Paper No. __
`Filed: July 20, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`UUSI, LLC d/b/a NARTRON
`Patent Owner
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`____________________
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`Case IPR2016-00908
`Patent No. 5,796,183
`____________________
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`DECLARATION OF DR. DARRAN CAIRNS
`IN SUPPORT OF PATENT OWNER PRELIMINARY RESPONSE
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`I.
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`TABLE OF CONTENTS
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`INTRODUCTION ......................................................................................... 1
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`II. BACKGROUND AND QUALIFICATIONS .............................................. 1
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`III. MATERIALS REVIEWED .......................................................................... 3
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`IV. PERSON OF ORDINARY SKILL IN THE ART ...................................... 4
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`V. OVERVIEW OF THE ’183 PATENT ......................................................... 5
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`VI. PROPER CLAIM CONSTRUCTION ......................................................11
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`VII. REFERENCES RELIED ON BY PETITIONER ....................................24
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`A.
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`B.
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`Ingraham I and II ..............................................................................24
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`Caldwell ...............................................................................................28
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`C. Gerpheide ............................................................................................35
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`VIII. GROUND I ...................................................................................................37
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`A. Claim 37 ..............................................................................................37
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`1.
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`2.
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`3.
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`4.
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`Claim Elements 37(b) and (c) ................................................37
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`Claim Element 37(d) ...............................................................41
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`Claim Element 37(e) ...............................................................46
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`Claim Elements 37(f), 37(g), and 37(h) .................................48
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`B. Claim 40 ..............................................................................................51
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`1.
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`2.
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`3.
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`4.
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`5.
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`Claim Element 40(b) ...............................................................51
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`Claim Elements 40(c), (d), and (e) .........................................51
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`Claim Elements 40(f) and (g) .................................................52
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`Claim Element 40(h) ...............................................................52
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`Claim Element 40(i) ................................................................53
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`Independent Claim 61 .......................................................................54
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`Independent Claim 83 .......................................................................54
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`Independent Claim 94 .......................................................................55
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`Dependent Claims 41, 43, 45, 64-67, 69, 85, 86, 88, 90, 91, 96, 97,
`99, 101, 102 .........................................................................................55
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`C.
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`D.
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`E.
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`F.
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`IX. GROUND II .................................................................................................56
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`A. Claims 47, 48, 62, 63, and 84. ...........................................................56
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`X. MOTIVATION TO COMBINE AND REASONBLE LIKELIHOOD
`OF SUCCESS ...............................................................................................57
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`A. No Motivation to Combine ...............................................................57
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`B. No Likelihood of Success ..................................................................59
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`XI. CONCLUSION ............................................................................................59
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`I, Darran Cairns, declare as follows:
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`I.
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`INTRODUCTION
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`1.
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`I have been retained by UUSI, LLC d/b/a/ Nartron (“Patent Owner” or
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`“Nartron”) as an independent expert consultant in this proceeding before the Patent
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`Trial and Appeal Board (“PTAB” or “Board”).
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`2.
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`I am being compensated at a rate of $490/hour for my work. I have
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`no other interest in this proceeding.
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`3. My compensation is in no way contingent on the nature of my
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`findings, the presentation of my findings in testimony, or the outcome of this
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`proceeding.
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`4.
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`I have been asked to consider the allegations made in the Petition for
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`Inter Partes Review of U.S. Patent No. 5,796,183 (“the ’183 Patent”) (the
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`“Petition”), the declaration of Dr. Subramanian in support of that Petition, and the
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`asserted prior art. My opinions are set forth below.
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`II. BACKGROUND AND QUALIFICATIONS
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`5.
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`I am the CEO of Tailored Surfaces, a technology development and
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`consulting company focused on functional coatings for the technology industry,
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`and an Adjunct Associate Professor of Mechanical and Aerospace Engineering at
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`West Virginia University, where I have served on the faculty since 2006. I was an
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`Associate Professor with Tenure at West Virginia University until August 2014.
