the integrated
`
`circuit;
`
`
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`disposing the contactless communication insert unit on a
`
`substrate and laminating it to form a laminated substrate;
`
`
`
`
`
`
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`supplying a first sheet of base material;
`
`supplying a second sheet of base material;
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`disposing the second sheet of base material on top of the first
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`sheet of base material and inserting the laminated substrate including
`
`the contactless communication insert unit between the first and second
`
`sheets of base material; and
`
`
`
`joining a third sheet of base material to the first and second
`
`sheets of base material having the laminated substrate disposed
`
`therebetween, the third sheet of base material containing printed text
`
`data located so as to be readable by humans.
`
`
`
`39. Claim 2, which depends from claim 1, requires that the method further
`
`includes attaching a cover page to the third sheet of base material.
`40. Claim 4, which also depends from claim 1, similarly requires that the
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`method further includes joining a cover comprising a relatively rigid material
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`compared to the first, second and third sheets of base material to the first, second
`
`and third sheets of base material for supporting the integrated circuit.
`41. Claim 3, which depends from claim 2, requires that the third sheet of
`
`base material containing the printed text data is joined to the cover page and the
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`second sheet of base material via tamper-proof stitching.
`42. Claim 5, which depends from claim 1, requires that the memory unit
`
`includes memory for storing biometrics data and memory for storing non-
`
`biometrics data, with the memory for storing biometrics data including multiple
`
`memory locations which can only be written to once and prevent the stored data
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`from ever being altered, and the memory for storing non-biometrics data including
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`memory locations which are capable of being altered.
`43. Claim 6, which depends from claim 5, further requires that the
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`biometrics data includes at least one of: a still photograph, moving video images, a
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`palm print, fingerprints, a retina scan, a voice print, a two-dimensional facial image,
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`and a three-dimensional facial image.
`44. Claim 7, which depends from claim 6, further requires that data stored
`
`in the memory unit is encrypted.
`VII. CLAIM CONSTRUCTION
`45.
`
`I have been advised that the first step of assessing the validity of a
`
`patent claim is to interpret or construe the meaning of the claim.
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`I have been advised that in this IPR before the U.S. Patent and
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`
`
`
`46.
`
`Trademark Office, a patent claim receives the broadest reasonable construction in
`
`light of the specification of the patent in which it appears. I have also been advised
`
`that, at the same time, claim terms are given their ordinary and accustomed
`
`meaning as would be understood by a POSITA at the time of invention. I have
`
`followed these principles in my analysis.
`47.
`
`I agree that in this case, there is no reason to depart from the ordinary
`
`and customary meaning of the claim terms as would be understood by a POSITA
`
`at the time of invention. I provide the following on two terms at issue, “integrated
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`circuit” and “sheet of base material,” to demonstrate how the ordinary and
`
`customary meaning of these terms would be understood by a POSITA at the time
`
`of the invention.
`A.
`“integrated circuit”
`48. Claim 1 of the ‘506 Patent recites “forming a contactless insert unit by
`
`electrically connecting an integrated circuit including a microprocessor, a
`
`controller, a memory unit, a radio frequencies input/output device, and an antenna.”
`49.
`
`I believe a POSITA would understand the proper construction of this
`
`clause as “forming a contactless insert unit by electrically connecting an integrated
`
`circuit including a microprocessor, a controller, a memory unit, a radio frequency
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`input/output device to or with an antenna.”
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`50. The plain language of the claims supports this construction. Claim 1
`
`recites “forming a contactless insert unit,” and then recites “electrically connecting”
`
`components. By definition, this requires multiple components to be electrically
`
`connect with one another, which in the claim is identified by the conjunction “and.”
`
`A POSITA would understand that an integrated circuit includes integrated circuit
`
`components, so in the claim language “an integrated circuit including a
`
`microprocessor, a controller, a memory unit, a radio frequency input/output device.”
`
`Each of these are known microchip components, so by definition components of an
`
`integrated circuit. A POSITA would also understand that an integrated circuit does
`
`not necessarily include an antenna, and would therefore interpret the claim in
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`accord with the clause’s grammatical construction as “electrically connecting an
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`integrated circuit…and an antenna.”
`51. The specification of the ‘506 Patent supports this construction:
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`Embedded within the substrate 12 is an integrated circuit IC including a
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`microcontroller 14 such as a known microprocessor, central processing unit
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`or other suitable device disposed thereon. As is well known, the
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`microprocessor 14 includes memory and is programmable and capable of
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`receiving, storing, retrieving and transmitting data….
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`…
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`The document 10 also includes an input/output interface device (I/O device)
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`16 preferably in the form of a known radio frequency interface input/output
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`chip including suitable signal processing electronic components and
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`circuitry. The I/O device 16 is connected to the microcontroller 14 so as to
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`receive and transmit signals to and from the microcontroller.
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`…
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`The microprocessor 14 and I/O device 16 of the integrated circuit are
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`preferably in the form of electronic component chips, such as well known
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`silicon chips which are capable of receiving, storing and transferring data
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`using known contactless communication protocols such as radio frequency
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`transmission and reception communication protocols. (Exhibit 1001 at
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`12:36-13:16).
