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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ZTE CORPORATION, and ZTE (USA), Inc.,
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`Petitioner
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`v.
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`HITACHI MAXELL, LTD
`Patent Owner
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`U.S. PATENT NO. 8,339,493
`Case IPR No.: To Be Assigned
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`DECLARATION OF DR. BARMAK MANSOORIAN IN SUPPORT OF
`PETITIONS FOR INTER PARTES REVIEW OF U.S. PATENT NO. 8,339,493.
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`ZTE Exhibit 1002
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`Table of Contents
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`Page
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`INTRODUCTION .......................................................................................... 3
`I.
`QUALIFICATIONS ....................................................................................... 4
`II.
`SCOPE OF OPINION .................................................................................... 7
`III.
`IV. MATERIALS REVIEWED AND CONSIDERED ....................................... 7
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ............................................ 8
`VI. LEGAL PRINCIPLES .................................................................................... 9
`VII. TECHNOLOGY BACKGROUND OF THE ‘493 Patent ........................... 11
`A.
`Evolution of Digital Camera .............................................................. 11
`B.
`Image Processing in Digital Cameras ................................................ 12
`C.
`Image Stabilization Technology ......................................................... 13
`D.
`Evolution of Camera Phone ............................................................... 14
`VIII. OVERVIEW OF THE U.S. PATENT NO. 8,339,493 (“‘493 Patent”) ....... 15
`IX. OVERVIEW OF THE PRIOR ART REFERENCES .................................. 18
`A. U.S. Patent No. 5,493,335 (“Parulski ‘335”) (EX. 1003) .................. 18
`B.
`U.S. Patent No. 5,440,343 (“Parulski ‘343”) (EX. 1004) .................. 19
`C.
`U.S. Patent No. 5,497,192 (“Ishizuka ‘192”) (EX. 1005) .................. 20
`D. U.S. Patent No. 5,828,406 (“Parulski ‘406”) (EX. 1006) .................. 21
`E.
`U.S. Patent No. 6,512,541 (“Dunton ‘541”) (EX. 1007) ................... 22
`CLAIM CONSTRUCTION ......................................................................... 23
`X.
`XI. SPECIFIC GROUNDS OF CHALLENGE .................................................. 25
`A. Ground A: Under 35 U.S.C. § 103, Parulski ‘335 (Ex. 1003) in
`view of Parulski ‘343 (Ex. 1004) renders independent claim 5
`obvious. .............................................................................................. 25
`Ground B: Under 35 U.S.C. § 103, Parulski ‘335 (Ex. 1003) in
`view of Parulski ‘343 (Ex. 1004) and Ishizuka ‘192 (Ex. 1005),
`renders dependent claim 6 obvious. ................................................... 33
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`B.
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`1
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`ZTE Exhibit 1002 - 2
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`C.
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`Ground C: Under 35 U.S.C. § 103, Parulski ‘406 (Ex. 1006) in
`view of Dunton ‘541 (Ex. 1007) renders independent claim 5
`obvious. .............................................................................................. 36
`D. Ground D: Under 35 U.S.C. § 103, Parulski ‘335 (Ex. 1003) in
`view of Parulski ‘343 (Ex. 1004) and Ishizuka ‘192 (Ex. 1005),
`renders dependent claim 6 obvious. ................................................... 47
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`2
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`ZTE Exhibit 1002 - 3
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`I.
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`INTRODUCTION
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`My name is Barmak Mansoorian, and I have been retained by counsel
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`for ZTE (USA) as an expert witness to opine on certain issues relating to U.S.
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`Patent No. 8,339,493 titled “ELECTRIC CAMERA” (“the ‘493 Patent) in ZTE’s
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`Petition for Inter Partes Review of the ‘493 Patent (“ZTE IPR Petition”) which
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`requests the Patent Trial and Appeal Board (“PTAB”) to review and cancel Claims
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`5 and 6, which based on my knowledge, are all the claims that are currently being
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`asserted in a patent litigation against ZTE.
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`In this declaration, I will discuss the technology related to the ‘493
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`Patent, including an overview of the technology as it was known prior to, and up to
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`the time of the filing of the applications. The overview of the relevant technology
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`provides some of the basis for my opinions with respect to the ‘493 Patent.
