UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`Petitioner
`
`v.
`
`COREPHOTONICS LTD.,
`Patent Owner
`____________
`
`Case IPR2018-01140
`Patent 9,402,032 B2
`
`Case IPR2018-01146
`Patent 9,568,712 B2
`____________
`
`DECLARATION OF DUNCAN MOORE, Ph.D.
`PURSUANT TO 37 C.F.R. §1.68
`
`Apple v. Corephotonics
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`Table of Contents
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`I. Background......................................................................................................... 1
`
`II. Summary of Opinions......................................................................................... 1
`
`III. Educational and Employment Background ........................................................ 4
`
`IV. Level of Ordinary Skill in the Art (POSITA) ..................................................... 6
`
`V. Relevant Legal Standards for Anticipation and Obviousness ............................ 7
`
`VI. Background....................................................................................................... 12
`
`A. Overview of the ’032 Patent and ’712 Patent ............................................... 12
`
`B. Multiple Element Lens Design ..................................................................... 18
`
`VII. Claim Construction ........................................................................................... 21
`
`A. “Total Track Length (TTL)” ......................................................................... 22
`
`B. “Effective Focal Length” .............................................................................. 28
`
`C. “Optical Power” ............................................................................................ 28
`
`VIII.
`
`Petition Grounds ........................................................................................ 29
`
`A. Claims 1 and 13 of the ’032 Patent are Not Anticipated by Ogino .............. 29
`
`B. Claims 14 and 15 of the ’032 Patent are Not Obvious over Ogino and Chen
`II 35
`
`C. Claims 1, 12-13, 15-16, and 19 of the ’712 Patent are Not Anticipated by
`Konno ................................................................................................................... 49
`
`D. Claims 6 and 14 of the ’712 Patent are not Obvious Over Konno and Bareau
`
`51
`
`E. Claims 15-17 of the ’712 patent are not Anticipated by Eggert ................... 64
`
`Appendix
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`I.
`
`Background
`
`1.
`
`I have been retained as a technical expert by Patent Owner
`
`Corephotonics Ltd. (“Patent Owner” or “Corephotonics”) in this proceeding.
`
`Corephotonics has asked me to provide my expert opinions concerning certain
`
`technical aspects of imaging lenses and imaging lens design as they relate to the
`
`Petitioner Apple Inc.’s petitions for inter partes review of U.S. Patent 9,402,032
`
`(“’032 patent”) in Case No. IPR2018-01140 (“’032 IPR”) and 9,568,712 (“’712
`
`patent”) in Case No, IPR2018-01146 (“’712 IPR”) and the accompanying
`
`Declarations of Jose Sasian. The statements in this declaration summarize my
`
`opinions on these matters based on my over 40 years of experience in the design and
`
`development of imaging lenses for optical systems, my education, knowledge, skills,
`
`and my review and analysis of the materials referenced herein.
`
`2.
`
`I am being compensated for my work in this matter at the rate of $425
`
`per hour. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the outcome of this matter or the substance of my testimony.
`
`II.
`
`Summary of Opinions
`
`3.
`
`In the preparation of this declaration, I have reviewed:
`
`• The ’032 patent. ’032 IPR, Ex. 1001;
`
`• The ’712 patent. ’712 IPR, Ex. 1001;
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`• Prosecution history of the ’032 patent. ’032 IPR, Ex. 1002.
`
`• Prosecution history of the ’712 patent. ’712 IPR, Ex. 1002.
`
`• The Declaration of Jose Sasian submitted in the ’032 IPR proceeding.
`’032 IPR, Ex. 1003;
`
`• The Declaration of Jose Sasian submitted in the ’712 IPR proceeding.
`’712 IPR, Ex. 1003;
`
`• U.S. Patent No. 9,128,267 (“Ogino”). Ex. 1005;
`
`• Warren J. Smith, Modern Lens Design (1992). Ex. 1006;
`
`• U.S. Patent No. 7,918,398 to Li et al. (“Li”). Ex. 1007;
`
`• U.S. Patent No. 7,777,972 to Chen et al. (“Chen”). Ex. 1008;
`
`• U.S. Patent No. 8,233,224 (“Chen II”). Ex. 1009;
`
`• Max Born et al., PRINCIPLES OF OPTICS, 6th Ed. (1980). Ex. 1010;
`
`• Ex. 1012, identified as Jane Bareau et al., “The optics of miniature
`digital camera modules,” SPIE Proceedings (2006) (“Bareau”). Ex.
