Inter Partes Review
`United States Patent No. 7,915,631
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`United States Patent No.: 7,915,631
`Inventors: Yoshinori Shimizu, et al.
`Formerly Application No.: 12/548,618
`Issue Date: Mar. 29, 2011
`Filing Date: Aug. 27, 2009
`Former Group Art Unit: 2822
`Former Examiner: Michael Trinh
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`Attorney Docket No.: 112868-0001-651
`Customer No. 28120
`Petitioner: VIZIO, Inc.
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`For: LIGHT EMITTING DEVICE AND DISPLAY
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`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`
`DECLARATION OF DR. PAUL R. PRUCNAL
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 7,915,631
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`United States Patent No. 7,915,631
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`United States Patent No.: 7,915,631
`Inventors: Yoshinori Shimizu, et al.
`Formerly Application No.: 12/548,618
`Issue Date: Mar. 29, 2011
`Filing Date: Aug. 27, 2009
`Former Group Art Unit: 2822
`Former Examiner: Michael Trinh
`
`
`§
`§
`§
`§
`§
`§
`§
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`Attorney Docket No.: 112868-0001-651
`Customer No. 28120
`Petitioner: VIZIO, Inc.
`
`
`For: LIGHT EMITTING DEVICE AND DISPLAY
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`
`DECLARATION OF DR. PAUL R. PRUCNAL
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 7,915,631
`
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`Inter Partes Review
`United States Patent No. 7,915,631
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`TABLE OF CONTENTS
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`Page
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`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
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`BACKGROUND AND QUALIFICATIONS ................................................. 2
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`III.
`
`PRIORITY DATE AND ONE OF ORDINARY SKILL ............................. 10
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`IV. MATERIALS RELIED UPON ..................................................................... 11
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`V.
`
`BACKGROUND ON THE STATE OF THE ART ...................................... 11
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`VI. ANALYSIS OF THE ’631 PATENT ............................................................ 24
`
`A. Overview of the ’631 Patent ................................................................ 24
`
`B.
`
`C.
`
`Overview of the ’631 Patent Prosecution History .............................. 28
`
`Claim Construction of the ’631 Patent Claims ................................... 32
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`VII. THE CHALLENGED CLAIMS ARE INVALID ......................................... 33
`
`A.
`
`B.
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`Legal Standards ................................................................................... 33
`
`Claims 1-4, 7-8, and 10-11 are Obvious Under 103 over Baretz
`in view of Matoba, Pinnow, and/or the knowledge of a POSITA ...... 37
`
`1.
`
`2.
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`3.
`
`4.
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`Overview of U.S. Patent No. 6,600,175 (“Baretz”) .................. 38
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`Overview of Japanese Publication No. H7-99345
`(“Matoba”) ................................................................................ 42
`
`Overview of U.S. Patent No. 3,699,478 (“Pinnow”) ................ 43
`
`Invalidity of Claim 1 as Obvious Over Baretz in view of
`Matoba and/or the Knowledge of a POSITA............................ 45
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`a. Preamble ..............................................................................45
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`b. Element [1.A] .......................................................................46
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`c. Element [1.B] .......................................................................55
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`d. Element [1.C] .......................................................................60
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`e. Element [1.D] .......................................................................65
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`f. Element [1.E] .......................................................................65
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`g. Element [1.F] .......................................................................78
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`Invalidity of Claim 2 as Obvious Over Baretz in View of
`Matoba and/or the Knowledge of a POSITA............................ 89
`
`Invalidity of Claim 3 as Obvious Over Baretz in View of
`Matoba, Pinnow, and/or the Knowledge of a POSITA ............ 89
`
`Invalidity of Claim 4 as Obvious Over Baretz in View of
`Matoba, Pinnow, and/or the Knowledge of a POSITA .......... 107
`
`Invalidity of Claim 7 as Obvious Over Baretz in View of
`Matoba, Pinnow, and/or the Knowledge of a POSITA .......... 109
`
`Invalidity of Claim 8 as Obvious Over Baretz in View of
`Matoba, Pinnow, and/or the Knowledge of a POSITA .......... 109
`
`Invalidity of Claim 10 as Obvious Over Baretz in View
`of Matoba, and/or the Knowledge of a POSITA .................... 111
`
`Invalidity of Claim 11 as Obvious Over Baretz in View
`of Matoba, and/or the Knowledge of a POSITA .................... 111
`
`5.