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`6. My undergraduate degree in Physics (1995) and PhD in Materials
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`Science and Engineering (1999) are from the University of Birmingham in the
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`United Kingdom. From 1998 to 2001 I was a postdoctoral research associate in the
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`Display Laboratory at Brown University. During my time at the University of
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`Birmingham, I performed research related to optical fibers and optical fiber sensors
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`and worked closely with engineers at Pirelli Cables. During my time at Brown
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`University, I performed research on optoelectronic and display devices including
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`flexible electronics, conformable displays, encapsulated liquid crystal devices, and
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`touch sensors.
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`7.
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`At West Virginia University my research focused on the fabrication of
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`flexible electronic devices. My work was funded by both federal agencies,
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`including the National Science Foundation, NASA, the Air Force Office of
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`Sponsored Research, and the Department of Energy, and private companies,
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`including EuropTec USA, Grote Industries, Kopp Glass, Eastman Chemical and
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`Articulated Technologies. I have worked closely with engineers at each of these
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`companies and assisted them in developing and commercializing electronic devices
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`including electronic lighting for automotive use; and flexible backlights for
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`displays.
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`8.
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`In my own research program, I am developing patented technologies
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`on functional coatings for electronic and energy applications. I am a named
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`inventor on 11 issued U.S. patents in the field of touch sensors, displays, and liquid
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`crystal materials.
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`9.
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`Prior to joining the faculty at West Virginia University, I worked for
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`five years as a Research Specialist at 3M Touch Systems. My research there
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`focused on capacitive touchscreen applications. My work at 3M included the
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`development of patented and proprietary technologies on capacitive touch sensors.
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`10.
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`I am a member of the Society of Information Display (SID), the
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`Institute of Physics (IOP) and the American Society of Mechanical Engineers.
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`11. My students have been awarded prestigious fellowships for work
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`performed in my laboratory including NSF Graduate Fellowships (3 students),
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`NDSEG Fellowship (1 student) and the RUBY graduate Fellowship (1 student).
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`12. My curriculum vitae documents more than 79 scientific publications
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`in journals, books, and peer-reviewed conferences, as well as invited presentations
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`on my work in polymer materials for electronic devices and surfaces, and is
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`provided as Exhibit 2003.
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`III. MATERIALS REVIEWED
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`13.
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`I have reviewed the following materials for the purpose of preparing
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`this declaration: Petition of Inter Partes Review of U.S. Patent No. 5,796,183;
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`U.S. Patent No. 5,796,183 including reexamination certificates issued on April 29,
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`2013 and June 27, 2014 (Ex. 1001); declaration of Dr. Vivek Subramanian (Ex.
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`1002); Prosecution History of U.S. Patent No. 5,796,183 (Ex. 1004); Prosecution
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`History of Reexamination Control No. 90/012,439 (Ex. 1005); Prosecution History
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`of Reexamination Control No. 90/013,106 (Ex. 1006); U.S. Patent No. 5,087,825
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`to Ingraham (“Ingraham I”) (Ex. 1007); U.S. Patent No. 4,731,548 to Ingraham
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`(“Ingraham II”) (Ex. 1008); U.S. Patent No. 5,594,222 to Caldwell (“Caldwell”)
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`(Ex. 1009); U.S. Patent No. 4,758,735 to Ingraham (“Ingraham III”) (Ex. 1010);
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`U.S. Patent No. 5,565,658 to Gerpheide et al. (“Gerpheide”) (Ex. 1012); U.S.
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`Patent No. 5,341,036 to Wheeler et al. (“Wheeler”) (Ex. 1015); U.S. Patent No.
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`5,572,205 to Caldwell et al. (“Caldwell ’205”) (Ex. 1016 and 2006); U.S. Patent
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`No. 5,463,388 to Boie et al. (“Boie”); List of Patents and Applications Citing U.S.
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`Patent 5,796,183 (Ex. 2004); and Nartron “Industry Firsts” (Ex. 2005).
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`IV. PERSON OF ORDINARY SKILL IN THE ART
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`14.