`1012;
`
`• U.S. Patent No. 3,388,956 (“Eggert”). Ex. 1013;
`
`• Japanese Patent Pub. No. JP2013106289 to Konno et al. Ex. 1014;
`
`• Certified English translation of JP2013106289 (“Konno”). Ex. 1015;
`
`• Bruce J. Walker, OPTICAL ENGINEERING FUNDAMENTALS (1995)
`(“Walker). Ex. 1016;
`
`• Robert E. Fischer, Biljana Tadic-Galeb, Paul R. Yoder, OPTICAL
`SYSTEM DESIGN, 2nd Ed., 2008,.Ex. 2003;
`
`• U.S. Patent No. 8,395,851 (“Tang”). Ex. 2004;
`
`• U.S. Patent Publication No. 2011/0249346. Ex. 2005;
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`• U.S. Patent Publication No. 2011/0279910, Ex. 2006;
`
`• U.S. Patent Publication No. 2011/0261470. Ex. 2007;
`
`• Transcript of the February 15, 2019 Deposition of Dr. Jose Sasian in
`the ’032 and ’712 IPR proceedings. Ex. 2008.
`
`4.
`
`In forming the opinions set forth herein, I have considered:
`
`a. The documents listed above.
`
`b. My education, knowledge, skills, and experience in the design
`
`and development of imaging lenses for optical systems; and
`
`c. The level of skill of a person having ordinary skill in the art
`
`(POSITA) at the time of the effective filing dates of the ’032 and
`
`’712 patents.
`
`5.
`
`It is my professional and expert opinion that Ogino does not anticipate
`
`claims 1 and 13 of the ’032 patent, that it would not be obvious to combine Ogino
`
`and Chen without hindsight based on knowledge of the ’032 patent’s invention,
`
`disclosures and claims, and claims 14 and 15 of the ’032 patent are not obvious over
`
`the combination of Ogino and Chen.
`
`6.
`
`It is my professional and expert opinion that Konno does not anticipate
`
`claims 1, 12-13, 15-16, and 19 of the ’712 patent, that it would not have been obvious
`
`to modify Konno in view of Bareau without hindsight based on knowledge of the
`
`’712 patent’s invention, disclosure and claims, and claims 6 and 14 are not obvious
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`over Konno in view of Bareau. It is also my professional and expert opinion that
`
`Eggert does not anticipate claims 15-17 of the ’712 patent.
`
`III. Educational and Employment Background
`
`7.
`
`As indicated in my Curriculum Vitae, attached as Exhibit 2002, I
`
`received my Ph. D. in Optics from the University of Rochester in New York in 1974.
`
`I also received an M.S. in Optics from the University of Rochester in 1970 and a
`
`B.A. in Physics from the University of Maine in 1969.
`
`8.
`
`As further described in my Curriculum Vitae, I am the Rudolf and Hilda
`
`Kingslake Professor of Optical Engineering at the University of Rochester, and have
`
`held that position since 1993. I have been a Professor at the Institute of Optics at the
`
`University of Rochester since 1986, and before that I held the titles of Assistant
`
`Professor and then Associate Professor at the Institute of Optics at the University of
`
`Rochester, starting in 1974. I have also served as Dean of the School of Engineering
`
`and Applied Sciences at the University of Rochester from 1995 to 1997. In all, I
`
`have conducted optics research and taught optics to both undergraduate and graduate
`
`students for more than 40 years.
`
`9.
`
`I also have extensive professional experience in the fields of optics and
`
`engineering. I worked for Western Electric Engineering Research Center from 1969-
`
`1971 where I was responsible for the design and fabrication of specialized lens
`
`systems. Beginning in 1971, I performed consulting and design services for gradient-
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`index lens systems and conventional lens systems. In 1980, I founded and became
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`President of the Gradient Lens Corporation. From 1997-2000, I was an Associate
`
`Director of Technology at the White House Office of Science and Technology
`
`Policy. From 2002-2004, I was President and Chief Executive Officer of Infotonics
`
`Technology Center. My Curriculum Vitae (Exhibit 2002) details various other
`
`professional positions I have held in the fields of optics and engineering over the last
`
`40 years.