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`6.
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`7.
`
`8.
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`9.
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`10.
`
`11.
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`VIII. CONCLUSION ............................................................................................ 113
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`APPENDIX A (Curriculum Vitae)
`APPENDIX B (List of Materials Considered)
`APPENDIX C (Claim Charts)
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`I, Dr. Paul R. Prucnal, hereby declare under penalty of perjury:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained to provide assistance regarding U.S. Patent No.
`
`7,915,631 (EX10011) (which I refer to as the ’631 patent). Specifically, I have
`
`been asked to consider the validity of claims 1-4, 7-8, and 10-11 of the ’631 patent
`
`(the “Challenged Claims”). I have personal knowledge of the facts and opinions
`
`set forth in this declaration, and, if called upon to do so, I would testify
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`competently thereto.
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`2.
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`I am being compensated for my time at my standard consulting rate of
`
`$650 per hour. I am also being reimbursed for expenses that I incur during the
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`course of this work. My compensation is not contingent upon the results of my
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`study, the substance of my opinions, or the outcome of any proceeding involving
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`the challenged claims. I have no financial interest in the outcome of this matter or
`
`in the pending litigation between Petitioner and Nichia Corporation.
`
`3.
`
`A table of contents is included above. Attached hereto as Appendix B
`
`is a list of exhibits referenced herein.
`
`
`1 The citations in this Declaration to an “Exhibit” or “EX” refer to the Exhibits to
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`the Petition.
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`Inter Partes Review
`United States Patent No. 7,915,631
`II. BACKGROUND AND QUALIFICATIONS
`I offer statements and opinions on behalf of Petitioner, VIZIO, Inc.
`4.
`
`(“VIZIO”), generally regarding the validity, novelty, prior art, obviousness
`
`considerations, and understanding of a person of ordinary skill in the art
`
`(“POSITA”) as it relates to the ’631 patent. Attached hereto as Appendix A, is a
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`true and correct copy of my Curriculum Vitae describing my background and
`
`experience.
`
`5.
`
`I am currently a Professor of Electrical Engineering at Princeton
`
`University in Princeton, New Jersey. I graduated summa cum laude from Bowdoin
`
`College in 1974 with an A.B. in Mathematics and Physics. I graduated from
`
`Columbia University in 1976 with a M.S. in Electrical Engineering. I went on to
`
`receive an M.Phil. in Electrical Engineering from Columbia University in 1978 and
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`a Ph.D. in Electrical Engineering from Columbia University in 1979. The title of
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`my dissertation was “Threshold Detection in Optical Communications and Visual
`
`Psychophysics,” which dealt with the detection of photons by both semiconductor
`
`detectors and the human visual system.
`
`6.
`
`Upon graduation from Columbia in 1979, I joined Columbia
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`University as an Assistant Professor of Electrical Engineering, and in 1984 I was
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`promoted to Associate Professor. My teaching at Columbia included courses on
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`semiconductor light emitters, light emitting diodes, lasers, and optoelectronic
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`devices. My research at Columbia included studying frequency modulation of
`
`semiconductor lasers and LEDs, as well as semiconductor modulators comprised
`
`of multiple quantum wells. My research at Columbia further included photonic
`
`switching and computing architectures using backlit LCD arrays to implement
`
`vector-matrix multiplication and packet routing.
`
`7.
