Inter Partes Review
`United States Patent No. 7,855,092
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Attorney Docket No.: 1285100-0002
`Petitioner: VIZIO, Inc.
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`§§§§§§§
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`United States Patent No.: 7,855,092
`Inventors: Yoshinori Shimizu, et al.
`Formerly Application No.: 12/829,182
`Issue Date: Dec. 21, 2010
`Filing Date: Jul. 1, 2010
`Former Group Art Unit: 2812
`Former Examiner: A. Mustapha
`
`
`For: DEVICE FOR EMITTING WHITE-COLOR LIGHT
`
`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. 7,855,092
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`VIZIO 1002
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`United States Patent No. 7,855,092
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`TABLE OF CONTENTS
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`Page
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`INTRODUCTION ........................................................................................... 1
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`BACKGROUND AND QUALIFICATIONS ................................................. 2
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`
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`I.
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`II.
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`III.
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`PRIORITY DATE AND ONE OF ORDINARY SKILL ............................. 10
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`IV. MATERIALS RELIED UPON ..................................................................... 11
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`V.
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`BACKGROUND ON THE STATE OF THE ART ...................................... 11
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`A. Development of White Light LEDs .................................................... 11
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`B.
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`C.
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`D.
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`Cerium-Activated Yttrium Aluminum Garnet (YAG) Phosphor ....... 13
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`Conventional LED Components ......................................................... 16
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`LED Displays and Controllers ............................................................ 18
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`VI. ANALYSIS OF THE ’092 PATENT ............................................................ 22
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`A. Overview of the ’092 Patent ................................................................ 22
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`B.
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`C.
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`Overview of the ’092 Patent Prosecution History .............................. 27
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`Claim Construction of the ’092 Patent Claims ................................... 29
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`VII. OVERVIEW OF THE PRIOR ART REFERENCES ................................... 29
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`A. Overview of U.S. Patent No. 6,600,175 (“Baretz”) .................. 29
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`B.
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`C.
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`Overview of U.S. Patent No. 5,796,376 (“Banks”) .................. 36
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`Overview of U.S. Patent No. 3,816,576 (“Auzel”) .................. 41
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`D. Overview of U.S. Patent No. 3,774,021 (“Johnson”) ............... 44
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`E.
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`F.
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`Overview of U.S. Patent No. 5,001,609 (“Gardner”) ............... 45
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`Overview of J.P. Publication No. H7-99345 (“Matoba”) ......... 48
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`G. Overview of U.S. Patent No. 3,699,478 (“Pinnow”) ................ 49
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`VIII. THE CHALLENGED CLAIMS ARE INVALID ......................................... 51
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`A.
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`B.
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`Legal Standards ................................................................................... 51
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`Claims 1-3, 7-9, 12 and 13 are Obvious by Baretz in view of Banks,
`and further in view of Auzel, Johnson, Gardner, Matoba, and/or
`Pinnow ................................................................................................. 55
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`1.
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`Claim 1 is Obvious Over Baretz in View of Banks .................. 56
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`a. Preamble: “A device for emitting white-color light
`comprising:” ........................................................................ 56
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`b. Element [1.A]: “a light emitting diode including:” ............. 58
`
`c. Element [1.A.i]: “an LED chip comprising a gallium nitride
`compound semiconductor containing indium and being
`capable of emitting a blue color light, and” ........................ 59
`
`d. Element [1.A.ii]: “a phosphor capable of absorbing a part
`of the blue color light and emitting a light having longer
`wavelength than the blue color light,” ................................. 61
`
`e. Element [1.A.iii]: “the blue color light and the light from
`said phosphor being mixed to make the white-color,” ........ 66
`
`f. Element [1.B]: “a control unit for converting an input to
`pulse signals,” ...................................................................... 74
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`g. Element [1.C]: “a driver receiving said pulse signals from
`said control unit to drive said LED chip,” ........................... 93
`
`h. Element [1.D]: “wherein the brightness of the white-color
`light from said light emitting diode is controlled by a width
`of said pulse signals.” .......................................................... 95
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`Claim 2 is Obvious Over Baretz in View of Banks .................. 96
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`Claim 3 is Obvious Over Baretz in View of Banks ................100
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`Claim 7 is Obvious Over Baretz in View of Banks, and Further
`in View of Auzel or Johnson ..................................................103
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`2.
