`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`NICHIA CORPORATION,
`
`Petitioner
`
`v.
`
`DOCUMENT SECURITY SYSTEMS, INC.,
`
`Patent Owner
`__________________
`
`Case No. IPR2018-01165
`Patent 7,524,087
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`Nichia Corporation
`v.
`Document Security Systems, Inc.
`IPR2018-01165 (U.S. Patent No. 7,524,087)
`
`ORAL ARGUMENT – AUGUST 28, 2019
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`

`

`U.S. PATENT NO. 7,524,087
`
`SHEARMAN & STERLING
`
`U.S. PATENT N0. 7,524,087
`
`USOOENUBTBI
`
`Il3l United States Patent
`um—
`Aiur et II.
`
`HS] Due of Patent: Apr. 28. 2009
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`
`()P'I'K 7.\|. DEVICE
`
`Filed:
`
`‘ tiled by cumin“
`f'n'nlan‘ Hmnn‘m‘r
`
`(57)
`
`Ilium» M Scnlhur
`
`ABS‘I‘RH '1'
`
`.\n cwmplur)‘ cmhwlimcnt “(an urllcul IIm ice rmy include
`.1 Irml I'nlmt: Will) .I rlumllly ul Icmh and :I n'llcclm Illlfllml
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`.1 |Ir.\1 va Illu- :IrItI .‘I hum; grid u [IL-ri'phmll mic-NIH
`extending human the filsl and fan.- and the Wald law.
`The n-Ik-um iii-using imluiL-i :1 flm [InckL'l with :l pita-r “ >
`opuunn in m:- {1:51deth and a word packet until :I pi‘ckcl
`opening. in tlbc swnnd end face. .\I Icasl uric I I'll die is
`nlmmlal Ill Ihc lilsl puck-I ul Ihc rcIIcUur hnunug. and. n Ilglll
`transmitting cmupululll i9- dispulx'd in [he fim paid and
`cnmpmlafing. IIIL‘ n: Icml um I I-‘Ihlul.
`
`l9 ('IillmmV 6 Drnwlng Sheen
`
`- ........
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Ex. 1001 (’087 Patent)
`
`2
`
`

`

`CLAIMS 1-19 ARE UNPATENTABLE
`
`Claims
`1, 6, 9-19
`
`2, 3, 5
`4
`
`7, 8
`
`Prior Art Grounds
`
`• Obvious over Kamada
`• Obvious over Okazaki in view of Critelli, Kamada, or Kyowa
`• Obvious over Takenaka in view of Critelli, Kamada, or Kyowa
`• Obvious over Takenaka in view of Critelli, Kamada, or Kyowa
`• Obvious over Takenaka in view of Critelli, Kamada, or Kyowa, in further view
`of Cheong
`• Obvious over Kamada in view of Kyowa or Cheong
`• Obvious over Okazaki in view of Kyowa
`• Obvious over Okazaki in view of Critelli or Kamada, in further view of Cheong
`• Obvious over Takenaka in view of Kyowa
`• Obvious over Takenaka in view of Critelli or Kamada, in further view of
`Cheong
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 4-5
`
`3
`
`

`

`CLAIMS 1-8
`
`SHEARMAN & STERLING
`
`CLAIMS 1-8
`
`I. An optical device comprising:
`a lead frame with a plurality of leads:
`a reflector housing formed around the lead frame. the
`rcllectnrhousinghavinga Iirslcnd litceandasecond end
`face and a peripheral sidewall extending between the
`first end face and the second end Iitce. the reflector
`housing IliWIIlg {I first pUCI'LCI Will] {I pOCIiL'l opening in
`the first end face and a second pocket with a pocket
`opening in the Scufmd end face;
`at least one LEI) die mounted in the first pocket of the
`“Emu“, housing;
`a light transmitting encapsulant disposed inthe first pocket
`and encapsulating the at least une nan die: and
`wherein a plurality of lead receiving cmnpanments are
`l'omted in the peripheml sidewall ol‘the reflector Imus-
`mg.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`comprising at least two colors.
`
`2. 'lhe optical device of claim 1. wherein the combined
`volume ol'the second pocket and the lead receiving compan-
`meats is at least 50% of the volume of the first pocket.
`3. The optical device of claim 2. said pluralit}r of leads
`being .l-shaped.
`4_ '11“,- optical device of claim 2. said plurality ol‘ leads
`comprising1 six leads in two rows-
`5_ The optical device of claim 2_ said plurality uf lead
`receiving compm‘unclus being J.§lmpcd_
`
`_
`_
`_
`_
`_
`_
`6. The optical deuce 01 claim I. wherein the plurality ol
`lead receiving compartments define a PIUPJIIW 0f ribs (“5'
`posed between the plurality of lead receiving compartments.
`
`_
`
`7. 'lhe optical device ofclaim 1, said at least one I .lil) die
`comprising three LED dies.
`8. The optical device of claim 7. said three LFD dies
`Ex. 1001 (’087 Patent), claims 1-8
`
`4
`
`