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`My opinions are based on my years of education, research and
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`experience, as well as my investigation and study of relevant materials. In forming
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`my opinion, I have relied on information and evidence identified in this
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`declaration, including the ‘493 Patent, the prosecution history of the ‘493 Patent,
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`and prior art references listed as Exhibits to the Petition for Inter Partes Review of
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`the ‘493 Patent.
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`I may rely upon these materials, my knowledge and experience,
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`and/or additional materials to rebut arguments raised by the patent owner. Further,
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`3
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`ZTE Exhibit 1002 - 4
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`I may also consider additional documents and information in forming any
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`necessary opinions, including documents that may not yet have been provided to
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`me.
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`My analysis of the materials produced in this investigation is ongoing
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`and I will continue to review any new material as it is provided. This declaration
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`represents only those opinions I have formed to date. I reserve the right to revise,
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`supplement, and/or amend my opinions stated herein based on new information
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`and on my continuing analysis of the materials already provided.
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`I am being compensated on a per hour basis for my time spent
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`working on issues in this case. My compensation does not depend on the outcome
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`of this matter or the opinions I express.
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`II. QUALIFICATIONS
`Attached hereto as Appendix A is a true and correct copy of my
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`curriculum vitae. I have summarized by educational background, work
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`experience, and relevant qualifications in this section.
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`I am the founder and president of Forza Silicon Corporation and one
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`of the world’s leading experts in CMOS image sensors.
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`I have been involved in image sensor design for over 20 years as
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`scientist, product developer, entrepreneur and mentor. My focus was in mixed-
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`signal integrated circuit design, semiconductor device physics and device micro-
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`4
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`ZTE Exhibit 1002 - 5
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`fabrication with specialization in active pixel sensors (APS), infrared focal plane
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`array technology and high-speed communication. I have summarized in this
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`section my educational background, work experience, and other relevant
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`qualifications
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`I received my Bachelor of Science degree and Master of Science
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`degree in Electrical Engineering from University of California, San Diego in 1988
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`and 1990, respectively. In 1994, I received my Ph.D. degree in Applied Physics
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`from University of California, San Diego. My dissertation was on on-chip optical
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`interconnections using Lead Lanthanum Zirconium Titanate material.
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`After receiving my Ph.D. degree in 1994, I worked at Jet Propulsion
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`Laboratory for one year as a member of technical staff. I was responsible for the
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`development of large format APS sensors. This work resulted in a 1Kx1K pixel
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`sensor with on-chip analog-to-digital converters – at the time the highest resolution
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`image sensor with integrated ADC and digital interface.
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`While at Jet Propulsion Laboratory, I also worked on research on APS
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`imagers also led to the development of CMOS image sensor arrays with a record
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`low noise performance that was not improved upon by the industry until 2003.
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`While at Jet Propulsion Laboratory, I was the recipient of the NASA
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`Group Achievement Award, along with the Active Pixel Image Sensor team.
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`5
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`ZTE Exhibit 1002 - 6
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`From 1995 to 1999, I worked at Photobit Corporation as senior
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`scientist and director of technical marketing. I was responsible for new image
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`sensor product development, technical interface with customers and fabrication
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`facilities, and business development in Japan and Korea.
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`While at Photobit Corporation, I was the lead designer responsible for
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`a series of high resolution, high-speed image sensors that, successively, held the
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`resolution/speed performance records for CMOS image sensors.
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`While at Photobit Corporation, I was also responsible for the
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`development of a very high dynamic range image sensor capable of “moonlight to
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`sunlight” imaging (0.01 lux to 20000 lux) targeted for security and machine vision
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`applications.
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`From 1999-2001, I worked at Optical Micro Machines Corporation as
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`director of hardware engineering. I was responsible for the development of
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`electronics hardware for MEM’s based optical switches. I managed the design of
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`96-channel, 300 volt, 14-bit amplifier IC’s and the activities of 20+ engineers in
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`designing the components for switch network products.
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`In 2001, I started Forza Silicon Corporation. The corporation is fully
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`dedicated to the development of high-performance mixed-signal integrated circuits
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`for imaging and high-speed communication.
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`6
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`ZTE Exhibit 1002 - 7
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`I hold 21 patents in image sensor design and have contributed to 12
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`articles in imaging and high-speed communication.
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`A complete list of publication is provided in my curriculum vitae,
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`which is attached as Appendix A.