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`3.
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`4.
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`Claim 8 is Obvious Over Baretz in View of Banks, and Further
`in View of Gardner .................................................................111
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`Claim 9 is Obvious Over Baretz in View of Banks, and Further
`in View of Matoba ..................................................................117
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`Claim 12 is Obvious Over Baretz in View of Banks, and
`Further in View of Pinnow .....................................................122
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`Claim 13 is Obvious Over Baretz in View of Banks ..............135
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`5.
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`6.
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`7.
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`8.
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`IX. CONCLUSION ............................................................................................137
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`APPENDIX A (Curriculum Vitae)
`APPENDIX B (List of Materials Considered)
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`I.
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`Inter Partes Review
`United States Patent No. 7,855,092
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`I, Dr. Paul R. Prucnal, hereby declare under penalty of perjury:
`
`INTRODUCTION
`1.
`
`I have been retained to provide assistance regarding U.S. Patent No.
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`7,855,092 (EX10011) (which I refer to as “the ’092 patent”). Specifically, I have
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`been asked to consider the validity of claims 1-3, 7-9, 12, and 13 of the ’092 patent
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`(the “Challenged Claims”). I have personal knowledge of the facts and opinions
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`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
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`$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
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`in the pending litigation between Petitioner, VIZIO, Inc. (“VIZIO”) and Nichia
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`Corporation.
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`3.
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`A table of contents and a list of exhibits referenced herein are
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`included above.
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`1 The citations in this Declaration to an “Exhibit” or “EX” refer to the Exhibits to
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`
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`the Petition.
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`II. BACKGROUND AND QUALIFICATIONS
`4.
`I offer statements and opinions on behalf of VIZIO, generally
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`regarding the validity, novelty, prior art, obviousness considerations, and
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`understanding of a person of ordinary skill in the art (“POSITA”) as it relates to the
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`’092 patent. Attached hereto as Appendix A, is a true and correct copy of my
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`Curriculum Vitae describing my background and experience.
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`5.
`
`I am currently a Professor of Electrical Engineering at Princeton
`
`University in Princeton, New Jersey. I graduated summa cum laude from Bowdoin
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`College in 1974 with an A.B. in Mathematics and Physics. I graduated from
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`Columbia University in 1976 with a M.S. in Electrical Engineering. I went on to
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`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
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`Psychophysics,” which dealt with the detection of photons by both semiconductor
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`detectors and the human visual system.
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`6.
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`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 (LEDs), lasers and
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`optoelectronic devices. My research at Columbia included studying frequency
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`modulation of semiconductor lasers and LEDs, as well as semiconductor
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`modulators comprised of multiple quantum wells. My research at Columbia
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`further included photonic switching and computing architectures using backlit
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`LCD arrays to implement vector-matrix multiplication and packet routing.
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`7.
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`In 1988, I joined the faculty of Princeton University as an Associate
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`Professor of Electrical Engineering. In 1990, I was promoted to Professor of
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`Electrical Engineering at Princeton.
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`8. My teaching at Princeton includes courses at the undergraduate and
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`graduate level on photonic devices including semiconductor light emitters, light
`
`emitting diodes, and lasers, and optical signal processing techniques that include
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`wavelength conversion.
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`9. My professional activities include attending and presenting papers at
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`optics conferences such as the annual meetings of the Lasers and Electro-Optics
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`Society, the Optical Society of America, the Society of Photooptical
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`Instrumentation Engineers, the Conference on Lasers and Electrooptics, and
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`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
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`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
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`semiconductor light emitters, light emitting diodes and lasers. Such light emitters
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`included titanium sapphire ring lasers, multiple quantum well semiconductor
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`optical amplifiers, III-V semiconductor distributed feedback lasers, and III-V
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`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
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`fiber lasers.