`
`10.
`
`I have held several advisory positions, including Special Advisor to the
`
`Director, White House Office of Science and Technology Policy, Executive Office
`
`of the President in 2001 and Senior Science Advisor to the Optical Society of
`
`America from 2001 to 2003. I am a Fellow of the Optical Society of America, the
`
`International Society for Optical Engineering (SPIE), American Association for the
`
`Advancement of Science, IEEE and the American Institute for Medical and
`
`Biological Engineering for my work in optics. I was also the Chairman of the Hubble
`
`Space Telescope Independent Optical Review Panel for NASA from 1990 to 1991.
`
`This committee determined the correct prescription to repair the Hubble Telescope.
`
`I am currently the Chairman of the Product Integrity Team verifying the optics for
`
`the future replacement for the Hubble, the James Webb Telescope – which, unlike
`
`the Hubble, will not be serviceable.
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`11.
`
`I have been awarded numerous honors over the course of my career
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`including Election to the National Academy of Engineering (membership
`
`comprising 0.1% of all engineers in the U.S.), Engineer of the Year by Rochester
`
`Engineering Society, National Engineering Award from the American Association
`
`of Engineering Societies, Optical Society of America Leadership Award, the
`
`International Society for Optical Engineering (SPIE) Gold Medal, and the Edwin
`
`Land Medal of the Society for Imaging Science and Technology and the Optical
`
`Society of America (OSA).
`
`12.
`
`I have authored or co-authored almost 90 publications in the field of
`
`optics and I was an editor of several books on Optics. I have given over 150
`
`presentations on optics. I am an inventor of 17 U.S. patents related to optics.
`
`IV. Level of Ordinary Skill in the Art (POSITA)
`
`13.
`
`I understand that in evaluating the validity of the ’032 patent and ’712
`
`patent claims, the content of a patent or printed publication prior art should be
`
`interpreted the way a person of ordinary skill in the art would have interpreted the
`
`prior art as of the effective filing date of these challenged patents.
`
`14.
`
`I understand that factors that may be considered in determining the level
`
`of ordinary skill in the art at the time of the effective filing date of the challenged
`
`patents include:  (1) the educational level of the inventor;  (2) type of problems
`
`encountered in the art;  (3) prior art solutions to those problems;  (4) rapidity with
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`which innovations are made;  (5) sophistication of the technology;  and (6)
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`educational level of active workers in the field.
`
`15.
`
`In my opinion, a person of ordinary skill in the art (POSITA) of the
`
`’032 and ’712 patents, at the time of the effective filing date, would have possessed
`
`an undergraduate degree in optical engineering, electrical engineering, or physics,
`
`with the equivalent of three years of experience in optical design.
`
`16.
`
`I understand that the ’032 patent is a continuation of U.S. App. No.
`
`14/367,294, filed as PCT App. No. PCT/IB2014/062465, which has the benefit of
`
`priority to U.S. Provisional App. No. 61/842,987, filed on July 4, 2013. See ’032
`
`IPR, Ex. 1001, 1. I understand that the ’712 patent is a continuation of the application
`
`that issued as the ’032 patent, and U.S. Provisional App. No. 61/842,987, filed on
`
`July 4, 2013. See ’712 IPR, Ex. 1001, 1. I understand that the effective filing date of
`
`both the ’032 and ’712 patent is July 4, 2013. I note that Dr. Sasian appears to have
`
`applied this date in his analysis of the level of ordinary skill as well. ’032 IPR, Ex.
`
`1003, 8; ’712 IPR, Ex. 1003, 9.
`
`V. Relevant Legal Standards for Anticipation and Obviousness
`
`17.
`
`I have been informed of the legal standards for establishing patent
`
`invalidity in inter partes review proceedings before the Patent Trial and Appeal
`
`Board.
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`18.