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`III. SCOPE OF OPINION
`I have been asked to provide my opinions regarding whether claims 5
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`and 6 of the U.S. Patent No. 8,339,493 (“the ‘493 Patent”) would have been
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`obvious to one of ordinary skill in art at the time of the alleged invention in view of
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`U.S. Patent No. 5,493,335 (“Parulski ‘335,” Ex. 1003), U.S. Patent No. 5,440,343
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`(“Parulski ‘343,” Ex. 1004), U.S. Patent No. 5,497,192 (“Ishizuka ‘192,” Ex.
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`1005), U.S. Patent No. 5,828,406 (“Parulski ‘406,” Ex. 1006), and U.S. Patent No.
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`6,512,541 (“Dunton ‘541,” Ex. 1007).
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`This declaration, including the exhibits hereto, sets forth my opinion
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`on this topic.
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`IV. MATERIALS REVIEWED AND CONSIDERED
`In connection with my work on this matter, I have reviewed and
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`considered the following documents:
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`7
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`ZTE Exhibit 1002 - 8
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`Exhibit
`Exhibit No.
`Ex.1001 U.S. Patent No. 8,339,493 (“the ‘493 Patent”)
`Ex.1003 U.S. Patent No. 5,493,335 (“Parulski ‘335”)
`Ex.1004 U.S. Patent No. 5,440,343 (“Parulski ‘343”)
`Ex.1005 U.S. Patent No. 5,497,192 (“Ishizuka ‘192”)
`Ex.1006 U.S. Patent No. 5,828,406 (“Parulski ‘406”)
`Ex.1007 U.S. Patent No. 6,512,541 (“Dunton ‘541”)
`Prosecution History of U.S. Patent No. 8,339,493 (“the ‘493 file
`Ex.1008
`history”)
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`I also have relied on my academic and professional experience in
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`reaching the opinions expressed in this declaration.
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`V. LEVEL OF ORDINARY SKILL IN THE ART
`In rendering the opinions set forth in this declaration, I was asked to
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`consider the patent claims and the prior art through the eyes of a person of ordinary
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`skill in the art. I considered factors such as the educational level and years of
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`experience of those working in the pertinent art; the types of problems encountered
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`in the art; the teachings of the prior art; patents and publications of other persons or
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`companies; and the sophistication of the technology. I understand that a person
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`ordinary skill in the art is not a specific real individual, but rather a hypothetical
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`individual having the qualities reflected by the factors discussed above.
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`In my opinion, a person ordinary skill in the art, at the time of the
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`‘493 Patent, would have been aware of electric camera generating still and moving
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`images using different operating modes. Such person ordinary skill in the art
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`would have a Bachelor’s Degree in Electrical Engineering, Computer Engineering
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`8
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`ZTE Exhibit 1002 - 9
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`and/or Computer Science with 3 years industry experience working with imaging
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`systems. Extensive experience and technical training may substitute for
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`educational requirements, while advanced education such as a relevant M.S. or
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`Ph.D. might substitute for experience.
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`VI. LEGAL PRINCIPLES
`I understand that, when construing claim terms, a claim subject to
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`inter partes review receives the “broadest reasonable construction in light of the
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`specification of the patent in which it appears.” I further understand that the
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`broadest reasonable construction is the broadest reasonable interpretation of the
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`claim language, and that any term that lacks a definition in the specification is also
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`given a broad interpretation.
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`I understand that there are two ways in which prior art may render a
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`patent claim unpatentable. First, the prior art can be shown to “anticipate” the
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`claim. Second, the prior art can be shown to have made the claim “obvious” to a
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`POSITA.
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`I understand that in order for a patent claim to be valid, the claimed
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`invention must be novel. In order for the invention to be anticipated, every
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`element of the claimed invention, as arranged in the claim, must be disclosed either
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`specifically or inherently by a single prior art reference. Every element of the
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`challenged claim need not be expressly defined in a single prior art reference, but
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`9
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`ZTE Exhibit 1002 - 10
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`may be inherently disclosed by prior art if “the prior art necessarily functions in
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`accordance with the limitations” of the challenged claim. I also understand that a
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`prior art reference must be enabling in order to anticipate a patent claim.
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`I understand where a prior art reference discloses less than all of the
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`limitations of a given patent claim, that patent claim is invalid if the differences
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`between the claimed subject matter and the prior art reference are such that the
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`claimed subject matter as a whole would have been obvious at the time the
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`invention was made to a person having ordinary skill in the relevant art. I further
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`understand that an obviousness analysis takes into consideration factual inquiries
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`such as the level of ordinary skill in the art, the scope and content of the prior art,
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`and the differences between the prior art and the patent claim.
