IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG DISPLAY CO., LTD. AND DELL INC.,
`Petitioner,
`
`v.
`
`SOLAS OLED, LTD.,
`Patent Owner.
`
`Patent No. 6,072,450
`
`DECLARATION OF ADAM FONTECCHIO, PH.D.
`
`SAMSUNG EX. 1007 - 1/108
`
`

`

`I.
`
`BACKGROUND AND QUALIFICATIONS ................................................. 2
`
`II. MATERIALS CONSIDERED ........................................................................ 5
`
`III. RELEVANT LEGAL STANDARDS ............................................................. 6
`
`a.
`
`b.
`
`Anticipation ........................................................................................... 6
`
`Obviousness ........................................................................................... 7
`
`IV. BACKGROUND OF MATRIX DISPLAYS .................................................. 9
`
`a.
`
`b.
`
`Passive Matrix Displays ...................................................................... 10
`
`Active Matrix Displays ....................................................................... 11
`
`V. OVERVIEW OF U.S. PATENT 6,072,450 .................................................. 14
`
`a.
`
`b.
`
`c.
`
`Summary ............................................................................................. 14
`
`File History .......................................................................................... 21
`
`The Claims at Issue ............................................................................. 22
`
`VI. LEVEL OF ORDINARY SKILL IN THE ART ........................................... 28
`
`VII. CLAIM CONSTRUCTION .......................................................................... 29
`
`VIII. OVERVIEW OF THE PRIOR ART ............................................................. 30
`
`a.
`
`Utsugi (U.S. Patent No. 5,670,792) .................................................... 30
`
`b. Manabe (Ex. 1004) .............................................................................. 35
`
`c.
`
`Eida (WO 96/25020) ........................................................................... 36
`
`IX. DISCLOSURE OF CLAIMS 1–2, 4–8, AND 15–16 BY UTSUGI ............. 39
`
`a.
`
`b.
`
`Claim 1 ................................................................................................ 39
`
`Dependent Claim 2 .............................................................................. 51
`
`ii
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`

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`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`h.
`
`Dependent Claim 4 .............................................................................. 51
`
`Dependent Claim 5 .............................................................................. 54
`
`Dependent Claim 6 .............................................................................. 55
`
`Dependent Claim 7 .............................................................................. 57
`
`Dependent Claims 8 and 16 ................................................................ 63
`
`Claim 15 .............................................................................................. 65
`
`X.
`
`THE SUGGESTION OF CLAIMS 1–2, 4–8, AND 15–16 BY UTSUGI .... 79
`
`a.
`
`b.
`
`c.
`
`Claim 1[c] ............................................................................................ 79
`
`Dependent Claims 8 and 16 ................................................................ 81
`
`Claim 15[f] and 15[j/k] ....................................................................... 83
`
`XI. THE COMBINATION OF UTSUGI AND MANABE (CLAIM 3) ............ 85
`
`a.
`
`Dependent Claim 3 .............................................................................. 89
`
`XII. THE COMBINATION OF UTSUGI AND EIDA (CLAIMS 9, 11–13, and
`17–18) ............................................................................................................ 91
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`Dependent Claim 9 .............................................................................. 94
`
`Dependent Claim 11 ............................................................................ 95
`
`Dependent Claim 12 ............................................................................ 98
`
`Dependent Claim 13 ............................................................................ 99
`
`Dependent Claim 17 ..........................................................................102
`
`Dependent Claim 18 ..........................................................................103
`
`iii
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`

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`I, Adam Fontecchio, Ph.D., declare as follows:
`1.
`
`I have been retained as a technical consultant by Samsung Display Co.,
`
`Ltd., who I have been informed is one of the petitioners in the present proceeding,
`
`as well as on behalf of Samsung Electronics Co., Ltd. and Samsung Electronics
`
`America, Inc., who I have been informed are identified as “real parties in interest”
`
`in the present proceeding. For ease of reference, throughout my declaration, I will
`
`refer to these entities collectively as “Samsung.” I am also informed that Dell Inc.
`
`is a co-petitioner in the present proceeding. Again, for ease of reference, throughout
`
`my declaration, I will refer to Samsung Display Co., Ltd. and Dell Inc. together as
`
`“Petitioner.”