`
`11. My research at Princeton has also included the investigation of
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`photonic packet switching architectures, including two-dimensional back-lit LCD
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`arrays, and experiments on wavelength conversion, such as using Mach Zehnder
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`and Sagnac interferometers, color center lasers pumped by Nd:YAG lasers,
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`wavelength conversion experiments using four wave mixing in highly germanium
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`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.
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`13.
`
`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
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`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; (c)
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`receiving the Gold Medal Award from the Faculty of Mathematics, Physics, and
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`Informatics at the Comenius University for leadership in the field of Optics; (d)
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`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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`In addition to the activities, education, and professional experience
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`16.
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`listed above, I have been involved in several projects outside of academics that
`
`contribute to my expertise relating to this declaration.
`
`17.
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`In 1979-1981, I worked with Phillips Laboratories on a project that
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`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
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`for optical recording using laser technology. The designed recording disks included
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`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
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`that involved optical transceiver design for fiber optic links. My responsibilities
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`included the design of optical transmitters including semiconductor laser diodes for
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`high-speed optical data transmission.
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`19.
`
`In 1983-1984, I worked with GTE Labs on a project that involved
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`performance analysis of fiber optic transmission systems. My responsibilities
`
`included the investigation of high performance modulation formats for optical
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`transmitters based on semiconductor lasers.
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`20.
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`In 1985-1986, I worked with AT&T Bell Laboratories on a project
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`that involved research on multiplexing techniques for fiber optic networks. My
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`responsibilities included investigating wavelength-based multiplexing.
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`In 1987-1988, I worked with IBM on a project that involved research
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`21.
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`on multiple access techniques for fiber optic networks. My responsibilities
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`included design and performance analysis of wavelength-division multiplexed
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`networks and wavelength conversion.
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`22.
`
`In 1987-1989, I worked with Dove Electronics on a project that
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`involved research on photonic switching technology and architectures. My
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`responsibilities included the design and analysis of packet switching architectures,
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`including wavelength switching using wavelength conversion.
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`23.
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`In 1992-1995, I worked with Siemens Corporate Research on a
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`project that involved research on ultrafast optical switching technology. My
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`responsibilities included the investigation of optoelectronic technologies including
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`semiconductor light emitters.
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`24.
`
`In 1998-2001, I worked with Sun Microsystems on a project which
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`involved research on optical backplanes and computer interconnects. My
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`responsibilities included the design of a high performance multiprocessor
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`interconnection system using semiconductor light emitters and integrated
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`optoelectronic modulators.
`
`25.
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`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.
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`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.
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`My responsibilities included the design and analysis of high-speed optical multi-
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`wavelength transmitters and receivers for WDM networks.
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`27.
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`In 2000-2002, I worked with Ultra Fast Optical Systems on a project
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`that involved research and development of all-optical wavelength conversion based
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`on semiconductor optical amplifiers and tunable semiconductor lasers.
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`28.
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`In 2000-2003, I was a member of the advisory board on optical
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`network technology for Alphion, Inc. My responsibilities included providing
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`guidance on the development of technology in the optical networks space.
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`29.
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`In 2003-2006, I worked with Kailight Photonics Inc. on a project
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`which involved research and development of all-optical regenerators based on
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`semiconductor optical amplifiers. My responsibilities included the design and
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`testing of optoelectronic technology.
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`30.
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`In 2004-2011, I worked with NEC Laboratories on a project that
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`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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`In 2005-2006, I worked with Princeton Optronics on a project that
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`31.
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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.
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`32.
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`In 2010, I worked with Access Optical Networks, Inc. on a project
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`that involved research and development on optical data storage, including gallium
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`nitride lasers, iron-doped lithium niobate crystals, liquid crystal spatial light
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`modulators, and including epoxy resin for embedding microoptic components. As
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`part of this design project, I investigated using spatial light modulators, including
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`back-lit LCD arrays, as a two-dimensional data modulator to write information into
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`an optical memory cell.
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`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.
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`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.
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`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 December of 2016. I have also
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`chaired or served as a member on several dozen boards and committees related to
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`optics and electrical engineering.
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`III. PRIORITY DATE AND ONE OF ORDINARY SKILL
`36.