`
`In 1988, I joined the faculty of Princeton University as an Associate
`
`Professor of Electrical Engineering. In 1990, I was promoted to Professor of
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`Electrical Engineering at Princeton.
`
`8. My teaching at Princeton includes courses at the undergraduate and
`
`graduate level on photonic devices including semiconductor light emitters, light
`
`emitting diodes, and lasers, and optical signal processing techniques that include
`
`wavelength conversion.
`
`9. My professional activities include attending and presenting papers at
`
`optics conferences such as the annual meetings of the Lasers and Electooptics
`
`Society, the Optical Society of America, the Society of Photooptical
`
`Instrumentation Engineers, the Conference on Lasers and Electrooptics, and
`
`Optical Fiber Communications. My activities also include regularly reading and
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`publishing papers in scholarly optics journals, including Photonics Technology
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`Letters, the Journal of the Optical Society of America, the Optical Engineering
`
`journal, Optics Letters, and others.
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`10. My research on photonic systems at Princeton has included the
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`design, fabrication and testing of solid state sources of radiation, including
`
`semiconductor light emitters, light emitting diodes and lasers. Such light emitters
`
`included titanium sapphire ring lasers, multiple quantum well semiconductor
`
`optical amplifiers, III-V semiconductor distributed feedback lasers, and III-V
`
`photonic integrated circuits including LEDs. In addition to the light emitters listed
`
`above, I also have worked with semiconductor fiber ring lasers and erbium doped
`
`fiber lasers.
`
`11. My research at Princeton has also included the investigation of
`
`photonic packet switching architectures, including two-dimensional back-lit LCD
`
`arrays, and experiments on wavelength conversion, such as using Mach Zehnder
`
`and Sagnac interferometers, color center lasers pumped by Nd:YAG lasers,
`
`wavelength conversion experiments using four wave mixing in highly germanium
`
`doped fibers, bismuth doped fibers, periodically poled lithium niobate, and optical
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`spectral broadening using supercontiuum generation with dispersion decreasing
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`fiber.
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`12. From 1989 through 1991, I was a founding director of the New Jersey
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`Advanced Technology Center for Photonics and Optoelectronic Materials. My
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`responsibilities there included leading a $10 million research program involving
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`approximately thirty faculty members. Research in this center included photonic
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`technology such as semiconductor and organic light emitting diodes for
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`communications, computing, and displays.
`
`13.
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`In 1991, I was a visiting professor in the Research Center for
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`Advanced Science and Technology at the University of Tokyo, where I held the
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`NEC Chair. My responsibilities there included research and teaching on photonics.
`
`14.
`
`In 1992, I was a visiting professor at the University of Parma. My
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`responsibilities there included researching and teaching photonics.
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`15. During my career at Princeton, I received numerous awards and
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`recognitions, including: (a) being elected a Fellow of the IEEE and a Fellow of the
`
`Optical Society of America; (b) receiving the Rudolf Kingslake Medal and Prize
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`from the SPIE for the most noteworthy original paper in Optical Engineering;
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`(c) receiving the Gold Medal Award from the Faculty of Mathematics, Physics,
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`and Informatics at the Comenius University for leadership in the field of Optics;
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`(d) receiving the Princeton University Graduate Mentoring Award; (e) receiving
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`numerous Engineering Council Awards; (f) receiving the Walter Curtis Johnson
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`Prize for Excellence in Teaching; (g) receiving the Princeton School of
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`Engineering and Applied Science Distinguished Teacher Award; and (h) The
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`President’s Award for Distinguished Teaching, Princeton University (2015).
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`16.
`
`In addition to the activities, education, and professional experience
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`listed above, I have been involved in several projects outside of academics that
`
`contribute to my expertise relating to this report.
`
`17.
`
`In 1979-1981, I worked with Phillips Laboratories on a project that
`
`involved research on bandwidth compaction coding for optical data storage. My
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`responsibilities included the design and analysis of efficient data encoding schemes
`
`for optical recording using laser technology. The designed recording disks
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`included an epoxy layer to protect the reflective information layer of the disk.