`
`2.
`
`I have been asked by counsel for the Petitioner to consider whether the
`
`references listed as Exhibits 1001-1006 and 1009–1011 below disclose or suggest,
`
`alone or in combination, the limitations recited in the claims of U.S. Patent 6,072,450
`
`(the “’450 patent”). I have also been asked to consider the state of the art and the
`
`prior art available before the filing of the ’450 patent. I have provided my opinions
`
`below.
`
`3.
`
`I have been informed that a company known as Solas OLED Ltd.
`
`alleges to be the owner of the ’450 patent. To the best of my knowledge, I have no
`
`financial interest in Samsung, Dell, Solas OLED Ltd., or the ’450 patent. To the
`
`best of my recollection, I have had no contact with Solas OLED Ltd. or the named
`
`1
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`

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`inventors of the patent, Hiroyasu Yamada, Tomoyuki Shirasaki, and Yoshihiro
`
`Kawamura. To the extent any mutual funds or other investments that I own have a
`
`financial interest in Samsung, the Patent Owner, or the ’450 patent, I am not aware
`
`of, nor do I have control over, any financial interest that would affect or bias my
`
`judgment.
`
`4.
`
`I am being compensated at my standard consulting rate for my time,
`
`and my compensation is in no way contingent on the results of these or any other
`
`proceedings relating to the above-captioned patent.
`
`I.
`
`BACKGROUND AND QUALIFICATIONS
`
`5.
`
`I am a professor of electrical engineering specializing in electro-optics
`
`and displays. I have studied and researched the function and use of numerous types
`
`of display technologies, including TFT-LCD, Holographically-formed Polymer
`
`Dispersed Liquid Crystal (H-PDLC) displays, Electrophoretic Displays (EPD),
`
`nano-Field Emission Displays (nFED), and novel electroluminescent displays
`
`including organic light emitting materials. I have conducted extensive research on
`
`color filtering, reflective and transmissive displays, and the fundamental interactions
`
`of light and matter. I have published numerous articles and delivered many lectures
`
`and research talks on these subjects.
`
`6.
`
`I have been employed as a faculty member at Drexel University since
`
`2002. Currently, my rank is that of tenured Full Professor. I served as the Vice-
`
`2
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`Dean of the Graduate College at Drexel University from 2015–2017, and from 2013-
`
`2015 served as an Associate Dean of the College of Engineering at Drexel
`
`University. Prior to my current position, I was a graduate student at Brown
`
`University, working under the direction of Prof. Gregory Crawford, where I
`
`conducted doctoral research on new technologies to be used in displays. While
`
`studying at Brown University, I completed a Bachelor’s degree in Physics in 1996,
`
`a Master’s degree in Physics in 1998, and a Doctorate degree in Physics in 2002.
`
`7.
`
`During my career as a doctoral student, researcher, and faculty member
`
`at Drexel University, I have conducted and directed research that is related, and of
`
`interest, to the display community. I have presented my research and findings at
`
`professional organizations and conferences including the Society for Information
`
`Display, the Optical Society of America, the American Physical Society, the
`
`Materials Research Society, and the International Liquid Crystal Society.
`
`8. My research into electro-optic phenomena and devices, as well as my
`
`work in engineering education initiatives, has been sponsored by both government
`
`agencies and private industry. My government sponsors have included the National
`
`Science Foundation, NASA, the Department of Energy, the National Institute of
`
`Standards and Technology (NIST), the US Army CERDEC, the Pennsylvania
`
`Department of Health, and the Department of Education.
`
`3
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`9.
`
`I am a Senior Member of the IEEE, have served as Vice-Chair of the
`
`IEEE Philadelphia Branch, and am a member of the American Society for
`
`Engineering Education (ASEE).
`
`10.
`
`I have worked as a consultant on technical issues, including electro-
`
`optics and displays, for private clients primarily offering technical guidance,
`
`contracted research services, or expert testimony. In the course of my work as a
`
`faculty member and as a consultant, I have visited microfabrication and display
`
`fabrication facilities around the world and witnessed the fabrication process first-
`
`hand.