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`I understand that the U.S. Supreme Court has recognized several
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`rationales for combining references and for modifying a reference as part of an
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`obviousness analysis. These rationales include combining prior art elements
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`according to known methods to yield predictable results, simple substitution of a
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`known element for another to obtain predictable results, a predictable use of prior
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`art elements in accordance with their established functions, applying a known
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`technique to improve a known device (or process) and yield predictable results,
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`and choosing from a finite number of known predictable solutions with a
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`reasonable expectation of success. It is further my understanding that an
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`10
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`ZTE Exhibit 1002 - 11
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`obviousness analysis takes into consideration whether the prior art provides a
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`teaching, suggestion or motivation to combine teachings of multiple prior art
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`references to arrive at the patent claim.
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`I also understand that the earliest possible priority date for the ‘493
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`Patent is July 28, 2010. I have therefore analyzed obviousness as of that date or
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`somewhat before that date.
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`VII. TECHNOLOGY BACKGROUND OF THE ‘493 Patent
`A. Evolution of Digital Camera
`The history of the digital camera began with Eugene F. Lally of the
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`Jet Propulsion Laboratory, who was thinking about how to use a mosaic
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`photosensor to capture digital images.
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`The camera generally recognized as the first digital camera was
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`designed and developed by Eastman Kodak engineer Steven Sasson in 1975. This
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`work lead to U.S. Patent No. 4,131,919, titled “Electronic still camera,” and issued
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`to Lloyd and Sasson.
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`The Sasson prototype digital camera comprised of a lens from an
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`8mm film camera, an analog-to-digital converter from a Motorola digital
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`voltmeter, and a digital-data cassette recorder for storing image data. The
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`prototype camera captured and stored black and white still images on to a cassette
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`tape and it took 23 seconds to capture and store each image.
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`11
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`ZTE Exhibit 1002 - 12
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`Canon was the first company to sell electronic still cameras in the
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`U.S. The Canon RC-701 electronic camera was introduced in 1986. By 1989,
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`many other companies, including Fuji, Konica, Minolta, Nikon, Olympus, Sony
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`and Panasonic were selling electronic still cameras
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`In 1986, Japanese company Nikon introduced the first digital single-
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`lens reflex (DSLR) camera, the Nikon SVC. In the mid-to-late 1990s, DSLR
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`cameras became common among consumers. By the mid-2000s, DSLR cameras
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`had largely replaced film cameras.
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`Almost all of the digital cameras include an image sensing device to
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`capture light coming through the lens to form image signals, an image signal
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`processing device to process the signal, and a display device to display captured
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`images. Additionally, most cameras would have a mode selector that the user can
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`select to record still images or videos.
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`B.
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`Image Processing in Digital Cameras
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`Digital image processing is the use of computer algorithms to perform
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`image processing on digital images. Many of the techniques of digital image
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`processing, or digital picture processing as it often was called, were developed in
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`the 1960s at the Jet Propulsion Laboratory, Massachusetts Institute of Technology,
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`Bell Laboratories, University of Maryland, and a few other research facilities. An
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`12
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`ZTE Exhibit 1002 - 13
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`image processor is a specialized digital signal processor (DSP) used for image
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`processing in digital cameras, mobile phones or other devices.
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`Digital cameras included a software programmable processor which
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`controlled the camera hardware in order to capture, store and retrieve images.
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`Every digital camera also has a device called a sensor to capture light coming
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`through the lens to form an image.
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`A digital camera uses an array of millions of tiny light cavities
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`photosites to record an image. To capture color images, a filter has to be placed
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`over each cavity that permits only particular colors of light. The most common
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`type of color filter array is called a “Bayer array,” which is a mosaic of filters used
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`to determine color. The filter pattern is 50% green, 25% red and 25% blue, hence
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`is also called BGGR, RGBG, GRGB, or RGGB. The image processor then
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`evaluates the color and brightness data of a given pixel, compares them with the
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`data from neighboring pixels and then uses a demosaicing algorithm to produce an
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`appropriate color and brightness value for the pixel.
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`C.
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`Image Stabilization Technology
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`As digital cameras become smaller, pictures are increasingly prong to
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`blurring from shaky hands.