`I understand that the factors considered in determining the level of a
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`POSITA include the level of education and experience of persons working in the
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`field; the types of problems encountered in the field; and the sophistication of the
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`technology at the time of the purported invention, which I understand is asserted to
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`be July 29, 1996. I understand that a POSITA is not a specific real individual, but
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`rather is a hypothetical individual having the qualities reflected by the factors
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`above. I understand that a POSITA would also have knowledge of the teachings of
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`the prior art, including the art cited below.
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`37.
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`In my opinion, on or before July 29, 1996, a POSITA relating to the
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`technology of the ’092 patent would have had a minimum of a bachelor’s degree in
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`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
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`experience, or significant experience in the field could substitute for formal
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`education. A POSITA is presumed to have knowledge of all relevant prior art, and
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`therefore would have been familiar with each of the references cited herein, as well
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`as the background knowledge in the art discussed in Section V, and the full range
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`of teachings they contain.
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`38. Well before July 29, 1996, my level of skill in the art was at least that
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`of a POSITA. I am qualified to provide opinions concerning what a POSITA
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`would have known and understood at that time, and my analysis and conclusions in
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`this declaration are from the perspective of a POSITA as of July 29, 1996.
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`IV. MATERIALS RELIED UPON
`39.
`In reaching the conclusions described in this declaration, I have relied
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`on the documents and materials cited in this declaration as well as those identified
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`in Appendix B to this declaration. Each of these materials is a type of document
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`that experts in my field would reasonably rely upon when forming their opinions.
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`40. My opinions are also based on my education, training, research,
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`knowledge, and personal and professional experience.
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`V. BACKGROUND ON THE STATE OF THE ART
`A. Development of White Light LEDs
`41. LEDs emitting a white-color light were well-known prior to the
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`asserted priority date of the ’092 patent. See e.g. U.S. Patent No. 6,600,175 to
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`Baretz et al. (EX1004) (which I refer to as “Baretz”) at Abstract. As explained by
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`Baretz, the development of white-color LEDs was driven by “the desirability of
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`white light displays (e.g., commercial bank ‘time and temperature’ message
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`boards, stadium scoreboards)” in conjunction with the “emerging trend in the
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`manufacturing and marketing of informational displays or signage, especially for
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`outdoor use, [] to utilize solid state LED lamps as replacement for more
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`conventional incandescent bulbs” which had “lower power consumption costs and
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`the longer operational lifetime (hence, reducing maintenance costs).”
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`EX1004[Baretz] 2:15-21.
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`42.
`
`In the “Background of the Invention” section of Baretz, Baretz
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`describes a number of other different approaches taken in the prior art to develop a
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`white light LED, such as packaging “a minimum of three LED dies (or chips)-one
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`red, one green and one blue, encapsulated in a single epoxy package” so that when
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`the emitted colors mix, white light is produced (EX1004[Baretz] 2:47-53), and
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`applying a layer of luminescent material (such as phosphors and/or fluorescers)
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`next to the active or light-emitting region of an LED so that “one can change the
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`phosphor in the luminescing layer, and thereby change the color of the whole
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`material” (EX1004[Baretz] 5:45-6:34). However, these approaches had their
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`shortcomings. See EX1004[Baretz] 2:51-58.
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`43. Baretz goes on to explain that his “invention is based on the discovery
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`that a highly efficient white light emitting device may be simply and economically
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`fabricated utilizing a solid state light emitting device for generating a shorter
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`wavelength radiation which is transmitted to a luminophor (fluorescent and/or
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`phosphorescent solid material) for down conversion by the luminophor of the
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`radiation from the solid state light emitting device, to yield white light.”
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`EX1004[Baretz] 8:18-25. For example, “[w]hite light LED solid state devices may
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`be made by the method of the present invention, utilizing a down conversion
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`process whereby the primary photon generated in the active region of the diode is
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`down converted with primary blue emission and/or secondary blue fluorescent or
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`phosphorescent centers, as well as green and red fluorescent or phosphorescent
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`centers.” EX1004[Baretz] 8:26-36. “Such a device for white light emission, based
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`on down-conversion, requires the primary light to be either blue or ultraviolet
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`emission, such as is available using blue or ultraviolet LED dies and lamps.”