`

`CLAIMS 9-14
`
`SHEARMAN & STERLING
`
`CLAIMS 9-14
`
`9- A display comprising 3 plurality 0f plastic leaded ChlP
`carrier LEDs. the plastic leaded chip carrier LEDs each com-
`Pmmg:
`3 lead frame Wllh 3 plurality 0f leads:
`the
`it reflector housing formed around the lead frame.
`reflector housing having a first end face and a second end
`face and a peripheral sidewall extending between the
`first end face and the second end face. the reflector
`housing havinga cavity in 11“? first end face, "ald periph-
`era] sidewall hat/mg a plurality 01 lead rcccwmg C0111‘
`partments fomied therein:
`at least one ”‘11) die mounted in the cavity ofthe reflector
`housing: and
`a light transmitting encapsulant disposed in the cavity and .
`encapsulating the at least one IFD die.
`
`a stadium display.
`
`10. The display 01' claim 9. said reflector housing further
`comprising. a second cavity in the second end face.
`11_ The display of claim 10. wherein the plurality of lead
`receiving compartments define a plurality of ribs disposed
`between the plurality of lead receiving compartments.
`12. 'lhe display of claim 11. said plurality of leads being
`J-shaped.
`
`13. The display of claim 9. wherein said lead receiving.
`compartments limit inward deflection of said plurality of
`leads.
`'
`
`.
`.
`.
`.
`.
`.
`1-1..le display of claim 9. wherein said display comprises
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claims 9-14
`
`5
`
`

`

`CLAIMS 15-19
`
`SHEARMAN & STERLING
`
`CLAIMS 15-19
`
`15. An illumination system. comprising:
`a reflector housing molded on a lead frame having a plu-
`ralin ofelectrically conductive leads. the reflector hous-
`ing having a first cavity and a second cavity.r on opposite
`sides of the reflector housing:
`at least one LED die mounted in said first cavity and elec-
`trically connected to said plurality of electrically con-
`ductive leads: and
`
`said reflector housing further having a first end face and a
`second end face and a peripheral sidewall extending
`between the first end face and the second end face, the
`
`reflector housing having a cavity in the first end face.
`said peripheral sidewall having a plurality ot‘lead receiv-
`ing compartments formed therein.
`
`prising a stadium display.
`
`16. ‘l'he illumination system of claim 15. wherein said
`plurality of electrically conductive leads have a J-shape.
`
`17. The illumination system of claim 15. further compris-
`ing an encapsulant filling said first cavity around said at least
`one 1 .lil ) die.
`
`18. The illumination system of claim 15. further compris-
`ing a plurality ofother reflector housings each having at least
`one I it'll) die mounted. said reflector housing and said plural-
`ity ol'othcr reflector housings arranged in an array in a dis-
`play.
`
`19.11“? illumination system ol'claim [8. said display com-
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claims 15-19
`
`6
`
`

`

`THE ’087 PATENT
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 7; Ex. 1001 (’087 Patent)
`
`7
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`8
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments …”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`9
`
`

`

`PATENT OWNER’S POSITION: KAMADA DOES NOT DISCLOSE LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Patent Owner Response
`
`* * * *
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 15 (POR) at 22-24
`
`10
`
`

`

`PATENT OWNER’S POSITION: KAMADA DOES NOT DISCLOSE LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 15 (POR) at 22-23
`
`11
`
`