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`Image stabilization was first introduced by Canon in 1995. Canon
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`published the idea of stabilized zoom lens in the U.S. in a 1976 in a patent titled
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`13
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`ZTE Exhibit 1002 - 14
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`“Image stabilizing optical system having a variable prism,” U.S. Patent No.
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`3,942,862. Since its introduction, image stabilization has appeared in products
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`such as digital single lens reflex cameras (DSLR), video cameras, camera phones
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`and binoculars.
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`Different companies have different names for image stabilization
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`technology; for example, Nikon uses Vibration Reduction (VR), Canon uses Image
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`Stabilizer (IS), Minolta and Konica Minolta uses Anti-Shake (AS), Olympus uses
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`In Body Image Stabilization (IBIS), Sony uses Optical SteadyShot (OSS) and HTC
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`uses UltraPixel.
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`There are two types of implementation of stabilization: lens-based or
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`body-based. The advantage of lens-based stabilization is that each stabilization
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`hardware is dedicated to a single lens; it stabilizes both the image on the sensor and
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`the image in the viewfinder. The advantage of body-based stabilization is that it is
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`operational with every lens mounted on the camera, which is cost effective to
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`consumers.
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`D. Evolution of Camera Phone
`The camera phone is the result of converging and enabling
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`technologies. In May 1999, Kyocera Corporation release of the VP-210
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`VisualPhone, the world’s first mobile color videophone that also doubled as a
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`camera phone for still photos. By the mid-2000s, higher-end cell phones had an
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`14
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`ZTE Exhibit 1002 - 15
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`integrated digital camera. By the beginning of the 2010s, almost all smartphones
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`had an integrated digital camera.
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`First U.S. camera phone was Sanyo SCP-5300, released in November
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`2002. Sprint’s PM8920 reached U.S. shores in July 2004, delivering market-
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`leading 1.3 megapixel images that could be shared wirelessly or even printed.
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`From 2004 to 2008, Nokia and Sony fought for control of the camera phone
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`market, Samsung stormed the market in 2007. Today, camera phones have strong
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`photography capabilities and the consumer market ranges from 20 to 40
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`megapixels.
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`VIII. OVERVIEW OF THE U.S. PATENT NO. 8,339,493 (“‘493 Patent”)
`The ‘493 Patent relates to an electric camera using imaging sensing
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`device with a large number of pixels. Ex. 1001 at 2:57-62. The ‘493 Patent is
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`directed to the use of camera elements and algorithms in the generation of images
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`and videos and such imaging device has a sufficient number of pixels to capture
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`highly detailed still images that use all pixel lines and to capture reduced quality of
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`moving video image that use mixed or culled pixel lines. Id. at 3:9-13. The ‘493
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`Patent further relates to use of an image-instability detector to detect and correct
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`image instability. Id. at 6:61-7:3.
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`The block diagram in Figure 1 below shows the configuration of an
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`electric camera according to the invention.
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`15
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`ZTE Exhibit 1002 - 16
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`The camera invention includes an image sensing device 3 which the
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`pixels are arranged horizontally and vertically in a grid format. Id. at 4:37-41. The
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`grid-arranged pixels include color filters that are capable of passing yellow (Ye),
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`green (G) and cyan (Cy), respectively, and the process is repeated horizontally
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`every three pixels, as shown in FIG. 2. Id. at 4:42-46.
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`
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`16
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`ZTE Exhibit 1002 - 17
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`The color sensitive filters are further supported in FIGs. 13A and 13B
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`that “[t]hese color filters in both examples are arranged in vertical stripes and,
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`regardless of the number of pixels to be vertically mixed or culled, the R, G, B
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`primary color signals can be generated from one line of output signals.” Id. at
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`15:26 – 15:30.
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`The camera invention also includes a signal processing circuit 7 that
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`has a function of using output signals from the image sensing device 3 to generate
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`image signals. Id. at 3:30-31. The signal processing circuit performs color signal
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`processing and luminance signal processing, such as process of “color signals,
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`gamma correction, white balance processing and outline enhancement.” Id. at
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`6:11-15.
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`Additionally, the camera invention is designed to produce output
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`signals conforming to a television system. Id. at Abstract. It requires a display unit
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`that is capable of displaying industry standard television signals such as NTSC or
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`PAL. Id. at 1:30-34.