`
`11. While a doctoral student at Brown University, I studied the morphology
`
`and structure of liquid crystal based devices. Nanoscale microscopy and imaging
`
`was a significant part of my thesis work, and I have significant experience with
`
`scanning electron microscopy (“SEM”), atomic force microscopy (“AFM”), and
`
`surface structure profilometry. For my final two years of graduate school, I served
`
`as the in-house expert on SEM, performing the majority of SEM imaging and
`
`analysis for the entire research group.
`
`12. At Drexel University, my research has included microfabrication and
`
`associated characterization methods, including SEM analysis. I spent several years
`
`rebuilding a class 1000 cleanroom with a class 100 wet lab clean room included,
`
`which became the shared Micro Fabrication Facility (“MFF”). I also served as
`
`4
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`Director of Micro/Nano Fabrication, A. J. Drexel Nanotechnology Institute, Drexel
`
`University, where I oversaw the acquisition, installation, and operation of
`
`microfabrication instrumentation for over 100 users/researchers.
`
`13.
`
`In summary, I have extensive familiarity with fields involving displays.
`
`Based on my experience, as well as my review of the literature, I am familiar with
`
`what the state of this field was at the relevant time up to the time that the ’450 patent
`
`was filed.
`
`14.
`
`In addition to my education and work experience that I have outlined
`
`above, a complete list of my work experience, awards, honors, and publications that
`
`may be relevant to the opinions are set forth in my CV (Exhibit 1008).
`
`II.
`
`MATERIALS CONSIDERED
`
`15.
`
`I am not an attorney and I am not offering any legal opinions as part of
`
`this declaration. However, through my consulting work I have had experience
`
`studying and analyzing patents and patent claims from the perspective of a person
`
`of ordinary skill in the art.
`
`16.
`
`I have reviewed the ’450 patent—both the claims and specification, as
`
`well as the associated prosecution history. In addition, I have reviewed a number of
`
`prior art references. I have provided below a complete list of materials considered
`
`in rendering the opinions found in this declaration.
`
`5
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`

`

`Exhibit Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1009
`
`1010
`
`1011
`
`U.S. Patent No. 6,072,450 (the “’450 patent”)
`
`File History for U.S. Patent No. 6,072,450
`
`U.S. Patent No. 5,670,792 (“Utsugi”)
`
`JPH053079 (certified translation, “Manabe”)
`
`WO 96/25020 (certified translation, “Eida”)
`
`S.W. Amos, Principles of Transistor Circuits, 8th Ed. (1994)
`
`JPH053079 (“Manabe”)
`
`WO 96/25020 (“Eida”)
`
`U.S. Patent No. 5,847,516 (“Kishita”)
`
`III.
`
`RELEVANT LEGAL STANDARDS
`
`17. As I noted earlier, I am not an attorney and do not provide any legal
`
`opinions as part of this declaration. However, for the purposes of this declaration, I
`
`have been informed about certain aspects of the law by the attorneys for Petitioner
`
`that are relevant to forming my opinions. Below is a summary of the law that has
`
`been explained and provided to me.
`
`a. Anticipation
`
`18. Petitioner’s counsel has informed me that a patent claim may be
`
`“anticipated” if each element of that claim is present either explicitly or inherently
`
`in a single prior art reference, and that the elements should be arranged in the
`
`reference as in the claim. Petitioner’s counsel has informed me that for a claimed
`
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`limitation to be inherently present, the prior art need not expressly disclose the
`
`limitation, so long as the claimed limitation necessarily flows from a disclosure in
`
`the prior art.
`
`b. Obviousness
`
`19. Petitioner’s counsel has informed me that even if all of the requirements
`
`of a claim are not found in a single prior art reference, the claim is not patentable if
`
`the differences between the subject matter in the prior art and the subject matter in
`
`the claim would have been obvious to a person of ordinary skill in the art at the time
`
`the application was filed.
`
`20. Petitioner’s counsel has informed me that a determination of whether a
`
`claim would have been obvious should be based upon several factors, including,
`
`among others:
`
`a) the level of ordinary skill in the art at the time the application was filed;
`
`b) the scope and content of the prior art; and
`
`c) what differences, if any, existed between the claimed invention and the
`
`prior art.