`52. The specification expressly states “the integrated circuit including a
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`microcontroller 14 such as a known microprocessor,” and “[t]he microprocessor 14
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`and I/O device 16 of the integrated circuit are preferably in the form of electronic
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`component chips.” The antenna is not part of the microprocessor/microcontroller
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`chip described in the specification.
`53. Nor is the antenna part of the I/O device. The antenna is instead
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`“disposed in the substrate 12 such that the I/O device 16 connects the antenna 18 to
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`the microprocessor 14,” and “the antenna 18 receives electrical signals preferably
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`in the form of radio waves…. in a contactless manner, i.e. there is no galvanic
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`contact, between the primary coil and the antenna 18. Upon receiving the signals,
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`the antenna 18 is energized and then transmits the received signals to the I/O
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`device 16.” Thus, the antenna is not a chip or other electronic integrated circuit
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`component and is “electrically connected” to the integrated circuit components of
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`claim 1.
`54. Thus, a POSITA would interpret “an integrated circuit including a
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`microprocessor, a controller, a memory unit, a radio frequency input/output device,”
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`as reciting the electronic component chip(s) of an integrated circuit (likely
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`application specific integrated circuit such as an integrated circuit for an RFID tag),
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`and not as including an antenna.
`55. The prosecution history also supports this construction. In an Office
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`Action, the Examiner rejected original claims 1-2 and 5 as obvious over
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`Moskowitz and another patent. In the rejection, the Examiner admitted that
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`Moskowitz did not show “the claimed microprocessor and controller in the
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`integrated circuit.” The Examiner stated: Moskowitz “teaches the use of a logic
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`unit along with a memory unit, a radio frequency input/output device in an
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`integrated circuit 210 and an antenna….” The Examiner alleged that it would be
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`obvious to “provide for the controlling and processing functions of the logic unit
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`… a well known microprocessor and controller combination can be used in the
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`integrated circuit to implement the logic unit.”
`56. Thus, when
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`the Examiner applied
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`the broadest
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`reasonable
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`construction as informed by the specification as required, he interpreted the claim
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`language such that the “microprocessor and controller combination,” and “a
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`memory unit, a radio frequency input/output device” were “in an integrated circuit
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`210” as distinct from “an antenna.” Thus, the Examiner interpreted the claim
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`language “forming a contactless insert unit by electrically connecting an integrated
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`circuit including a microprocessor, a controller, a memory unit, a radio frequency
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`input/output device, and an antenna….” in accord with the construction: “forming
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`a contactless insert unit by electrically connecting an integrated circuit including a
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`microprocessor, a controller, a memory unit, a radio frequency input/output device
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`to or with an antenna.”
`B.
`57.
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`"sheet of base material"
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`Independent claim 1 of the '506 Patent is directed to making an
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`identification document and recites "supplying a first sheet of base material,"
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`"supplying a second sheet of base material," and "disposing the second sheet of
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`base material on top of the first sheet of base material." Claim 1 further recites
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`"joining a third sheet of base material to the first and second sheets of base
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`material," with "the third sheet of base material containing printed text data."
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`'506 Patent is directed to making an improved security
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`58. The
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`identification document. The specification explains that a "security identification
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`document" is "a personal identification document such as a passport, visa, driver's
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`license, a frequent traveler's card, a worker's identification card, a social security
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`card, a healthcare card, land title document, ATM card, credit card, phone card,
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`welfare recipient card, green card, gun permit and registration card, an object or
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`luggage identification document or a travel authorization document." (Exhibit
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`1001 at 1:28-36).1 These enumerated examples, along with the claims and the
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`entire Detailed Description section of the specification, make it clear that the '506
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`Patent is directed to producing a security identification document that includes
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`printed information.
`59. The process of manufacturing a printed security identification
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`document generally involves applying one or more coatings. In the manufacturing
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`process, a "coating" is often applied to the surface of a layer (or "substrate") that is
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`to receive printed text or image information. More specifically, a coating process
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`is performed to apply a thin film of a coating material to a substrate material such
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`1 See also id. at 4:10-24 (the "security identification document" is in the form of a "suitable
`personal or object identification document" or "suitable identification document for use with a
`person or an object security and verification system").
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`as paper, plastic, fabric, film, foil, or sheet stock. (See Exhibit 2017 at 1:67-2:4).2
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`Examples of such coatings include an adhesive layer for attaching the substrate to
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`an object, and an ink layer for printing information on the substrate.
`60.
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`In the specific field of printing, the substrate is the material to which a
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`thin film of ink is applied. This substrate material is commonly called the "base
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`material." (See Exhibit 2020 (“printing on the base material”)). Further, this
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`substrate material is frequently in the form of individual pages of paper or paper-
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`like material that are known as "sheets." Thus, in the field of printing, the substrate
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`being printed upon is generally a piece of paper or similar material, and such a
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`substrate is commonly referred to as a "sheet of base material."
`61. Thus, a POSITA, who has knowledge and experience in field of
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`making security identification documents containing printed information, would
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`understand the plain meaning of a "sheet of base material" to be a she