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`I have been informed that factors relevant to determining the level of
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`ordinary skill may include: the educational level of the inventor; the type of
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`problems encountered in the art; the prior art solutions to those problems; the
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`rapidity with which innovations are made; the sophistication of the technology; and
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`the educational level of the active workers in the field. On this basis, one of
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`ordinary skill in the art of capacitive touch sensors would have had at least a
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`bachelor’s degree in physics or electrical engineering or equivalent industry
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`experience in the field.
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`V. OVERVIEW OF THE ’183 PATENT
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`15. The ’183 Patent, issued in 1998, is exemplary of the efforts Nartron
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`undertook as a pioneer in touchscreen technology. The ’183 Patent builds upon
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`and provides significant improvements over Ingraham I, Petitioner’s primary
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`reference, as well as Ingraham II and III. Filed over 20 years ago, the ’183 Patent
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`provides the foundation upon which today’s touch screen technology is built. See
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`Ex. 1014, at 1.
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`16. The ‘183 Patent has been cited at least 196 times by patents and patent
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`applications and is referenced in at least 148 issued US patents. See
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`https://patents.google.com/patent/US5796183A/en#citedBy. Many of these
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`patents are assigned to companies such as Cypress Semiconductor, Samsung
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`Electronics, Touchscreen Technologies Inc., Microsoft, Nokia and Intel. See Ex.
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`Ex. 2004.
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`17. The ’183 Patent issued on August 18, 1998 from an application filed
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`on January 31, 1996. The ’183 Patent has been reexamined twice. Ex. 1005-1006.
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`Three of the challenged claims, Claims 37, 38 and 39, were added during the first
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`reexamination. See Ex. 1001 at 35-36. The remainder of the challenged claims
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`were added during the second reexamination. See Ex. 1001 at 38-41. The ’183
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`Patent generally relates to a capacitive responsive electronic switching circuit
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`including an oscillator providing a periodic output signal, an input touch terminal
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`defining an area for an operator to provide an input by proximity and touch, and a
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`detector circuit coupled to the oscillator for receiving the periodic output signal
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`from the oscillator, and coupled to the input touch terminal. See, e.g., Ex. 1001,
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`’183 Patent, Abstract.
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`18. Capacitive sensors at the time of the invention (including the prior art
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`cited in the Petition) were largely limited to use in kitchen appliances such as
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`stoves and microwaves. Indeed, the filing date of the application (January 1996)
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`predates the release of the widely used Palm Pilot 1000 in March 1996. The touch
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`screen interface for the Palm Pilot was a relatively crude resistive touch sensor that
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`was not capable of multi touch input.
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`19.
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`In early 1996 when the application from which the ‘183 Patent issued
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`was filed, due to physical space constraints, there was a drive to make capacitive
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`touch keypads smaller and smaller while increasing the number of touch terminals
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`on the keypad. Yet, a substantial barrier existed in that the more densely the touch
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`terminals were spaced and the smaller the touch terminals became, the greater the
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`risk of coupling adjacent touch terminals, resulting in multiple actuations of touch
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`terminals or keys where only a single one is desired. This problem is described in
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`the specification of the ‘183 Patent. See Ex. 1001 at 3:64-4:8.
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`20. At the time, the only way that was known to put touch pads as closely
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`together as possible was to use physical structures to prevent inadvertent actuation
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`of adjacent touch pads or cross talk. These physical structures included guard
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`rings, guard bands, or a combination of electrodes with opposing electric fields
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`(collectively referred to as “guard rings”) included as a part of each touch terminal.
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`Id. However, guard rings presented a barrier to developing a truly compact device
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`because they require additional space and therefore limit the proximity and size of
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`the touch terminals. There was no known way to overcome this problem until the
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`invention disclosed and claimed in the ’183 Patent.
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`21. Today’s cell phones and tablets offer a rich user input interface in
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`very large part due to the innovations taught in the ’183 Patent. These devices
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`require a very closely spaced array of sensitive small-sized multi-touch input
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`sensors that can be rapidly controlled using a microprocessor. In addition, these
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`devices must be able to recognize multi-touch gestures and differentiate these
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`gestures from noise, contamination and unintentional touches. The ’183 Patent
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`was the first to teach the combination of all these things.