`

`’087 PATENT’S FIGURE 4 AND KAMADA’S RIGHT SIDE VIEW
`
`’087 Patent Figure 4
`
`Kamada “Right Side View”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 15 (POR) at 2, 22-23; Paper 18 (Reply) at 15-16; Ex. 1016 (Shealy
`Reply Decl.) at ¶20; Ex. 1006 (Kamada); Ex. 1001 (’087 Patent)
`
`12
`
`

`

`DR. SHEALY’S TESTIMONY: KAMADA DISCLOSES LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Reply Declaration
`
`Kamada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 11-12; Ex. 1016 (Shealy Reply Decl.) at
`¶14; Ex. 1006 (Kamada)
`
`13
`
`

`

`DR. SHEALY’S TESTIMONY: KAMADA DISCLOSES LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Reply Declaration
`
`Kamada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 14-15; Ex. 1016 (Shealy Reply Decl.) at
`¶21; Ex. 1006 (Kamada)
`
`14
`
`

`

`DR. SHEALY’S TESTIMONY: KAMADA DISCLOSES LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Reply Declaration
`
`Kamada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 15-16; Ex. 1016 (Shealy Reply Decl.) at ¶20;
`Ex. 1006 (Kamada)
`
`15
`
`

`

`EXPERT TESTIMONY: “PERIPHERAL SIDEWALL” “DOESN’T HAVE TO BE
`CONTINUOUS” OR “SOLID”
`
`Mr. Credelle’s Deposition
`
`Dr. Shealy’s Reply Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 16; Ex. 1013 (Credelle Depo.) at 149:18-
`150:6; Ex. 1016 (Shealy Reply Decl.) at ¶¶17-18
`
`16
`
`

`

`DR. SHEALY’S TESTIMONY: KAMADA DISCLOSES LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Reply Declaration
`
`Kamada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 12-13, 15-16; Ex. 1016 (Shealy Reply
`Decl.) at ¶¶15, 19; Ex. 1006 (Kamada)
`
`17
`
`

`

`DR. SHEALY’S TESTIMONY: KAMADA DISCLOSES LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Initial Declaration
`
`Kamada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 20-21, 72-74, 78-79; Paper 18 (Reply) at 10; Ex.
`1003 (Shealy Decl.) at ¶¶54, 85, 266; Ex. 1006 (Kamada)
`
`18
`
`

`

`DR. SHEALY’S TESTIMONY: KAMADA DISCLOSES LEAD RECEIVING
`COMPARTMENTS IN THE REFLECTOR HOUSING’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Reply Declaration
`
`Kamada and the ’087 Patent
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 13-14; Ex. 1016 (Shealy Reply Decl.) at
`¶16; Ex. 1001 (’087 Patent); Ex. 1006 (Kamada)
`
`19
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`20
`
`

`

`PATENT OWNER’S POSITION: “CRITELLI IS DIRECTED TO A DIFFERENT
`ART….”
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claim 1; Paper 15 (POR) at 20-21
`
`21
`
`

`

`DR. SHEALY’S TESTIMONY: CRITELLI DISCLOSES LEAD RECEIVING
`COMPARTMENTS
`
`Dr. Shealy’s Initial Declaration
`
`Critelli
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 2 (Pet.) at 18-20; Ex. 1003 (Shealy Decl.) at ¶¶80-81,
`83; Ex. 1005 (Critelli)
`
`22
`
`

`

`THE BOARD: PATENT OWNER HAS NOT PRESENTED EXPERT TESTIMONY
`
`The Board
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 11 (ID) at 33-34
`
`23
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1,
`10, 15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`24
`
`