`
`18.
`
`In 1982, I worked with Optical Information Systems, Inc. on a project
`
`that involved optical transceiver design for fiber optic links. My responsibilities
`
`included the design of optical transmitters including semiconductor laser diodes for
`
`high-speed optical data transmission.
`
`19.
`
`In 1983-1984, I worked with GTE Labs on a project that involved
`
`performance analysis of fiber optic transmission systems. My responsibilities
`
`included the investigation of high performance modulation formats for optical
`
`transmitters based on semiconductor lasers.
`
`20.
`
`In 1985-1986, I worked with AT&T Bell Laboratories on a project
`
`that involved research on multiplexing techniques for fiber optic networks. My
`
`responsibilities included investigating wavelength-based multiplexing.
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`21.
`
`In 1987-1988, I worked with IBM on a project that involved research
`
`on multiple access techniques for fiber optic networks. My responsibilities
`
`included design and performance analysis of wavelength-division multiplexed
`
`networks and wavelength conversion.
`
`22.
`
`In 1987-1989, I worked with Dove Electronics on a project that
`
`involved research on photonic switching technology and architectures. My
`
`responsibilities included the design and analysis of packet switching architectures,
`
`including wavelength switching using wavelength conversion.
`
`23.
`
`In 1992-1995, I worked with Siemens Corporate Research on a project
`
`that involved research on ultrafast optical switching technology. My
`
`responsibilities included the investigation of optoelectronic technologies including
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`semiconductor light emitters.
`
`24.
`
`In 1998-2001, I worked with Sun Microsystems on a project which
`
`involved research on optical backplanes and computer interconnects. My
`
`responsibilities included the design of a high performance multiprocessor
`
`interconnection system using semiconductor light emitters and integrated
`
`optoelectronic modulators.
`
`25.
`
`In 1999-2000, I worked with SAIC on a project that involved research
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`on fiber optic network architectures. My responsibilities included the investigation
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`of novel switching and multiplexing techniques that included wavelength
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`conversion.
`
`26.
`
`In 1999-2002, I worked with Multi Link Technologies, Inc. on a
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`project that involved fiber optic transceiver design and optoelectronic technology.
`
`My responsibilities included the design and analysis of high-speed optical multi-
`
`wavelength transmitters and receivers for WDM networks.
`
`27.
`
`In 2000-2002, I worked with Ultra Fast Optical Systems on a project
`
`that involved research and development of all-optical wavelength conversion based
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`on semiconductor optical amplifiers and tunable semiconductor lasers.
`
`28.
`
`In 2000-2003, I was a member of the advisory board on optical
`
`network technology for Alphion, Inc. My responsibilities included providing
`
`guidance on the development of technology in the optical networks space.
`
`29.
`
`In 2003-2006, I worked with Kailight Photonics Inc. on a project
`
`which involved research and development of all-optical regenerators based on
`
`semiconductor optical amplifiers. My responsibilities included the design and
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`testing of optoelectronic technology.
`
`30.
`
`In 2004-2011, I worked with NEC Laboratories on a project that
`
`involved research on physical layer security in optical networks. My
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`responsibilities included the design and analysis of spectral spreading techniques
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`for privacy using optical steganography.
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`31.
`
`In 2005-2006, I worked with Princeton Optronics on a project that
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`involved the design of fiber optic networks for avionics platform. My
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`responsibilities included designing and implementing a multi-wavelength fiber
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`optic CDMA network.
`
`32.
`
`In 2010, I worked with Access Optical Networks, Inc. on a project
`
`that involved research and development on optical data storage, including gallium
`
`nitride lasers, iron-doped lithium niobate crystals, liquid crystal spatial light
`
`modulators, and including epoxy resin for embedding microoptic components. As
`
`part of this design project, I investigated using spatial light modulators, including
`
`back-lit LCD arrays, as a two-dimensional data modulator to write information into
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`an optical memory cell.