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`22.
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`In particular, the teachings of the ’183 Patent were crucial to the
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`elimination of the physical structures used in the prior art to prevent crosstalk
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`between adjacent input touch terminals and an increase in sensitivity that allowed
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`for the reduction in the size of individual input touch terminals. In addition, I
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`understand that the ’183 Patent also teaches how to minimize noise due to
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`contaminants and how to select oscillator frequencies. This is another critical
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`contribution that is widely used in today’s cell phones and tablets. The ability to
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`differentiate between a touch and a partial touch and reject unintentional touches is
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`essential to the ability to recognize the multi-touch gestures, which led to the rich-
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`user interface that has driven the rapid adaptation of smart phones and cell phones
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`utilizing multi-touch capacitive sensors. The ’183 Patent enabled this innovation.
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`23. By eliminating the need for guard rings in a multi touch pad
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`configuration, the ’183 Patent offers improvements in detection sensitivity that
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`allow and enable employment of a multiplicity of small sized touch terminals in a
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`physically close array such as a keyboard. Id. at 5:53-57. This increased
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`sensitivity is accomplished by using an oscillator circuit in combination with a
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`floating common operating at a voltage 5V different from the output of the
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`oscillator and used as a reference for the touch input circuitry and by using high
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`frequency signals (preferably greater than 800 kHz) to drastically reduce the
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`impact of supply noise and noise due to contaminants on the screen. Thus, the
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`combination of the innovative sensor design combining an oscillator and floating
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`common with the implementation of a microprocessor to selectively provide output
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`frequencies to a closely spaced array of touch input points opened up the
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`development and commercialization of today’s multi touch capacitive sensors in
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`cell-phones and tablets that replaced crude resistive sensors for mobile devices.
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`This innovative touch sensor design allows for input touch terminals to be very
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`small and densely arranged together. With the use of a microprocessor to send the
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`oscillator signal to each of these small, closely spaced input touch terminals, it was
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`possible to create for the first time a keypad we now see in cell phones and tablets.
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`24. Accordingly, the ’183 Patent paved the way for today’s touch screen
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`devices. The ’183 Patent achieves detection sensitivity without the need for guard
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`rings in several ways described below.
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`25. First, the ’183 Patent offers “enhanced sensitivity” because it
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`minimizes “susceptibility to variations in supply voltage and noise” by use of high
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`oscillator frequencies and by “use of a floating common and supply that follow the
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`oscillator signal to power the detection circuit.” Id. at 6:1-22; 18:66-19:6. The
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`floating common provides a reference that is only 5V away from the high-
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`frequency oscillator output signal, enabling the system to compare the signals that
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`are only 5V apart. This 5V differential thus minimizes noise that otherwise would
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`be generated due to the presence of contaminants on the touch pad, such as liquids
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`or skin oils. Ex. 1001 at 4:18-20; 5:48-53; 16:12-24.
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`26. Second, the ’183 Patent discloses that this “enhanced sensitivity” of
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`the detection circuit also uses an oscillator that outputs a signal with a voltage that
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`is as high as possible, for example a 26V peak square wave, while at the same time
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`is low enough to obviate the need for expensive components and testing to
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`alleviate safety concerns. Id. at 6:6-13; 12:6-23.
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`27. Third, the ’183 Patent’s detection circuit “operates at a higher
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`frequency than prior art touch sensing circuits” which “is not a benign choice”
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`relative to the prior art detection circuits. Id. at 8:9-14. The ’183 Patent discloses
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`extensive testing that was performed in order to determine the required frequency
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`ranges. With reference to Figure 3A, the ’183 Patent discloses that the tests were
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`designed to find the ideal frequency ranges that would provide a substantial
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`enough “impedance difference between the paths to ground of the touched pad 57
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`and adjacent pads 59.” Id. at 11:1-9. “This . . . result[s] in a much lower incidence
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`of inadvertent actuation of adjacent touch pads to that of the touched pad.” Id.; see
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`also id. at 11:19-25.