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`EX1004[Baretz] 8:36-39.
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`44.
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`I explain the white light LED of Baretz in greater detail in Sections
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`VII.A and VIII.B, below.
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`B. Cerium-Activated Yttrium Aluminum Garnet (YAG) Phosphor
`45. One such well-known phosphor material suitable to make a white
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`light device is cerium-activated yttrium aluminum garnet (also referred to as
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`“YAG:Ce” or “Ce:YAG” by those in the art). See U.S. Patent No. 3,699, 478 to
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`Pinnow et al. (EX1009) (which I refer to as “Pinnow”) at ABSTRACT (“[a] black
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`and white display is produced by projection using a scanning argon laser beam
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`operating at 4,880 A and a phosphorescent screen of cerium-doped yttrium
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`aluminum garnet which emits a broad range of frequencies centering about 5,500
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`A. The yellowish cast of the phosphor output is compensated by a small amount of
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`reflected blue argon light.”).
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`46.
`
`In a paper published in the Journal of Applied Optics in 1971 by L.G.
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`Van Uitert et al. entitled “Photoluminescent Conversion of Laser Light for Black
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`and White and Multicolor Displays. 1: Materials” (EX1013) (which I refer to as
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`“Van Uitert”), Van Uitert teaches that “[b]y properly coating a viewing screen with
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`existing organic and inorganic phosphors it is possible to efficiently convert
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`monochromatic blue or ultraviolet laser light into virtually any visible color
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`including white.” EX1013[Van Uitert] p. 150. Van Uitert identifies “Y3Al5O15
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`(YAG)” with cerium added (which Van Uitert refers to as “YAG:Ce”) as one such
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`suitable phosphor, describing it as “[a] rather unusual but useful material.”
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`EX1013[Van Uitert] p. 151. Van Uitert details the useful benefits of YAG:Ce
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`include: (1) a “relatively large absorption cross section”; (2) “a very short lifetime
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`of approximately 0.07 µsec”; and (3) “a quantum efficiency of approximately
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`70%,” noting that “[t]hese properties make YAG:Ce very attractive for display
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`screen applications.” See EX1013[Van Uitert] p. 151. Moreover, Van Uitert
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`teaches that YAG:Ce “may be tuned for a particular use” and that “[b]y replacing
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`some Y with Gd the peaks of the absorption spectra and emission spectra shift to
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`somewhat longer wavelengths, while replacing Al with Ga causes the opposite
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`effect.” See EX1013[Van Uitert] p. 151 (emphasis in original).
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`47. Other advantages of YAG:Ce that make it suitable for lighting
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`applications include its ability to withstand harsh operating conditions, including
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`high temperature and intense light sources. See M.V. Hoffman, “Improved Color
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`Rendition in High Pressure Mercury Vapor Lamps,” Journal of the Illuminating
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`Engineering Society, Vol. 6, No. 2 (1977) (EX1014) (which I refer to as
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`“Hoffman”) p. 91 (describing YAG:Ce phosphor working at 300ºC in a mercury
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`vapor lamp). In particular, J.M. Robertson et al. details in a paper entitled
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`“Epitaxially Grown Monocrystalline Garnet Cathode-Ray Tube Phosphor Screens”
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`published in 1980 in the Applied Physics Letters 37 (EX1015) (which I refer to as
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`“Robertson”), that “[o]ne of the limiting factors in obtaining a bright cathode
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`luminescent device is the heat conductivity of the phosphor screen” and that at
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`increasing electron beam densities, the “phosphor is heated to a temperature at
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`which the efficiency decreases” and “[e]ventually the phosphors ‘burn out’ and
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`become permanently degraded.” See EX1015[Robertson] p. 471. Robertson
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`identified the use of YAG:Ce as a solution to this problem, explaining that “[t]hese
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`materials have excellent thermal properties so that they can be used with electron
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`beam of high power density without thermal quenching.” See EX1015[Robertson]
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`p. 472 (“[i]n particular, the epitaxial layers of Ce:YAG can be used up to power
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`densities of 108 W/m2 and are capable of emitting light with a radiance of over 105
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`W/m2 Sr.”).