`
`33. From 1996-present, I have been a member of the advisory board on
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`advanced computing research for the Center for Computing Sciences. My
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`responsibilities include providing feedback on the Center’s research program.
`
`34. From 2010-present, I have worked with Bascom Hunter Technologies
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`on a project that has involved research and development on RF photonics. My
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`responsibilities include developing novel systems for RF interference cancellation
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`based on integrated semiconductor photonic components.
`
`35.
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`I have also published a book on optical CDMA and 32 book chapters
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`in the optics field. In addition, I have published approximately 350 papers in
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`conference proceedings and over 290 peer reviewed journal papers. My book,
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`“Neuromorphic Photonics,” will be published in May of 2017. I have also chaired
`
`or served as a member on several dozen boards and committees related to optics
`
`and electrical engineering.
`
`III. PRIORITY DATE AND ONE OF ORDINARY SKILL
`I understand that the factors considered in determining the ordinary
`36.
`
`level of skill in a field of art include the level of education and experience of
`
`persons working in the field; the types of problems encountered in the field; and
`
`the sophistication of the technology at the time of the purported invention, which I
`
`understand is asserted to be July 29, 1996. I understand that a person of ordinary
`
`skill in the art is not a specific real individual, but rather is a hypothetical
`
`individual having the qualities reflected by the factors above. I understand that a
`
`person of ordinary skill in the art would also have knowledge of the teachings of
`
`the prior art, including the art cited below.
`
`37.
`
`In my opinion, on or before July 29, 1996, a POSITA relating to the
`
`technology of the ’631 patent would have had a minimum of a bachelor’s degree in
`
`electrical engineering, chemistry, or physics, or a related field, and approximately
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`two years of professional experience with optoelectronics, or other relevant
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`experience. Additional graduate education could substitute for professional
`
`experience, or significant experience in the field could substitute for formal
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`education. I understand that a POSITA is presumed to have knowledge of all
`
`relevant prior art, and therefore would have been familiar with each of the
`
`references cited herein, as well as the background knowledge in the art discussed
`
`in Section V, and the full range of teachings they contain.
`
`38. Well before July 29, 1996, my level of skill in the art was at least that
`
`of a POSITA. I am qualified to provide opinions concerning what a POSITA
`
`would have known and understood at that time, and my analysis and conclusions in
`
`this declaration are from the perspective of a POSITA as of July 29, 1996.
`
`IV. MATERIALS RELIED UPON
`In reaching the conclusions described in this declaration, I have relied
`39.
`
`on the documents and materials cited in this declaration as well as those identified
`
`in Appendix B to this declaration. Each of these materials is a type of document
`
`that experts in my field would reasonably rely upon when forming their opinions.
`
`40. My opinions are also based on my education, training, research,
`
`knowledge, and personal and professional experience.
`
`V. BACKGROUND ON THE STATE OF THE ART
`41. Prior to the claimed priority date, light emitting diodes (LEDs) having
`
`a light emitting component and a fluorescent material that absorbs light emitted by
`
`the light emitting component and emits light of a wavelength different from that of
`
`the absorbed light (wavelength conversion) were well-known. See, e.g., EX1004
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`(Baretz), 7:19-27 (“an LED operative to emit, for example, monochromatic blue or
`
`ultraviolet (UV) radiation is packaged along with fluorescent organic and/or
`
`inorganic fluorescers and phosphors in an insulating polymeric matrix.