`
`I understand that the petitioner must prove invalidity of a patent claim
`
`by a preponderance of the evidence, that is, the evidence must be sufficient to show
`
`that a fact or legal conclusion is more likely than not.
`
`19.
`
`I understand that a claim may be anticipated if (1) the claimed invention
`
`was patented, described in a printed publication, or in public use, on sale, or
`
`otherwise available to the public before the effective filing date of the claimed
`
`invention; or (2) the claimed invention was described in a patent or published
`
`application, in which the patent or application names another inventor and was
`
`effectively filed before the effective filing date of the claimed invention.
`
`20.
`
`I understand that, once the claims of a patent have been properly
`
`construed, the next step in determining anticipation of a patent claim requires a
`
`comparison of the properly construed claim language to the prior art on a limitation-
`
`by-limitation basis.
`
`21.
`
`I understand that a prior art reference “anticipates” an asserted claim,
`
`and thus renders the claim invalid, if all elements of the claim are disclosed in that
`
`prior art reference. In determining whether every one of the elements of the claimed
`
`invention is found in the prior art, I understand that one should take into account
`
`what a person of ordinary skill in the art would have understood from his or her
`
`examination of the particular prior art. I also understand that the prior art reference
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`alleged to be anticipatory must also enable one of ordinary skill in the art to make
`
`the claimed invention without undue experimentation.
`
`22.
`
`I understand that anticipation must be found in a single reference,
`
`device, or process. In other words, anticipation does not allow an additional
`
`reference to supply a missing claim limitation. I further understand that the prior art
`
`reference must disclose all elements of the claim within the four corners of the
`
`document. I further understand that the reference must disclose those elements
`
`arranged as in the claim, and that the disclosure not be so sparse and ambiguous for
`
`a person of ordinary skill to understand it to be disclosing the claim. I understand
`
`that in order for an element to be considered inherently disclosed by a reference, it
`
`must necessarily, and not simply likely, be present in light of the disclosure.
`
`23. Moreover, I understand that any differences between a prior art
`
`reference and a claimed invention invoke the question of obviousness, not
`
`anticipation. In other words, I understand it is not sufficient for a prior art reference
`
`to disclose part of a claimed invention or that it includes multiple distinct teachings
`
`that one of ordinary skill in the art might somehow combine to achieve the claimed
`
`invention. The prior art reference must disclose the claimed invention without any
`
`need for combining various disclosures not directly related to each other. I further
`
`understand that an ambiguous prior art reference cannot be anticipatory.
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`24.
`
`I understand that even if a patent claim is not anticipated, it may still be
`
`invalid if the differences between the claimed subject matter and the prior art are
`
`such that the subject matter as a whole would have been obvious at the time the
`
`invention was made to a person of ordinary skill in the pertinent art.
`
`25.
`
`I also understand that a patent may be rendered obvious based on an
`
`alleged prior art reference or a combination of such references plus what a person of
`
`ordinary skill in the art would understand based on his or her knowledge and the
`
`references. It is also my understanding that in assessing the obviousness of claimed
`
`subject matter one should evaluate obviousness over the prior art from the
`
`perspective of one of ordinary skill in the art at the time the invention was made (and
`
`not from the perspective of either a layman or a genius in that art).
`
`26.
`
`I understand that a patent claim composed of several elements is not
`
`proved obvious merely by demonstrating that each of its elements was known in the
`
`prior art. There must be a reason for combining the elements in the manner claimed.
`
`That is, there must be a showing that a person of ordinary skill in the art at the time
`
`of the invention would have thought of either combining two or more references or
`
`modifying a reference to achieve the claimed invention.
`
`27.
`
`I understand
`
`that an obviousness determination
`
`includes
`
`the
`
`consideration of the following factors: (1) the scope and content of the prior art, (2)
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`the differences between the prior art and the claims at issue, (3) the level of ordinary
`
`skill in the art, and (4) objective evidence of nonobviousness.
`
`28.
`
`I understand that the burden is on the petitioner to explain how specific
`
`references could be combined, which combinations of elements in specific
`
`references would yield a predictable result, and how any specific combination would
`
`operate or read on the claims. I further understand that the petitioner cannot rely on
`
`conclusory statements but must instead provide a reasoned explanation supported by
`
`evidence. I also understand that obviousness does not exist where the prior art
`
`discourages or teaches away from the claimed invention.