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`Furthermore, ‘493 Patent realizes the image stabilizing function. The
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`gyro sensors 16a, 16b detect vertical and horizontal image instabilities and the
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`image instability decision circuit 17 checks and converts the instability information
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`into the number of pixels in vertical and horizontal directions. Id. at 7:10-16.
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`17
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`ZTE Exhibit 1002 - 18
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`Based on the converted pixel numbers, the position of the effective pixel area is
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`shifted in a direction that cancels the image instability. Id. at 7:16-21.
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`The ‘493 Patent proposes static image mode and video mode. When
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`the camera is in static image mode, all signal charges in the pixel sensor element
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`are used to produce high resolution images. Id. at 16:42-46.When monitoring and
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`not recording, the image is formed using pixel lines that have been formed as a
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`mixture of other pixel lines. Id. at 16:47-53. The image only includes pixel lines
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`that are separated from each other by a certain distance; the rest are not used. Id.
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`When the camera is in video mode, the images are also formed by mixing or
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`culling pixels lines from other lines and that the video image only contains pixel
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`lines separated by a different distance. Id. at 16:54-60.
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`The electric camera disclosed in the ‘493 Patent was well know prior
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`to the invention of the ‘493 Patent. As discussed below, the cited references teach
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`all of the claimed features.
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`IX. OVERVIEW OF THE PRIOR ART REFERENCES
`A. U.S. Patent No. 5,493,335 (“Parulski ‘335”) (EX. 1003)
`Parulski ‘335 is directed to an electronic camera for processing
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`images of different resolution to provide a user selectable image record size. The
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`resolution options include a full resolution mode, and at least one reduced
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`resolution mode. Ex. 1003 at Abstract.
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`18
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`ZTE Exhibit 1002 - 19
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`The electronic camera includes an image sensor for generating a
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`baseband image signal. Id. at 2:22-27. The color image pixels of the image signal
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`are arranged in vertical and horizontal direction covered by a pattern of luminance
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`and chrominance color filter. Id. The electronic camera also includes a resolution
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`mode switch that allows the user to select the image record size. Id. at 2:32-38.
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`When the full resolution mode is activated, all color image pixels are selected and
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`when the reduced resolution mode is activated, a fewer number of color image
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`pixels are selected. Id.
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`Additionally, in order to form the low resolution images, a suitable
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`“subsampling” pattern is required. Id. at 6:4-22. Subsampling rate can be, for
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`example, at every second pixel of every second line. Id. Subsampling is done to
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`reduce the amount of data that needs to be transmitted or stored. Id.
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`Furthermore, the electronic camera includes a display unit capable of
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`displaying image and video. The diagram of Figure 1 shows a display section for
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`user interface with the camera. Id. at 3:25-39.
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`B. U.S. Patent No. 5,440,343 (“Parulski ‘343”) (EX. 1004)
`Parulski ‘343 is directed to an electronic imaging system that records
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`both motion and still video images. The imaging system records NTSC resolution
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`images in a motion mode operation and records high resolution images in a still
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`mode operation. Ex. 1004 at Abstract.
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`ZTE Exhibit 1002 - 20
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`The electronic imaging system utilizes an image sensor that includes
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`an array of pixel image signal. Id. at 2:10-15. In order to generate high resolution
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`image signals, the electronic imaging system is placed in the still mode of
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`operation and all of the pixels are selected. Id. at 2:14-15. However, in the motion
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`mode of operation, in order to generate images in accordance with NTSC standard,
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`which is a standard video rate of thirty frames per second, image signals generated
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`from certain selected pixels are discarded or combined with nearby signals. Id. at
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`2:15-22.
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`Additionally, the electronic image sensor incorporates “charge
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`clearing” structures and “charge parking” structures. Id. at 3:44-51. “The charge
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`clearing structures are used to selectively discard [i.e., cull] the signal charge from
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`certain pixels, while the charge parking structures are used to add the charge from
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`non-adjacent vertical pixels [i.e., mix].” Id. “An NTSC resolution image is
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`obtained in a motion mode of operation by selectively activating the charge
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`clearing structures.” Id. at 5:32-59.
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`C. U.S. Patent No. 5,497,192 (“Ishizuka ‘192”) (EX. 1005)
`Ishizuka ‘192 is directed to a video signal process apparatus for
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`correcting vibration effects in a video camera. Defective pixels in the image are
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`compensated by storing the address of the defective pixels and interpolating at
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`those positions. During vibration correction, the defective pixels are shifted to
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`correspond to the amount of corrections. Ex. 1005 at Abstract.