`

`CLAIMS 1, 9, 10, 15
`
`SHEARMAN & STERLING
`
`CLAIMS 1, 9,10,15
`
`1. An optical device comprising:
`a lead frame with a plurality ofleads:
`a reflector housing formed around the lead frame. the
`reflectorhousing having a first end face and a second end
`face and a peripheral sidewall extending between the
`first end face and the second end face. the reflector
`housing having
`
`ing.
`
`and a second pocket with a pocket
`opening in the second end face;
`at least one LED die mounted in the first pocket of the
`reflector housing:
`a light transmitting encapsulauit disposed in the lirst pocket
`and encapsulating the at least one [.FD die: and
`wherein a plurality of lead receiving compartments are
`fomied in the peripheral sidewall ol'the reflector hous-
`
`9. A display comprising a plurality ofplastic leaded chip
`carrier LEDs. the plastic leaded chip carrier [, EDs each com-
`prising:
`a lead frame with a plurality of leads:
`a rellector housing formed around the lead fnunc. the
`rellector housing having a first end face and a second end
`face and a peripheral sidewall extending between the
`first end face and the second end face.
`the rellector
`housing l1avi1_ said periph-
`eral sidewall having a plurality of lead receiving coili-
`parlments formed therein:
`at least one [,l-ll) die mounted in the cavity of the reflector
`musing: and
`a light transmitting cncapsulant disposed in the cavity and
`encapsulating the at least one llil) die.
`10. The display of claim 9. said relloclor housing funher
`comprising a second cavity in the second end face.
`
`ing compartments formed therein.
`
`15. An illumination system. comprising:
`a reflector housing molded on a lead frame h. ving. a plu-
`rality ol‘elcttrically conductive leads. the rellector hous-
`ing. having-and a second cavity on opposite
`sides ol'the reflector housing:
`at [cast one LED die mounted in said first cavity and elec-
`trically connected to said plurality of electrically con-
`ductive leads: and
`
`said reflector housing further having a first end face and a
`second end face and a peripheral sidewall extending
`between the first end face and the second end face. the
`
`reflector housing having—
`said peripheral sidewall having a plural ityoflead receiv-
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claims 1, 9, 10, 15
`
`25
`
`

`

`PATENT OWNER’S POSITION: OKAZAKI’S “TUBULAR VESSEL” IS NOT A
`POCKET/CAVITY
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 15 (POR) at 11-13
`
`26
`
`

`

`DR. SHEALY’S TESTIMONY: OKAZAKI DISCLOSES A FIRST AND SECOND
`POCKET/CAVITY
`
`Dr. Shealy’s Initial Declaration
`
`Okazaki Figure 3
`
`Dr. Shealy’s Deposition
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 13-15; Paper 18 (Reply) at 5; Ex. 1003 (Shealy. Decl.)
`at ¶71; Ex. 2016 (Shealy Depo.) at 55:1-18; Ex. 1004 (Okazaki)
`
`27
`
`

`

`DR. SHEALY’S TESTIMONY: OKAZAKI DISCLOSES A FIRST AND SECOND
`POCKET/CAVITY
`
`Okazaki Figures 1 and 3
`
`Dr. Shealy’s Deposition
`
`’087 Patent Figure 4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 13-15; Paper 18 (Reply) at 6-7; Ex. 2016 (Shealy
`Depo.) at 46:9-22; Ex. 1001 (’087 Patent); Ex. 1004 (Okazaki)
`
`28
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`29
`
`

`

`PATENT OWNER’S POSITION: INSUFFICIENT REASONS TO COMBINE
`OKAZAKI WITH CRITELLI, KAMADA, OR KYOWA
`
`Patent Owner Response
`
`* * * *
`
`* * * *
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 15 (POR) at 25-28
`
`30
`
`

`

`THE BOARD: BODILY INCORPORATION OF REFERENCES IS NOT REQUIRED
`
`The Board
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 11 (ID) at 35-36
`
`31
`
`

`

`THE PRIOR ART: OKAZAKI, CRITELLI, KAMADA, AND KYOWA
`
`Okazaki
`
`Kyowa
`
`Kamada
`
`Critelli
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 12-13, 15, 18-25; Paper 18 (Reply) at 13, 16; Ex. 1004
`(Okazaki); Ex. 1005 (Critelli); Ex. 1006 (Kamada); Ex. 1010 (Kyowa)
`
`32
`
`

`

`DR. SHEALY’S TESTIMONY: IT WOULD HAVE BEEN OBVIOUS TO ADD LEAD
`RECEIVING COMPARTMENTS TO OKAZAKI’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Initial Declaration
`
`Critelli
`
`Kyowa
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 25-26; Ex. 1003 (Shealy Decl.) at ¶¶93-94; Ex.
`1005 (Critelli) at 1:56-59, 2:2-4; Ex. 1010 (Kyowa) at ¶0006
`
`33
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`34
`
`