`
`29.
`
`I understand that it is impermissible to use hindsight to arrive at the
`
`claimed invention. My understanding is that the inventor’s own path never leads to
`
`a conclusion of obviousness. I also understand that, when assessing whether there
`
`was a motivation to combine references to teach a claim element, defining the
`
`problem in terms of its solution reveals improper hindsight.
`
`30.
`
`I also understand that in evaluating whether patent claims are invalid as
`
`obvious, objective indicia of nonobviousness are considered. Such objective indicia
`
`of nonobviousness can include unexpected results, and, (a) long-felt and unmet need
`
`in the art that was satisfied by the invention of the patent; (b) failure of others to
`
`achieve the results of the invention; (c) commercial success or lack thereof of the
`
`products and processes covered by the invention; (d) deliberate copying of the
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`invention by others in the field; (e) taking of licenses under the patent by others; (f)
`
`whether the invention was contrary to the accepted wisdom of the prior art; (g)
`
`expression of disbelief or skepticism by those skilled in the art upon learning of the
`
`invention; (h) unexpected results achieved by the invention; (i) praise of the
`
`invention by others skilled in the art; and (j) lack of contemporaneous and
`
`independent invention by others.
`
`31.
`
`I understand that, in this proceeding, prior art to the ’032 and ’712
`
`patents includes patents and printed publications in the relevant art that predate the
`
`effective filing date of the ’032 and ’712 patents’ challenged claims, which I
`
`understand to be July 4, 2013. See supra ¶ 15.
`
`VI. Background
`
`A. Overview of the ’032 Patent and ’712 Patent
`
`32.
`
`I understand that the patents at issue in this case are Patent Owner
`
`Corephotonics’ ’032 and ’712 patents. ’032 IPR, Ex. 1001; ’712 IPR, Ex. 1001. I
`
`understand that these lens patents share a common specification.
`
`33. The ’032 and ’712 patents are directed to fixed-focal length telephoto
`
`lens assembly technology with a small thickness and good quality imaging
`
`characteristics. ’032 IPR Ex. 1001 at 1:36-381. The ’032 and ’712 patents
`
`1 To simplify the discussion, in this section of my report I only provide citations to
`the ’032 patents as the ’032 and ’712 patents share a common specification.
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`advantageously teach and claim such compact telephoto assemblies for application
`
`in digital camera modules that are used in digital camera modules used in mobile
`
`devices, such as cellular telephones. Id. at 1:23-38. The ’032 and ’712 patents state
`
`that they thus provide a miniature lens assembly with a small total track length (TTL)
`
`and small ratio of TTL to the effective focal length (EFL) of the lens assembly to
`
`meet the need of a small camera for use in mobile devices and with better image
`
`quality than existing lens assemblies. Id. at 1:36-38, 2:4-8.
`
`34. The total track length (TTL) determines how long or thick a camera
`
`will be. The smaller the TTL, the thinner and more compact the camera. The
`
`effective focal length (EFL) determines how well the camera performs at capturing
`
`images of small or distant objects, as opposed to closer objects. A lens with a greater
`
`EFL is able to capture images of such objects at greater distances and create a
`
`magnified image. By increasing the EFL, the field of view (FOV) is narrowed. This
`
`allows the camera to view things that are further away, which allows them to be
`
`resolved better because the focal length has changed. If a sensor size stays constant,
`
`then the field of view gets smaller. This means, for example, that if the user sees
`
`trees farther away, the camera with a longer focal length lens will provide an image
`
`that can resolve precise features like the tree branches. An increase the focal length
`
`will reduce the FOV. In a system with two cameras with different fixed focal lengths,
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`then each camera will show a different level of magnification of objects in the scene.
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`The one with a higher magnification will appear to be “zoomed in.”
`
`35. The ’032 and ’712 patents explain that the prior art conventional
`
`assemblies did not have good image quality or TTL/EFL properties suitable for use
`
`in telephoto cameras in mobile devices. Ex. 1001 at 1:23-35. In particular, the ’032
`
`and ’712 patents are directed to providing a ratio of TTL to EFL (TTL / EFL) less
`
`than 1, which provides a narrower field of view than a standard cell phone camera.