`
`21. Petitioner’s counsel has informed me that a single reference can render
`
`a patent claim obvious by itself if any differences between that reference and the
`
`claims would have been obvious to a person of ordinary skill in the art.
`
`Alternatively, the teachings of two or more references may be combined in the same
`
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`way as disclosed in the claims, if such a combination would have been obvious to
`
`one having ordinary skill in the art. In determining whether a combination based on
`
`either a single reference or multiple references would have been obvious, it is
`
`appropriate to consider, among other factors:
`
`a) whether the teachings of the prior art references disclose known
`
`concepts combined in familiar ways, and when combined, would yield
`
`predictable results;
`
`b) whether there is some teaching or suggestion in the prior art to make
`
`the modification or combination of elements claimed in the patent;
`
`c) whether the innovation applies a known technique that had been used
`
`to improve a similar device or method in a similar way.
`
`d) whether a person of ordinary skill would have recognized a reason to
`
`combine known elements in the manner described in the claim;
`
`e) whether a person of ordinary skill in the art could implement a
`
`predictable variation, and would see the benefit of doing so; and
`
`f) whether the claimed elements represent one of a limited number of
`
`known design choices, and would have a reasonable expectation of
`
`success by those skilled in the art.
`
`22. Petitioner’s counsel has informed me that one of ordinary skill in the
`
`art has ordinary creativity and is not an automaton. Petitioner’s counsel has
`
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`informed me that in considering obviousness, it is important not to determine
`
`obviousness using the benefit of hindsight derived from the patent being considered.
`
`23. Petitioner’s counsel has informed me that under specific circumstances
`
`whereby a secondary reference is not being used to teach a limitation but rather to
`
`explain the teachings of a primary reference, a specific motivation to combine need
`
`not be identified; however, in the case of the combination of art discussed in this
`
`declaration, a specific motivation to combine is present and I have identified it.
`
`24. Petitioner’s counsel has also informed me that, in this proceeding, the
`
`claim terms should be given their plain and ordinary meaning as understood by one
`
`of ordinary skill in the art, consistent with the disclosure and the prosecution history.
`
`IV.
`
`BACKGROUND OF MATRIX DISPLAYS
`
`25. According to the face of the patent, the ’450 patent was filed on
`
`November 21, 1997, but claims priority to two Japanese references filed on
`
`November 28, 1996. Ex. 1001 at cover. Accordingly, for purposes of my discussion
`
`below, I assume that the timeframe of the purported invention of the ’450 patent was
`
`November 1996, and have provided an overview of the background of matrix
`
`displays by this timeframe. In particular, I have provided a brief discussion of
`
`passive and active matrix displays, as they relate to the ’450 patent.
`
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`a. Passive Matrix Displays
`
`26. Passive matrix addressing is a convenient method of addressing a large
`
`array of pixels when using a top to bottom electrode system. This particular method
`
`works through orthogonal rows and columns of individually electrically controlled
`
`electrodes located on the top and bottom of the switchable sample. By activating a
`
`row on the top and a column on the bottom, only in the intersection of the row and
`
`column is there a large enough electric field to completely activate the pixel.
`
`27. Figure 1 of Utsugi, reproduced below, shows the basic configuration of
`
`a passive matrix display. As shown in the figure, conductors form rows and columns
`
`for the top and bottom electrodes, depicted here as scan line 153 and signal line 151.
`
`An organic emission layer, like the organic emission layer 152B, can be formed
`
`between the electrodes. Applying a voltage bias to a row and column will cause a
`
`voltage difference great enough to activate the pixel at the intersection of the
`
`activated row and column, e.g., for the pixel to turn on and emit light.
`
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`
`
`28. Historically, the passive matrix system was employed primarily for
`
`large arrays where running a trace to each pixel is space prohibitive. Passive
`
`addressing has some significant limitations, such as the inability to create a ring
`
`structure, or a structure with a cutout in the center. In addition, as discussed by the
`
`’450 patent, in order to ensure that each pixel holds its image for the entire frame,
`
`i.e., for the time it takes to address every scan line, high voltages are often necessary
`
`to create an adequate electric field. See, e.g., Ex. 1001 at 1:30–37.