`

`PATENT OWNER’S POSITION: INSUFFICIENT REASONS TO COMBINE
`TAKENAKA WITH CRITELLI, KAMADA, OR KYOWA
`
`Patent Owner Response
`
`* * * *
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 15 (POR) at 34-37
`
`35
`
`

`

`THE PRIOR ART: TAKENAKA, CRITELLI, KAMADA, AND KYOWA
`
`Takenaka
`
`Kyowa
`
`Kamada
`
`Critelli
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 18-25, 47-48, 51-53; Paper 18 (Reply) at 13, 16; Ex. 1005
`(Critelli); Ex. 1006 (Kamada); Ex. 1008 (Takenaka); Ex. 1010 (Kyowa)
`
`36
`
`

`

`DR. SHEALY’S TESTIMONY: IT WOULD HAVE BEEN OBVIOUS TO ADD LEAD
`RECEIVING COMPARTMENTS TO TAKENAKA’S PERIPHERAL SIDEWALL
`
`Dr. Shealy’s Initial Declaration
`
`Critelli
`
`Kyowa
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 53-54; Ex. 1003 (Shealy Decl.) at ¶¶184-85; Ex.
`1005 (Critelli) at 1:56-59, 2:2-4; Ex. 1010 (Kyowa) at ¶0006
`
`37
`
`

`

`DR. SHEALY’S TESTIMONY: PROTECTING TAKENAKA’S LEADS
`
`Takenaka
`
`Kyowa
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 47-48, 51-53; Paper 18 (Reply) at 23-26; Ex. 1003 (Shealy
`38
`Decl.) at ¶¶88-90, 183-84; Ex. 1016 (Shealy Reply Decl.) at ¶¶29-33; Ex.
`1008 (Takenaka); Ex. 1010 (Kyowa); Paper 15 (POR) at 36-37
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`39
`
`

`

`PATENT OWNER’S POSITION: TAKENAKA DOES NOT DISCLOSE THE
`RELATIVE CLAIMED VOLUMES
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claim 2; Paper 15 (POR) at 38
`
`40
`
`

`

`DR. SHEALY’S TESTIMONY: TAKENAKA’S SECOND POCKET IS AT LEAST 50%
`OF ITS FIRST POCKET
`
`Dr. Shealy’s Initial Declaration
`
`Takenaka
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 54-56; Ex. 1003 (Shealy Decl.) at ¶¶
`189-90; Ex. 1008 (Takenaka)
`
`41
`
`

`

`DR. SHEALY’S TESTIMONY: OTHERWISE, IT WOULD HAVE BEEN OBVIOUS TO
`MAKE TAKENAKA’S SECOND POCKET AT LEAST 50% OF ITS FIRST POCKET
`
`Dr. Shealy’s Initial Declaration
`
`Dr. Shealy’s Takenaka
`Annotation (at Deposition)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 54-56; Paper 18 (Reply) at 26-27; Ex. 1003 (Shealy
`Decl.) at ¶191; Ex. 2016 (Shealy Depo.) at 31:1-33:13; Ex. 2017 (Shealy
`Depo. Annotation)
`
`42
`
`

`

`TAKENAKA’S SECOND POCKET IS TAUGHT TO BE “AS LARGE AS POSSIBLE”
`
`Second
`Pocket
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 54-56; Ex. 1008 (Takenaka) at ¶0044
`
`43
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`44
`
`

`

`PATENT OWNER’S POSITION: NO MOTIVATION TO USE J-SHAPED LEADS
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claims 3, 12, 16;
`Paper 15 (POR) at 31
`
`45
`
`

`

`DR. SHEALY’S TESTIMONY: OBVIOUS TO USE J-SHAPED LEADS
`
`Dr. Shealy’s Initial Declaration
`
`Khandpur: Printed Circuit Boards
`
`Kitamura
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 32; Ex. 1003 (Shealy Decl.) at ¶120; Ex.
`1009 (Khandpur) at 7-8; Ex. 1012 (Kitamura) at ¶0001
`
`46
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`47
`
`

`

`PATENT OWNER’S POSITION: PRIOR ART DOES NOT MENTION LIMITING
`INWARD DEFLECTION
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claim 13; Paper 15 (POR) at 32
`
`48
`
`