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`48. Given the widely published benefits of YAG:Ce, it is unsurprising
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`that by the 1980s, YAG:Ce was predominantly used across a variety of white light
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`applications, including displays (as described in Pinnow and Robertson) and
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`mercury vapor lamps (as described in Hoffman).
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`C. Conventional LED Components
`49. As shown below in Figure 1 of U.S. Patent No. 3,764,862 to
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`Jankowski (EX1017) (which I refer to as “Jankowski”) for example, conventional
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`LEDs typically include: (1) a pair of electrical leads 14 and 15; (2) a reflective cup
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`17 electrically coupled to one of the electrical leads (here electrical lead 15) within
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`which the LED die 20 is placed; (3) a wire 23 electrically coupled to the top of the
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`LED die 20 and the other electrical lead 14; and (4) a housing 22 that encapsulates
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`(i.e. seals) the LED die 20, electrical leads 14 and 15, etc. and serves as a lens for
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`the LED. See EX1017[Jankowski] 2:39-59; 3:44-4:5.
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`(EX1017[Jankowski] FIG. 1.)
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`50.
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`Jankowski explains the cup 17 formed in the electrical lead 15 can be
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`made reflective by applying a thin coating of gold, which Jankowski recognizes “is
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`one of the most highly reflective materials.” See EX1017[Jankowski] 3:1-8. By
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`making the cup 17 reflective, the light emitted downwards or laterally (sideways)
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`from the LED die 20 towards the base or edges of the cup 17 can be reflected back
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`upwards towards the housing 22, rather than being lost or absorbed by the
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`environment surrounding the LED die 20, thereby increasing the overall amount of
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`light emitted by the LED. See EX1017[Jankowski] 1:57-60, 2:61-68. It was also
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`generally understood that the outer surface of the housing 22 can be roughened to
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`obtain an even illumination or uniform distribution of the light emitted by the
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`LED. See U.S. Patent No. 4,143,394 to Schoberl (EX1020) 2:34-38 (“[t]he light
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`outlet surface is provided with a fine structure or is roughened in order to achieve
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`even illumination.”), 3:14-16 (“[i]n order to obtain a uniform distribution of light,
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`this end 10 [of the light outlet surface 10] is roughened or is slightly structured on
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`its surface.”).
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`51.
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`Jankowski further explains that the LED die 20, electrical leads 14
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`and 15, etc. are encapsulated within the housing 22 by filling the interior of the
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`housing 22 “with a liquid plastic such as epoxy” and allowing the epoxy to cure,
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`sealing the LED die 20 and its surrounding components within the housing 22. See
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`EX1017[Jankowski] 3:61-4:9. Other well-known materials used to encapsulate an
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`LED include silicone resins. See U.S. Patent No. 4,032,963 to Thome (EX1021)
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`(which I refer to as “Thome”) 2:33-41 (“the present invention provides method and
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`structure for encapsulating a radiant energy emitting semiconductor chip and all
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`angular edge portions of the terminal leads with a resilient, rubber-like silicone
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`resin inner encapsulating core.”). Thome explains that it was known that “silicone
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`resins provide both mechanical and device protection to the semiconductor
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`device.” EX1021[Thome] at 1:62-65.
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`D. LED Displays and Controllers
`52. Electronic displays using LEDs are conventional devices that have
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`been used in various applications since at least the 1970s. See U.S. Patent Nos.
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`3,740,570 to Kaelin et al. (EX1018) (which I refer to as “Kaelin”) and 4,090,189 to
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`Fisler (EX1019) (which I refer to as “Fisler”). These LED displays typically
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`included an array of LEDs, connected to a set of switches that are configured to
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`turn the LEDs on (i.e. a light-emitting state) by applying a sufficient amount of
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`voltage or current to the electrical leads of the LED or off by removing the applied
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`voltage or current to the LED. See EX1018[Kaelin] 2:43-3:19; EX1019[Fisler]
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`3:19-35. The application of voltage or current to operate an LED is also referred to
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`as “driving” the LED. EX1018[Kaelin] 1:3-5. As noted b