`
`b. Active Matrix Displays
`
`29.
`
` Active matrix addressing was designed in an effort to overcome the
`
`issues encountered in multiplexing devices like passive matrix displays, by way of
`
`adding individual modulation of each pixel using a pixel-by-pixel switch. The
`
`dominant technology used in active matrix addressing is thin film transistor (“TFT”)
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`technology. Originally demonstrated as a potential driving element in 1966 by RCA,
`
`transistors act as individual on-off switches at each pixel.
`
`30.
`
`In an active matrix display, each individual pixel contains at least one
`
`thin film transistor and a storage capacitor. Rows and columns of the display are
`
`then used to control the transistors, which in turn modulate the current across the
`
`organic emission layer. The basic configuration of a TFT array for an active matrix
`
`display is demonstrated, for instance, in Figure 2 of Utsugi, shown below.
`
`
`
`31. The process of generating a dynamic image via active matrix
`
`addressing requires a few sequential steps. First, the gate voltage of a transistor, for
`
`example, the switching transistor QS in Figure 1, is applied on the scan line. Ex.
`
`1003 at 3:4–5. The capacitor is then charged based on the parameter of the data line,
`
`e.g., the signal electrode line 101M, which feeds into the source of the transistor. Ex.
`
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`1003 at 3:5–7. This turns on the current-controlling transistor QI and allows current
`
`to flow across the electroluminescent element of the pixel. Ex. 1003 at 3:7–10.
`
`32.
`
`In the second step, the switching transistor’s gate voltage sets the
`
`transistor to turn off. Once this occurs, the next scan line is activated. When the
`
`switching transistor is turned off, the time constant of the capacitor holds the
`
`intensity of the pixel at a relatively constant value while the remaining scan lines are
`
`scanned, generating a complete frame. Ex. 1003 at 3:7–10.
`
`33. Finally, this entire process is repeated, with the state of each pixel being
`
`redefined by the next image. This scanning process continues to repeat, creating a
`
`moving and dynamic display through the continual actuation of all the pixels.
`
`34. Row and column drivers are generally attached to the edges of the TFT
`
`array glass substrate to supply the address and data signals to the pixels. The row
`
`and column drivers receive their signals from one or more controller circuits
`
`mounted on a printed circuit board.
`
`35. Given the superior picture quality, speed, and driving voltages, active
`
`matrix technology is the primary driving method in use today for displays. Since
`
`the late 1990s and early 2000s, it has taken over from passive matrix displays, and
`
`it is unusual to find passive matrix drive methods in any significant display
`
`technology today.
`
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`36. Active matrix technology has been used with multiple types of flat
`
`panel displays, including liquid crystal displays (LCDs), as well as the organic
`
`electroluminescent displays described in the ’450 patent and the prior art. In organic
`
`electroluminescent displays, which make use of organic light emitting diodes
`
`(OLEDs), a voltage is applied to one or more layers of organic semiconductor
`
`material(s), which will emit light of various wavelengths, based on the composition
`
`of the layer(s). Active matrix OLED display technology is commonly referred to as
`
`AMOLED.
`
`V.
`
`OVERVIEW OF U.S. PATENT 6,072,450
`
`a. Summary
`
`37. According to the cover of the patent, the ’450 patent is entitled “Display
`
`Apparatus,” and it was filed on November 21, 1997. Ex. 1001 at cover. In the “Field
`
`of the Invention” section of the patent, the ’450 patent states that the “[p]resent
`
`invention relates
`
`to a display apparatus, and more particularly
`
`to an
`
`electroluminescent (hereinafter referred to as EL) display apparatus with a matrix
`
`display panel including EL elements.” Ex. 1001 at 1:5–8. As I have explained
`
`above, by the November 28, 1996 foreign filing date, matrix display panels including
`
`electroluminescent elements were well-known. Ex. 1001 at 1:11–14.