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`28. Thus, the ’183 Patent discloses a circuit with very high frequencies, a
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`floating common generator, and as high an oscillator voltage as possible so as to
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`bring the input touch terminals in closer proximity and make them smaller, while
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`still providing enhanced detection sensitivity, without the need for physical
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`structures like guard rings to isolate the touch terminals, which therefore permits
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`touch terminals to be spaced extremely close together and yet avoid inadvertent
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`actuations. Id. at 8:9-11:60. A schematic of the essential elements of the invention
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`is shown in Figure 11 reproduced below.
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`29. The inventions of the ‘183 Patent therefore made a groundbreaking
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`contribution to the art as it existed at the time the application was filed. To my
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`knowledge, no other device existed that allowed for the combination of smaller
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`input terminals with enhanced detection sensitivity. To the contrary, the
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`developments in the art at that time were focused on the use of physical structures,
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`such as guard rings to reduce noise and crosstalk. Thus, the invention of the ‘183
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`Patent represented a marked departure from the prevailing approach at the time.
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`VI. PROPER CLAIM CONSTRUCTION
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`30.
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`I understand that Dr. Subramanian has applied what he has concluded
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`is the “plain and ordinary meaning” of claim terms for which neither Nartron nor
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`Petitioner previously offered constructions in the related District Court litigation.
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`Ex. 1002, ¶ 25. For these terms, Dr. Subramanian has not proposed any
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`constructions, and it is not clear what constructions he applied.
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`31.
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`It is my opinion that there are three claim terms that appear in each of
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`the challenged claims and that are crucial to the understanding of the inventions
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`claimed in the ‘183 Patent. These terms are (1) “closely spaced array of input
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`touch terminals of a keypad” / “small sized input touch terminals of a keypad,” (2)
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`“oscillator voltage is greater than a supply voltage” / “peak voltage of the
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`[oscillator’s] signal output frequencies is greater than a supply voltage,” and (3)
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`“selectively providing signal output frequencies.” To the extent I have been able
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`to understand how Dr. Subramanian is construing these critical terms, I disagree
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`with his constructions for the reasons explained below.
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`32.
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`I understand that the claims are to be interpreted according to how
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`they are understood by one of ordinary skill in the art based on the claim language
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`itself, the specification and the file history, which I understand is considered the
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`“intrinsic evidence.” I have carefully reviewed and considered this intrinsic
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`evidence, and based on that review and consideration, I believe that the critical
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`terms I have identified should be construed as set forth below.
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`“closely spaced array of input touch terminals of a keypad” /
`“small sized input touch terminals of a keypad”
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`33.
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`It is my opinion that “closely spaced array of input touch terminals of
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`a keypad” / “small sized input touch terminals of a keypad” should be construed as
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`touch terminals that are closely-spaced or small-sized without requiring physical
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`structures to isolate the touch terminals. My reasons are as follows.
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`34. The claim language makes clear that input touch terminals are either
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`“small” or in a “closely spaced array.” Claims 37, 83, and 94 (and their dependent
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`claims) recite a “closely spaced array of input touch terminals of a keypad” and
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`claims 40, 61 (and their dependent claims) recite “small sized input touch terminals
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`of a keypad.” These limitations appear only in the multi touch claims.
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`35. The ’183 Patent teaches both single touch pad and multi touch pad
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`embodiments. With respect to the multi touch pad embodiment, the specification
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`is unequivocal that this embodiment is different from the prior art in that it does
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`not require the use of guard rings. Indeed, the problem that the ’183 Patent solves
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`is making a highly sensitive detection circuit without the requirement of guard
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`rings in a multi touch pad system.
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`36. For example, in the background of the invention, the ’183 Patent
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`explains that “[a]n additional consideration in using zero force switches resides in
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`the difficulties that arise in trying to employ dense arrays of such switches.” Ex.