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`Ishizuka ‘192 teaches that shaking in the vertical direction can be
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`detected by the pitch angular velocity speed sensor and the output of the pitch
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`angular velocity speed sensor is supplied to a converter through an amplifier, then
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`to the vibration correcting controller. Id. at 7:12-24
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`Ishizuka ‘192 further teaches that shaking in the horizontal direction
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`can be detected by the yaw angular velocity sensor and an output of the yaw
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`angular velocity sensor is supplied to a converter through an amplifier, then to the
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`vibration correcting controller. Id.
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`D. U.S. Patent No. 5,828,406 (“Parulski ‘406”) (EX. 1006)
`Parulski ‘406 is directed to an electronic camera that produces high
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`quality still images using complex digital image processing technique and
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`acceptable quality of preview images using simple image processing technique.
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`Ex. 1006 at Abstract.
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`The electronic camera includes two modes that can be tailored for a
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`low quality motion mode and a high quality still mode. Id. at 6:22-45. The motion
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`mode corresponds to a “line skipping” mode which the timing and control section
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`of the device controls the fast dump structure to eliminate two or more consecutive
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`lines of the image charge from the image sensor. Id. The still mode corresponds
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`to a high quality still image mode wherein all rows of image pixel charge are
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`readout during a single scan. Id.
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`Additionally, the electronic camera includes an electronic color
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`display wherein a number of user control buttons, such as zoom buttons, preview
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`button and a capture button, are available. Id. at 3:20-24.
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`E. U.S. Patent No. 6,512,541 (“Dunton ‘541”) (EX. 1007)
`Dunton ‘541 is directed to an imaging apparatus that is configured to
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`operate in at least still image capture mode and video image capture mode. The
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`imaging data in the video image mode is smaller and with lower resolution than the
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`still image mode. The reduction is accomplished by ways of digital scaling or
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`cropping, or a combination of digital scaling and cropping. Ex. 1007 at Abstract.
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`Dunton ‘541 teaches that the signal processing unit can include
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`scaling and compression logic to perform image scaling and compression prior to
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`transmission and storage. Id. at 6:33-36. The scaling and compression logic can
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`be used for both still and video images by selecting the appropriate scaling ratio.
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`Id. at 6:66-7:16. Scaling ratio can be a 4:1 sub-sampling of the corrected image
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`that 16 pixels from the corrected image data are averaged together to produce 1
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`pixel in the scaled image data. Id. Lower scaling ratios such as 2:1 may also be
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`used, where 4 pixels are averaged to generate a single pixel in the scaled image
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`data. Id.
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`X. CLAIM CONSTRUCTION
`I understand that, when construing claim terms, a claim subject to
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`inter partes review receives the “broadest reasonable construction in light of the
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`specification of the patent in which it appears.” See 37 C.F.R. § 42.100(b). I
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`further understand that the broadest reasonable construction is the broadest
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`reasonable interpretation of the claim language, and that any term that lacks a
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`definition in the specification is also given a broad interpretation.
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`I understand that the terms of the ‘493 patent are to be given their
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`broadest reasonable interpretation as understood by a POSITA at the time of the
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`invention in view of the specification.
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`Claim 5 contains the limitation “an image sensing device with a light
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`receiving sensor having an array of pixels arranged vertically and horizontally in a
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`grid pattern.” The appropriate structure to perform the function of image sensing
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`should include color filters arranged in vertical lines. The ‘493 patent specification
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`states, “On these grid-arrayed pixels three types of color filters that pass yellow
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`(Ye), green (G) and cyan (Cy), respectively, are arranged in such a way that the
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`combination of these three colors is repeated horizontally every three pixels and
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`that the filters of the same colors are lined vertically in so-called vertical stripes.”
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`Ex. 1001 at 4:41-4:46. The specification further states that the color filters “are
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`arranged in vertical stripes and, regardless of the number of pixels to be vertically
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`ZTE Exhibit 1002 - 24
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`mixed or culled, the R, G, B primary color signals can be generated from one line
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`of output signals.” Id. at 15:25-15:30.
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`Claim 6 contains the limitation “an image instability detector.” The
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`term has the function of “detecting an image-instability of the electric camera.” Id.
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`at 15:61-62. (“an image-instability detector, configured to dete