`
`The monochromatic blue or UV radiation output of the LED is absorbed and then
`
`down converted by the fluorphore or phosphor to yield longer wavelengths to
`
`include a broad spectrum of frequencies which appear as white light.”); EX1005
`
`(Matoba), Abstract (“An LED sealing resin is composed of a first resin 11 that fills
`
`a cup internal part 3, and a second resin 12 that encloses the first resin; by
`
`including in the first resin 11 a wavelength-conversion material 5 such as a
`
`fluorescent substance that converts a wavelength of light from a light-emitting chip
`
`into another wavelength.”), Fig. 1; EX1013 (Tadatsu), Abstract (“A light emitting
`
`diode comprising a light emitting element . . . comprises gallium nitride-related
`
`compound semiconductors . . . and further into the aforementioned resin mold a
`
`fluorescent dye or a fluorescent pigment, which is excited by the emission by the
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`aforementioned gallium nitride-related compound semiconductor and thereby
`
`emits fluorescent light.”), Fig. 2; see also EX1001 (’631 patent), 2:5-22.
`
`42. An LED chip having an electrode was also well-known. See, e.g.,
`
`EX1004 (Baretz), 12:12-17 (“The top contact of the LEDs, joined by connecting
`
`wires 43, are electrically coupled by means of electrode 46…for joining to the
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`aforementioned power supply”); EX1007 (Nakamura), 1869 (“The surface of the
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`p-type GaN layer was partially etched until the n-type GaN layer was exposed.
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`Next, a Ni/Au contact was evaporated onto the p-type GaN layer and a Ti/Al
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`contact onto the n-type GaN layer.”), Fig. 1; EX1010 (Edmond), 4:5-10 (“Another
`
`solution is to use a relatively large ohmic contact to the p+ layer so as to increase
`
`the current across the junction.”), 7:39-46 (“a wire-bondable overlay contact is
`
`preferably added to ohmic contact 24 and is most preferably formed of aluminum,
`
`gold, or silver.”), Figs. 5, 8; EX1011 (Tamaki), 4:36-40 (“Terminal electrode 9 is
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`constituted of two layers including an Ni layer 9a and an Au layer 9b.”), 4:44-51
`
`(“Light-emitting diode 10…is electrically connected to lead pins 41…. [T]he Au
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`layer 9b of the terminal electrode 9 connected to the first electrode 7 is connected
`
`to the lead pin 41 through an Au wire 43.”), Figs. 1, 2; EX1012 (the Nakamura
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`’350 patent), 6:41-48 (“On the surface of this current-contracting layer 16 is
`
`formed a positive electrode (p-electrode) 17 connected to the p-type contact layer
`
`15 through the opening 16a.…In the case of an LED device, the positive electrode
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`17 is directly formed on the p-type contact layer 15.”); EX1013 (Tadatsu), ¶2
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`(“The front surface electrode of the light emitting diode 1 is wire-bonded on the
`
`surface with a gold wire”).
`
`43.
`
`It was also well-known to have an electrode on the emitting surface of
`
`an LED chip that partially blocks the light emitted by the LED chip. See, e.g.,
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`EX1010 (Edmond), 4:5-10 (“Another solution is to use a relatively large ohmic
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`contact to the p+ layer so as to increase the current across the junction. The
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`practical effect, however, is to block light from being emitted from the p+ layer by
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`the presence of the ohmic contact.”); EX1014 (Dutta), 1:22-25 (“To enhance the
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`light output, the electrode area needs to be as small as possible and the light
`
`emitting surface needs to be as wide as possible.”), 1:60-62 (“In addition,
`
`the darkness at the center portion due to the circular shaped electrode reduces the
`
`coupling efficiency even with a larger core fiber.”), Figs. 1A, 1B, 2; EX1011
`
`(Tamaki), 1:49-58 (“However, with a GaN blue light LED having an MIS
`
`structure, little current diffusion along the transverse direction parallel to the
`
`interface takes place in the i-type layer beneath the light-emitting electrode. This
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`results in a light-emitting portion which is limited only to a region beneath the
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`light-emitting electrode. Because the electrode is generally made of a metal, light
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`emission is rarely observed from the side of the light emission electrode as if
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`disappearing behind the electrode.”).