`
`38. The ’450 patent acknowledges that matrix display panels were known
`
`prior to the filing date, but claims to solve two particular problems with conventional
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`matrix displays, i.e., to provide a display which (1) “has a light emitting area
`
`enlarged so as to emit light at a satisfactorily high luminescence even though a
`
`voltage applied to an EL layer is low, and which has long luminance life,” and (2)
`
`“prevents light from entering active elements such as transistors, to thereby avoid
`
`the malfunction of the active elements.” Ex. 1001 at 2:66–3:7.
`
`39. By way of background on these issues, the ’450 patent describes the
`
`passive matrix technology used in earlier electroluminescent displays. In passive
`
`matrix EL displays, a matrix is formed through a grid of perpendicular cathode lines
`
`(serving as common lines) and anode lines (serving as data lines), and an organic EL
`
`layer is situated between the two. Ex. 1001 at 1:14–21. “A positive voltage is
`
`applied to the data lines in each of cathode selection periods, thereby driving organic
`
`EL elements located at the intersections of the common lines and the data lines.”
`
`Ex. 1001 at 1:21–24. “The display apparatus displays an image which corresponds
`
`to the voltage applied to the data lines.” Ex. 1001 at 1:24–25.
`
`40.
`
`In such displays, displaying an entire frame consists of cycling through
`
`each cathode line, selecting one line at a time. The period over which the EL element
`
`will continue to emit light after the cathode selection period is short; accordingly,
`
`conventional passive matrix displays increased the luminance of the organic EL
`
`layer of each pixel by applying a higher voltage to the organic EL layer during the
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`selection period. Ex. 1001 at 1:30–39. However, raising the voltage across the EL
`
`layer can lead to its deterioration. Ex. 1001 at 1:40–41.
`
`41. Active matrix displays address this particular problem by including a
`
`pair of transistors, “which confer a voltage storing capability on the pixels.” Ex.
`
`1001 at 1:47–51. As shown in Figure 22 of the ’450 patent below, which discloses
`
`“related art,” Ex. 1001 at 5:12–13, each pair of transistors consists of a selection
`
`transistor T1 and drive transistor T2, Ex. 1001 at 1:51–52. The selection transistor
`
`T1 is connected to the data line DL, and the gate of the selection transistor T1 is
`
`connected to the address or gate line GL. Ex. 1001 at 1:52–55. The gate electrode
`
`of the drive transistor T2 is connected to the selection transistor T1. Ex. 1001 at
`
`1:55–56. The source of the drive transistor T2 is connected to a constant voltage
`
`line VL, and the drain of the drive transistor T2 is connected to the anode electrode
`
`103 of the EL device. Ex. 1001 at 1:56–65.
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`
`42. When the selection transistor T1 is turned on by the gate line GL, image
`
`data is passed through T1 to the drive transistor T2, turning T2 on and off. When
`
`T2 is on, a current flows from the constant voltage line VL through T2, a first
`
`electrode (the anode electrode 103), an organic EL layer 106, and a second electrode
`
`(the cathode electrode 107), causing the EL layer to emit light. See Ex. 1001 at 2:2–
`
`6. I will refer to the first electrode, the organic EL layer, and the second electrode
`
`as the “EL structure.”
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`43. As the ’450 patent explains, the transistors used in the active matrix can
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`be sensitive to light. When light enters the channel of the transistors, it can cause
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`“unnecessary photoelectromotive force,” which causes
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`the
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`transistors
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`to
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`malfunction. Ex. 1001 at 2:27–32. Accordingly, in bottom-emitting devices, there
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`is a concern with locating the TFTs under the electroluminescent device, as light
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`from the electroluminescent layer could then enter the TFTs.
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`44. As shown in Figure 22 above, and as explained by the ’450 patent,
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`conventionally, this problem was addressed by limiting the light emitting area of
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`each pixel “to an area in which the thin film transistors T1 and T2 are not located.”
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`Ex. 1001 at 2:32–37. By avoiding the region of the pixel where the transistors are
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`located, the overall light emitting area of the pixel is decreased.
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`45. The ’450 patent solves these issues through the use of a particular
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`structure, wherein the TFTs of each pixel are covered by all three elements of the
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`organic EL structure, including the first electrode (cathode), the organic
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`electroluminescent layer, and the second electrode (anode). This structure can be
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`seen in Figure 2 of the ’450 patent below.