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`1001 at 3:54-4:3. The ’183 Patent further teaches that the prior art Ingraham I
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`patent “employs conductive guard rings around the conductive pad of each touch
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`terminal in an effort to decouple adjacent touch pads and prevent multiple
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`actuations where only a single one is desired.” Id. at 4:3-8. The ’183 Patent
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`discourages guard rings because, in a multi touch embodiment that requires guard
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`rings, the sensitivity of the detection circuits is such that it requires the operator’s
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`finger to substantially overlap the touch terminal. Id. at 4:10-14. The ’183 Patent
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`discloses that even with the use of guard rings, susceptibility to surface
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`contaminants, cross talk, and multiple actuations of adjacent touch pads remains a
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`problem. Id. at 4:14-24. The ‘183 Patent strives to improve upon the prior art by
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`the use of sensitive detection circuitry, disclosing that “[s]mall touch terminals
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`placed in close proximity by necessity require sensitive detection circuits.” Ex.
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`1001 at 4:24-25.
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`37. FIG. 11 of the ’183 Patent, reproduced below, depicts a multiple touch
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`pad embodiment:
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`The multiple touch pad circuit of Figure 11 is a variation of the embodiment shown
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`in Figure 4. It contains some, but not all, of the elements of the single touch pad
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`circuit of Figure 4. The specification discloses that “the touch circuit 400 shown in
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`FIGS 4 and 8 and the input touch terminal pad 451 (FIG 4)” are included in the
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`Figure 11 embodiment. Not included is Figure 4’s guard ring 460. Id. at 18:39-43.
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`The components that are similar to those in Figure 4 are designated with the same
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`reference numerals and other components are discussed in greater detail at columns
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`18 and 19. Id. at 18:34-19:6. The multiple touch pad embodiment includes an
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`array of touch detection circuits designated as 9001 through 900nm. Id. at 18:34-41.
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`38. Figure 8, reproduced below, depicts the touch detection circuitry that
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`is used for touch circuits 9001 through 900nm in the multi touch pad embodiment.
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`Ex. 1001, Figure 8. As seen in Figure 8, the touch detection circuit does not
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`include a guard ring. The ’183 Patent explains that “[t]ouch circuit 400, as shown
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`in FIG. 8, preferably includes a transistor 410 having a base connected to touch
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`pad 450 via resistor 413 and line 451.” Ex. 1001 at 14:47-49. Thus, in the multi
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`touch pad embodiment, line 451 is connected directly to the touch pad itself,
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`without requiring any extra components such as guard rings. With respect to FIG.
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`11, the ’183 Patent explains that:
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`The use of high frequency in accordance with the present invention
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`provides distinct advantages for circuits such as the multiple touch pad
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`circuit of the present invention due to the manner in which crosstalk is
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`substantially reduced without requiring any physical structure to
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`isolate the touch terminals. Further, the reduction in crosstalk afforded
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`by the present invention allows the touch terminals in the array to be
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`more closely spaced together.
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`Id. at 18:66-19:6 (emphasis added). Thus, guard rings are not required in a multi
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`touch pad configuration in stark contrast to the prior art that requires the use of
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`guard rings to prevent unwanted actuation of adjacent touch pads.
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`39. Thus, for the touch terminals to be both in a “closely spaced array”
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`and “small sized” as taught and claimed in the ‘183 Patent, physical structures to
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`isolate the touch terminals, such as guard rings that are part of the terminals
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`themselves, must be eliminated.
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`B.
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`“oscillator voltage is greater than a supply voltage” / “peak
`voltage of the [oscillator’s] signal output frequencies is greater
`than a supply voltage”
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`40.
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`It is my opinion that “oscillator voltage is greater than a supply
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`voltage” / “peak voltage of the [oscillator’s] signal output frequencies is greater
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`than a supply voltage” should be construed as meaning that the oscillator, and its
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`supply signal and periodic output signal having a predefined frequency, must be
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`within the capacitive responsive electronic switching circuit, not outside the
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`switching circuit such as an external commercial power supply from the wall. My
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`reasons are as follows.