`
`44. LED chips with a main emission peak within the range from 400 nm
`
`to 530 nm (and 420 to 490 nm) were also well-known. See, e.g., EX1004 (Baretz),
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`9:10-18 (“LED 13 comprises a leaded, gallium nitride based LED which exhibits
`
`blue light emission with an emission maximum at approximately 450 nm.”);
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`EX1007 (Nakamura), 1868 (“The blue LEDs produced 4.8 mW at 20 mA and
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`sharply peaked at 450 nm.”); EX1012 (the Nakamura ’350 patent), 36:49-51 (“This
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`14
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`Inter Partes Review
`United States Patent No. 7,915,631
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`LED exhibited a blue emission at 450 nm and 3.5V in Vf (forward voltage) under
`
`an If (forward current) of 20 mA.”).
`
`45.
`
`It was also well-known that LED chips can comprise indium gallium
`
`nitride (InGaN). See, e.g., EX1004 (Baretz), 10:24-25 (“A blue LED light source
`
`may be based on: indium gallium nitride”); EX1007 (Nakamura), 1868 (“As an
`
`active layer, the InGaN single-quantum-well-structure was used.”); EX1015
`
`(Nitta), 1:10-15 (“Gallium-nitride-based compound semiconductor such as
`
`GaN, InGaN, and GaAlN is drawing attention as material for fabricating blue light
`
`emitting diodes (LEDs) and blue laser diodes (LDs).”), 7:5-7 (“The gallium-
`
`nitride-based semiconductor active layer 706 is made of In(x)Ga(1-x)N compound
`
`semiconductor having a quantum well structure.”).
`
`46.
`
`It was also well-known that LED chips can comprise sapphire
`
`substrates. See, e.g., EX1004 (Baretz), 10:36-40 (“If gallium nitride emitters are
`
`employed, preferred substrates for the emitters include silicon carbide, sapphire,
`
`gallium nitride and gallium aluminum indium nitride alloys, and gallium nitride-
`
`silicon carbide alloys, for achieving a proper lattice match.”); EX1007
`
`(Nakamura), 1868 (“High-power blue and violet light-emitting diodes (LEDs)
`
`based on III–V nitrides were grown by metalorganic chemical vapor deposition
`
`on sapphire substrates”); EX1015 (Nitta), 1:16-25 (“FIG. 7 shows the basic
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`15
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`Vizio EX1003 Page 0018
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`Inter Partes Review
`United States Patent No. 7,915,631
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`structure of a blue light emitting element 2 according to a prior art. On a sapphire
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`substrate 200, a buffer layer 201 is formed.”).
`
`47. Further, it was well-known to have a transparent material covering the
`
`LED chip. See, e.g., EX1004 (Baretz), 8:58-9:9 (“The enclosure 11 may be
`
`formed of any suitable material having a light-transmissive character, such as
`
`a clear or translucent polymer, or a glass material.”), Fig. 1; EX1005 (Matoba), ¶2
`
`(“Ordinarily, a highly transparent resin is selected for resin 4 for the purpose of
`
`efficiently emitting light from the light-emitting chip through air.”), Fig. 2;
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`EX1016 (Bhattacharya), 215-216 (“Two techniques that can be used to increase FT
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`[light radiated to the total light generated]…The second, and cheaper technique,
`
`shown in Fig. 5.5(b), is to use dielectric encapsulation shaped as a dome with
`
`a transparent material of high refractive index.”), Fig. 5.5(b)).