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`46. As shown in Figure 2, the selection transistor Q1 and the drive transistor
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`Q2 are formed on the substrate 2. The organic EL structure is formed above the
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`TFTs, such that the first electrode (cathode electrode 15), the organic EL layer 16,
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`and the second electrode (anode 17) cover the TFTs. The first electrode (cathode
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`15) is made of a light-blocking material that prevents light from entering the TFTs
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`and reflects light back out of the top of the device.
`
`47. Because the TFTs are shielded from the light emitted from the organic
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`EL layer 16, the EL structure can be formed over nearly the entirety of the pixel area,
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`as shown in Figure 1 of the ’450 patent below.
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`48.
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`In addition to the structure described above, the ’450 patent also
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`includes embodiments that make use of wavelength conversion layers and/or color
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`filters. These layers allow for a multicolor display. An example of such a structure
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`is shown in Figure 12 below. The wavelength conversion layers, such as layers 52R,
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`52G, and 52B absorb light emitted from the organic EL layer 16 and emit light in a
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`different wavelength (e.g., absorb blue light and emit red and green light). Ex. 1001,
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`11:47–65. As their name implies, the color filters, such as 55R, 55G, and 55B filter
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`the light, permitting only certain wavelengths to pass, which results in a higher color
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`purity. Ex. 1001, 12:49–13:17.
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`b. File History
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`49. As part of the preparation of my declaration, I have reviewed the file
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`history for U.S. Application No. 08/976,217, the application that led to the ’450
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`patent. The original independent claims of the application were rejected by the
`
`Examiner as either anticipated or rendered obvious by the prior art. Ex. 1002 at 154–
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`162 (August 31, 1999 Non-Final Rejection).
`
`50.
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`In response to the Examiner’s rejections, the applicants amended
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`independent claim 1 and former independent claim 16 (issued claim 15) to include,
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`among other things, limitations that the electroluminescent layer be formed of an
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`organic electroluminescent material, and
`
`to
`
`require
`
`that
`
`the organic
`
`electroluminescent material and second electrode cover the active elements. Ex.
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`1002 at 294–307 (November 30, 1999 Amendment). In their “Remarks,” the
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`applicants generally differentiated the prior art based on any of the following: (1)
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`the prior art comprised an electroluminescent layer that was not organic, Ex. 1002
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`at 304 (November 30, 1999 Amendment); (2) the prior art did not include the
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`claimed arrangement of the first electrode, organic electroluminescent layer, and the
`
`second electrode all covering the active elements, Ex. 1002 at 305; or (3) that the
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`prior art did not disclose the specific layer formation order for preventing thermal
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`deterioration, i.e., forming the organic EL layer after forming the transistors, so as
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`not to expose the organic EL layer to high temperatures, Ex. 1002 at 305.
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`51.
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`In response to the applicant’s arguments, the Examiner allowed the
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`claims.
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`c. The Claims at Issue
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`52. For purposes of this declaration, I have been asked to address claims 1–
`
`9, 11–13, and 15–18. For reference, I have provided the language of each of those
`
`claims below:
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`1. A display apparatus comprising: a substrate; active elements
`
`formed over said substrate and driven by an externally supplied
`
`signal; an insulation film formed over said substrate so as to cover
`
`said active elements, said insulation having at least one contact hole;
`
`at least one first electrode formed on said insulation film so as to
`
`cover said active elements, and connected to said active elements
`
`through said at least one contact hole, said at least one first electrode
`
`being made of a material which shields visible light; an organic
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`electroluminescent layer having an organic electroluminescent
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`material formed on said at least one first electrode so as to cover said
`
`active elements and including at least one layer which emits light in
`
`accordance with a voltage applied to said at least one layer; and at
`
`least
`
`one
`
`second
`
`electrode
`
`formed
`
`on
`
`said
`
`organic
`
`electroluminescent layer which covers said active elements.
`
`2. The display apparatus according to claim 1, wherein said at
`
`least one first electrode is formed of a conductive material
`
`containing magnesium.
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`3. The display apparatus according to claim 1, wherein said at
`
`least one first electrode has a rough surface which is in contact with
`
`said organic electroluminescent layer.
`
`4. The di