`

`DR. SHEALY’S TESTIMONY: PRIOR ART LEAD RECEIVING
`COMPARTMENTS LIMIT INWARD DEFLECTION
`
`Critelli
`
`Dr. Shealy’s Initial Declaration
`
`Kyowa
`
`Kamada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 33-35; Ex. 1003 (Shealy Decl.) at ¶¶125-26;
`Ex. 1005 (Critelli); Ex. 1006 (Kamada); Ex. 1010 (Kyowa)
`
`49
`
`

`

`DR. SHEALY’S TESTIMONY: PRIOR ART LEAD RECEIVING
`COMPARTMENTS LIMIT INWARD DEFLECTION
`
`Dr. Shealy’s Reply Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 23; Ex. 1016 (Shealy Reply Decl.) at ¶¶29-31
`
`50
`
`

`

`DR. SHEALY’S TESTIMONY: PRIOR ART LEAD RECEIVING
`COMPARTMENTS LIMIT INWARD DEFLECTION
`
`Dr. Shealy’s Reply Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 23; Ex. 1016 (Shealy Reply Decl.) at ¶¶32-33
`
`51
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obvious to combine Takenaka with Critelli, Kamada, or Kyowa?
`
`Does Takenaka disclose that “the combined volume of the second pocket and the lead receiving
`compartments is at least 50% of the volume of the first pocket,” or would claim 2 otherwise have
`been obvious?
`
`Would it have been obvious to form the prior art leads in a J-shape?
`
`Do the prior art lead receiving compartments “limit inward deflection” of the leads?
`
`Would it have been obvious to arrange the prior-art packages in an array?
`
`Does “stadium” operate to limit the claimed “display”; does the prior art disclose “stadium
`displays”?
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Claim(s)
`
`1, 9, 15
`
`1, 9, 15
`
`1, 9, 10, 15
`
`1, 9, 15
`
`1, 9, 15
`
`2
`
`3, 12, 16
`
`13
`
`18
`
`14, 19
`
`52
`
`

`

`PATENT OWNER’S POSITION: PRIOR ART DOES NOT
`TEACH THE REQUIRED ARRAY
`
`Patent Owner Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’087 Patent), claim 18; Paper 15 (POR) at 33
`
`53
`
`

`

`DR. SHEALY’S TESTIMONY: ’087 PATENT ADMITS
`PRIOR ART DISPLAYS ARE ARRANGED IN ARRAYS
`Dr. Shealy’s Reply Declaration
`
`’087 Patent
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 24-25; Ex. 1016 (Shealy Reply Decl.) at ¶23; Ex. 1001
`(’087 Patent) at 1:5-11
`
`54
`
`

`

`DR. SHEALY’S TESTIMONY: PRIOR ART TEACHES DISPLAYS
`ARRANGED IN ARRAYS
`
`Dr. Shealy’s Initial Declaration
`
`Okazaki
`
`Kamada
`
`Takenaka
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 1 (Pet.) at 40-41, 66; Ex. 1003 (Shealy Decl.) at ¶¶152, 244; Ex. 1004
`(Okazaki) at 1:17-20; Ex. 1006 (Kamada) at 6-7; Ex. 1008 (Takenaka) at
`¶0037
`
`55
`
`

`

`DR. SHEALY’S TESTIMONY: PRIOR ART TEACHES DISPLAYS
`ARRANGED IN ARRAYS
`
`Dr. Shealy’s Reply Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Paper 18 (Reply) at 24-25; Ex. 1016 (Shealy Reply Decl.) at ¶¶25-26
`
`56
`
`

`

`KEY REMAINING DISPUTES
`
`Key Remaining Disputes
`Does Kamada disclose “a plurality of lead receiving compartments … formed in the peripheral
`sidewall of the reflector housing”?
`
`Does Critelli disclose “a plurality of lead receiving compartments…”?
`
`Does Okazaki disclose a first pocket/cavity (claims 1, 9, 15) or a second pocket/cavity (claims 1, 10,
`15)?
`
`Would it have been obvious to combine Okazaki with Critelli, Kamada, or Kyowa?
`
`Would it have been obviou