`
`48. Transparent material made out of epoxy resin, urea resin, silicone
`
`resin, or glass was also well-known. See, e.g., EX1004 (Baretz), 8:58-9:9 (“The
`
`enclosure 11 may be formed of any suitable material having a light-transmissive
`
`character, such as a clear or translucent polymer, or a glass material.”); EX1005
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`(Matoba), ¶2 (“Ordinarily, a highly transparent resin is selected for resin 4 for the
`
`purpose of efficiently emitting light from the light-emitting chip through air.”), ¶10
`
`(“both can be composed of an epoxy resin, and include the wavelength-conversion
`
`material 5 in only the first resin.”); EX1017 (Shiobara), 1:20-25 (“Epoxy resins are
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`16
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`Vizio EX1003 Page 0019
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`United States Patent No. 7,915,631
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`well known in the art . . . [and] are widely used in encapsulating optical
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`semiconductor devices because of their light transparency.”).
`
`49. Additionally, it was well-known that phosphor contained in the
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`transparent material absorbs a part of light emitted by the LED chip and emits light
`
`of a wavelength different from that of the emitted light. See, e.g., EX1004
`
`(Baretz), Abstract (“down-converting luminophoric medium…in exposure to said
`
`first, relatively shorter wavelength radiation, is excited to responsively emit
`
`second, relatively longer wavelength radiation. In a specific
`
`embodiment, monochromatic blue or UV light output from a light-emitting diode is
`
`down-converted to white light by packaging the diode with fluorescent organic
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`and/or inorganic fluorescers and phosphors in a polymeric matrix”), 9:4-9 (“The
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`enclosure is filled with a suitable down-converting material 20, e.g., a down-
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`converting medium comprising fluorescer and/or phosphor component(s), or
`
`mixtures thereof, viz., a luminophoric medium, which functions to down convert
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`the light output from face 18 of LED 13 to white light.”), 9:39-50 (“the
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`luminophoric medium may comprise simply the fluorescer(s) and/or phosphor(s),
`
`without any associated mediating material such as intermediate luminescent dyes,
`
`if the fluorescer(s) and/or phosphor(s) are directly excitable to emit the desired
`
`white light.”); EX1005 (Matoba), ¶10 (“In the LED of the present invention, it is
`
`acceptable for the materials in the first resin 11 and the second resin to be the same
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`17
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`Vizio EX1003 Page 0020
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`United States Patent No. 7,915,631
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`material. For example, both can be composed of an epoxy resin, and include
`
`the wavelength-conversion material 5 in only the first resin.”), Fig. 2.
`
`50. Further, it was well-known that phosphor diffuses light and suppresses
`
`a formation of an emission pattern by a partial blocking of light. See, e.g., EX1004
`
`(Baretz), 7:13-18 (“The solid state device is structurally associated with a recipient
`
`down-converting luminophoric medium which when impinged by 15 the first,
`
`relatively shorter wavelength radiation is excited to responsively emit a radiation in
`
`the visible white light spectrum.”); EX1005 (Matoba), ¶3 (“The arrows in Fig. 2
`
`schematically show light from the light-emitting chip hitting the wavelength-
`
`conversion material 5 and wavelength-converted light being scattered. In other
`
`words, the quantity of light at the luminescence observation surface is reduced by
`
`the scattering of wavelength-converted light, thereby reducing brightness.”), ¶7
`
`(“Light whose wavelength is converted in this way scatters in all directions, but
`
`almost all of the scattered light is reflected by a cup, and collected at a
`
`luminescence observation surface.”), Fig. 2; EX1029 (Lengyel), 11:60-63 (“A
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`‘diffuser’ is often used to compensate for the non-uniformities of light distribution
`
`and dark areas.”), 12:17-21 (“Because substantially the entire cavity is coated with
`
`phosphors in the present invention, and each individual phosphor particle emits
`
`light in a dispersive, omniradiant profile, the fluorescent cavity 16 is in effect self-
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`diffusing.”); EX1026 (Kitta), 6:23-37 (“By using the light diffuser 22,
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`18
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`Vizio EX1003 Page 0021
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`United States Patent No. 7,915,631
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`directionality of the light emitting sources such as light emitting diodes can be
`
`broadened so that the intensity of the
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