`
`The ’032 and ’712 patents also provide a small TTL, which is suitable for use in a
`
`mobile device, such as a cell phone. Ex. 1001, 1:29-32 (“Cameras in cellphone
`
`devices in particular require a compact imaging lens system for good quality imaging
`
`and with a small total track length (TTL).”); 4:40-42; 5:57-58, 7:28-30
`
`(embodiments providing TTL of 5.904 mm, 5.9 mm, and 5.904 mm respectively).
`
`36. The ’032 and ’712 patents are also directed to a low F-number (F#).
`
`The F# in a single lens element is the ratio of the focal length of a lens to the aperture
`
`diameter of the lens. The F# determines the exposure time of the lens system, i.e.,
`
`how much light the sensor will be exposed to. The F# is also related to lens
`
`resolution and depth of field. All of the exemplary embodiments in the ’032 and ’712
`
`patents have a F# less than 2.9. ’032 IPR, Ex. 1001 at 4:35-37, 5:50-52, 6:15-16.
`
`37. The ’032 and ’712 patents’ embodiments and claims describe lens
`
`assemblies that follow design rules for the shapes of lens surfaces (convex, concave,
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`meniscus), the focal lengths of individual lenses, thicknesses of lenses, air gaps
`
`between lenses, and material properties, such as the Abbe number. The ’032 and
`
`’712 patents’ claims describe ranges and relationships between the properties of the
`
`lenses in the assembly. For example, claim 1 of the ’032 patent provides as follows:
`
`1. A lens assembly, comprising: a plurality of refractive lens elements
`
`arranged along an optical axis, wherein at least one surface of at least
`
`one of the plurality of lens elements is aspheric, wherein the lens
`
`assembly has an effective focal length (EFL), and wherein the lens
`
`assembly has a total track length (TTL) of 6.5 millimeters or less and a
`
`ratio TTL/EFL of less than 1.0, wherein the plurality of lens elements
`
`comprises, in order from an object side to an image side, a first lens
`
`element with positive refractive power and a second lens element with
`
`negative refractive power, wherein a focal length f1 of the first lens
`
`element is smaller than TTL/2.
`
`Claim 1 of the ’712 patent provides as follows:
`
`1. A lens assembly, comprising: a plurality of refractive lens elements
`
`arranged along an optical axis, wherein at least one surface of at least
`
`one of the plurality of lens elements is aspheric, wherein the lens
`
`assembly has an effective focal length (EFL), a total track length (TTL)
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`of 6.5 millimeters or less and a ratio TTL/EFL of less than 1.0, and
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`wherein the plurality of lens elements comprises, in order from an
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`object side to an image side, a first lens element with a focal length f1
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`and positive refractive power, a second lens element with a focal length
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`f2 and negative refractive power and a third lens element with a focal
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`length f3, the focal length f1, the focal length f2 and the focal length f3
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`fulfilling the condition 1.2×|f3|>|f2|>1.5×f1.
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`38. The ’032 and ’712 patents disclose three exemplary embodiments.
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`Below this paragraph is a reproduction of Fig. 3A from the ’712 patent, which shows
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`embodiment “300.” ’712 IPR, Ex. 1001, 6:65-8:19. In this diagram, the “object”
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`side, where the scene or object being viewed would be, i.e., in front of the camera,
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`is to the left, and the “image” side, where the image is projected, i.e., back of the
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`camera, is to the right. Fig. 3A also shows the result of a ray-trace simulation through
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`the lens assembly of embodiment 300. The specification discloses that embodiment
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`300 provides an EFL of 6.84 mm and TTL of 5.904 mm. Ex. 1001, 5:15-17. The
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`specification discloses that the lens assembly has a FOV (field of view) of 44
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`degrees, and that the TTL/EFL ratio is 0.863. Ex. 1001, 5:15-17.