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`41. All of the claims at issue recite a capacitive responsive electronic
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`switching circuit comprising an oscillator that outputs a periodic output signal
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`having a predefined frequency. While claim 40 does not require the oscillator
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`voltage be greater than the supply voltage, it is similar to the other claims at issue
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`in that it, too, recites a capacitive responsive electronic switching circuit
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`comprising an oscillator that outputs a periodic output signal having a predefined
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`frequency. I understand that “comprising” in a patent claim means including, but
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`not limited to. Accordingly, the claimed oscillator must be included in, not
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`external to, the electronic switching circuit. The elements of the capacitive
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`electronic switching circuit are shown in Figure 11 as made clear by the caption.
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`
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`42. The first component of Figure 11 is the voltage regulator. The
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`oscillator is clearly shown to be between the voltage regulator and the floating
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`common generator. The purpose of the regulator is described in column 11:64-66
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`and further explained in 13:23-31. If the available power source is a 110 V AC 60
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`Hz commercial power line then the voltage regulator may have an added
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`transformer to convert the voltage to 24 V AC. It is clear that if the voltage
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`regulator is part of the capacitive electronic switching circuit then the oscillator is
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`required to be too.
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`43. Claim 37 recites that the “oscillator voltage is greater than the supply
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`
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`voltage,” whereas claims 61, 83 and 94 recite that the “peak voltage of the
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`[oscillator’s] signal output frequencies is greater than a supply voltage.”
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`Accordingly, these claims and their dependent claims require a capacitive
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`responsive electronic switching circuit that includes an oscillator that has an output
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`voltage greater than its supply voltage. As a person of ordinary skill in the art, I
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`therefore understand that the oscillator of the ’183 Patent, and the signal it outputs,
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`are components included within the responsive electronic switching circuit.
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`44. The ’183 Patent explains that the voltage of the signal output from its
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`oscillator circuit is sufficiently high to resolve the aforementioned issues related to
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`eliminating the guard rings, yet also sufficiently low that it “obviates the need for
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`expensive . . . construction measures and testing to handle what would otherwise
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`be large enough voltages to cause safety concerns.” Ex. 1001 at 6:1-13
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`(distinguishing Ingraham III). The ’183 Patent discloses one embodiment in
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`which the voltage generated by the oscillator is 26V peak square wave. Ex. 1001
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`at 6:1-13; 12:6-13.
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`45. Regarding the supply voltage, the ’183 Patent discloses an
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`embodiment in which “a regulated 5V DC power” is supplied to the oscillator. Id.
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`at 11:64-12:2. As a person of ordinary skill in the art, I understand that this 5V DC
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`power is the supply voltage to the oscillator. In order to reach a higher output
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`signal voltage than the input signal voltage, the disclosed oscillator preferably
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`includes a buffer circuit that boosts the peak output of the oscillator from 5V to
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`26V, while maintaining the preferred frequency. Id. at 13:32-39.
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`46. Because the express language of the claims requires that the oscillator
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`and the signal it outputs is a component within the responsive electronic switching
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`circuit, a commercial power supply from the wall, which is outside of the
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`switching circuit, cannot be the claimed oscillator signal output. Indeed, the ’183
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`Patent discourages using high commercial power line voltage in the disclosed
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`circuitry. The ’183 Patent explains that, if the power source to the system is very
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`high, for example, “a 110V AC 60 Hz commercial power line, a transformer may
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`be added to convert the 110V AC power to 24V AC.” Id. at 13:23-29. As a person
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`of ordinary skill in the art, I understand that neither the 110V AC power supply nor
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`the 24V AC signal could be construed to be the oscillator voltage since the
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`oscillator voltage is an output voltage and in one example is 26V.
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`47. The ’183 Patent states that using commercial power lines in capacitive
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`touch switches radiates too much noise and is subject to contamination, corrosion
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`and wear and is particularly problematic when multiple switches are in a dense
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`array. Id. at 3:11-33. Thus, the specification discloses an oscillator that is a
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`component of the electronic switching circuit and that has an output signal with a
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`voltage greater than its supply signal. Accordingly, as a perso