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`39. Element 312 in Fig. 3A above is a cover glass, which is positioned
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`before the image sensor location. Element 312 is a cover glass (also known as cover
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`glass window or cover plate). The cover glass has at least two important functions
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`in a lens system. The cover glass protects the sensitive surface of the electronic
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`sensor. This is particularly important because in the manufacturing process, there
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`can be damage to the electronic sensor, for example because of dust, which will
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`damage the sensor and make it unusable. This problem is described, for example, in
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`the Bareau article, which Apple included as an exhibit to its petitions, and which
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`points to “contamination” close to image sensor as a particular problem for miniature
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`cameras. Ex. 1012, 2-3. 2) The cover glass also cuts off infrared light before reaching
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`the sensor. This ensures that the sensor responds only to visible light from the objects
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`that the user takes a picture of, so that the resulting image accurately shows the
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`visible light in the scene.
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`B. Multiple Element Lens Design
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`40. The design parameters of a lens assembly include, among others: 1) the
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`properties of lens materials (index of refraction, as well as the Abbe number, which
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`describes the dispersion of refraction in the lens); 2) shapes of the optical surfaces
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`of the lenses; 3) thicknesses of each of the lenses; 4) distances between each of the
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`lens elements as well as the face of the image sensor; 5) the precise contours of the
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`front (object-facing) and back (image-facing) surfaces of the lenses; 6) the aperture
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`stop size and location.
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`41. The optical surfaces of the lenses are determined by radii of curvature
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`and “aspheric coefficients.” To achieve improved performance by reducing spherical
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`aberrations, astigmatism, and other problems with image quality, lens assemblies
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`employ “aspheric” lens shapes, which are more complex than ordinary spherical
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`lenses. The “aspheric coefficients” are parameters of a mathematical equation that
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`defines a curve in space. The curve defined by that equation defines the curvature of
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`the lens. The equation that defines the curvature of lenses is provided in the ’032 and
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`’712 patents as follows:
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`42.
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`In the above equation, r is distance from (and perpendicular to) the
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`optical axis, k is the conic coefficient, c=1/R where R is the radius of curvature, and
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`the α’s are aspheric coefficients. Each surface (front and back) of each lens is defined
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`by a combination of numbers for each of the above parameters. Calculating the
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`above equation will generate a curve that defines the surface. The sum total of all of
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`the parameters of a lens system, including the gaps between lenses, the curvature
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`parameters, indices of refraction, and Abbe numbers, all together are sometimes
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`called a “lens prescription.” See, e.g., Ex. 1006, 62-63. The pathway of light through
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`the lenses is defined by the incidence of rays on the surface of each lens, and then
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`how the material properties of the lenses bends the rays that pass through them.
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`These are shown mathematically, for example, in the ray-trace plots below for
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`various lens system designs.
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`43. The embodiments in the ’032 and ’712 patents describe an arrangement
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`of at least five aspheric lens elements. As a result, there are at least the following
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`parameters that can be varied: the gaps between the five lenses, the sensor, the stop,
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`and window covering the sensor, and thicknesses of these elements (13 parameters
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`as shown in the tables describing embodiments of the ’032 and ’712 patents); the
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`aspheric coefficients and a conic coefficient, k, and radius of curvature, r, for each
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`lens (8 parameters per lens surface or 80 total), and Abbe numbers and refractive
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`indices for each lens (or 10 total for 5 lenses). Therefore, there are 103 parameters
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`that can be independently varied. This leads to a nearly infinite variety of possible
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`lens designs. For example, considering just ten possible values for each of these
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`parameters would require evaluating 10103 combinations of parameter values. This
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`is greater than the number of elementary particles in the observable universe,2 and
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`vastly more designs than could ever be feasibly evaluated. (Another way of looking
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`at it is that there are also 57 “factorial” or 4 * 1076 permutations of parameters in any
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`lens design.)
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`44. Moreover, the interrelationships between these parameters creates
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`increased complexity. Although a computer program can predict what will happen
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`when rays of light go through a lens system, when just looking at the parameters
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`without running a simulation, the relationship between the variables can be nonlinear
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`and unpredictable. The result is a huge design space for a lens designer to explore.
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`And, while computer simulation and optimization techniques can help in aspects of
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`the process, ultimately a significant degree of manual and hand-driven modification
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`is required to arrive at an acceptable design. Also, computational optimization
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`2 h