UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`LG ELECTRONICS INC.,
`Petitioner,
`
`v.
`
`IMMERVISION, INC.,
`Patent Owner.
`____________
`
`IPR2020-00179, -00195
`U.S. Patent No. 6,844,990
`____________
`
`DECLARATION OF RUSSELL CHIPMAN, PH.D. REGARDING CODE V
`
`LGE Exhibit 1017
`LGE v. ImmerVision - IPR2020-00179
`Page 1 of 5
`
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`LG ELECTRONICS INC.,
`Petitioner,
`
`v.
`
`IMMERVISION, INC.,
`Patent Owner.
`____________
`
`IPR2020-00179, -00195
`U.S. Patent No. 6,844,990
`____________
`
`DECLARATION OF RUSSELL CHIPMAN, PH.D. REGARDING CODE V
`
`LGE Exhibit 1017
`LGE v. ImmerVision - IPR2020-00179
`Page 1 of 5
`
`
`
`IPRs of U.S. Patent No. 6,844,990 (IPR2020-00179, -00195)
`Declaration of Dr. Russell Chipman
`
`
`I, Russell Chipman, hereby declare the following:
`
`
`1. My name is Russell Chipman and I am over 21 years of age and
`
`otherwise competent to make this Declaration. I make this Declaration based on
`
`facts and matters within my own knowledge and on information provided to me by
`
`others, and, if called as a witness, I could and would competently testify to the
`
`matters set forth herein.
`
`2.
`
`I have been retained as a technical expert witness in this matter by
`
`Counsel for Petitioner LG Electronics Inc. to provide my independent opinions on
`
`certain issues requested by Counsel for Petitioner relating to the petitions for Inter
`
`Partes Review of U.S. Patent No. 6,844,990 (“the ’990 Patent”). My compensation
`
`in this matter is not based on the substance of my opinions or the outcome of this
`
`matter. I have no financial interest in Petitioner. I have been informed that
`
`ImmerVision, Inc. (“ImmerVision”) is the purported owner of the ’990 Patent, and
`
`I note that I have no financial interest in ImmerVision. I previously submitted a
`
`declaration dated November 27, 2019, which I understand was submitted with the
`
`Petitions filed as Exhibit 1008 by the Petitioner.
`
`3.
`
`A summary of my relevant experience and qualifications are set forth
`
`in that November 27, 2019 declaration and my curriculum vitae, which I
`
`understand is Ex. 1009 to these proceedings.
`
`1
`
`LGE Exhibit 1017
`LGE v. ImmerVision - IPR2020-00179
`Page 2 of 5
`
`
`
`IPRs of U.S. Patent No. 6,844,990 (IPR2020-00179, -00195)
`Declaration of Dr. Russell Chipman
`
`4.
`
`As I mentioned in my prior declaration, the Code V software merely
`
`
`
`performs mathematical calculations applying well known principles of optics and
`
`physics, which have not changed in any material respects since at least the early
`
`2000s. (Ex. 1008, ¶ 51). In other words, the physics and optics of lenses do not
`
`change over time, i.e., the prior art lens system has the same physical and optical
`
`properties whether they are calculated using a current Version of Code V, whether
`
`they are calculated using an earlier version of Code V, whether they are calculated
`
`using other lens design software, or even whether they are calculated by hand. I
`
`have personally used the Code V software in connection with optical lens design
`
`since the late 1970s beginning with my work for Beckman Instruments from 1978-
`
`1981 as an Optical Engineer. I used Code V extensively for my course work and
`
`research for my M.S. in Optical Science that I obtained in 1984 and my Ph.D. in
`
`Optical Sciences which I received in 1987. I continued to use Code V in
`
`connection with my work and my research from that time and still use Code V to
`
`this day.
`
`5.
`
`I have used Code V to perform an analyses similar to that which I
`
`performed and described in connection with my prior declaration since at least
`
`1978. Since that time, the Code V ray trace algorithms that calculate the paths of
`
`light rays as the rays refract through lens systems have not operated differently in
`
`any relevant aspects.
`
`2
`
`LGE Exhibit 1017
`LGE v. ImmerVision - IPR2020-00179
`Page 3 of 5
`
`
`
`IPRs of U.S. Patent No. 6,844,990 (IPR2020-00179, -00195)
`Declaration of Dr. Russell Chipman
`
`6.
`
`I have been provided with a copy of the 1978 Designer’s Manual for
`
`
`
`Code V (Ex. 1014). I have reviewed the manual and its description of Code V is
`
`consistent with my recollection of how Code V operated around that time.
`
`Accordingly, the manual appears to be a true and correct copy of the 1978
`
`Designer’s Manual.
`
`7.
`
`I have also personally located a copy of the Code V Version 7.6
`
`Reference Manual (Feb. 1994), relevant excerpts of which are provided as Ex.
`
`1015. I have reviewed the manual and its description of Code V is consistent with
`
`my recollection of how Code V operated around that time. Accordingly, the
`
`Reference Manual appears to be a true and correct copy of the 1994 Version 7.6
`
`Reference Manual. Moreover, the 1994 Reference Manual describes each of the
`
`same operations and functions of the software that I used to perform the analysis I
`
`performed in connection with my prior declaration and confirms these operations
`
`and functions were available prior to 2001. The principles of optics and physics
`
`that Code V relies on for performing these calculations have not changed during
`
`this time, so I know of no reason to believe that the Code V software from 1994 (or
`
`1978) would provide any materially different results to the more recent versions of
`
`the Code V software.
`
`8.
`
`In addition, I have reviewed an article from Proceedings Volume 0766
`
`(1987) of the Society of Photo-Optical Instrumentation Engineers (SPIE), Recent
`
`3
`
`LGE Exhibit 1017
`LGE v. ImmerVision - IPR2020-00179
`Page 4 of 5
`
`
`
`IPRs of U.S. Patent No. 6,844,990 (IPR2020-00179, -00195)
`Declaration of Dr. Russell Chipman
`
`Trends in Optical Systems Design and Computer Lens Design Workshoptitled “A
`
`Technical Overview of CODE V Version 7” (Ex. 1016) by Bruce R.Irving of
`
`Optical Research Associates, which was the company that developed Code V at
`
`that time. The article further evidences the wide availability of Version 7 of the
`
`Code V software prior to 2001.
`
`9.
`
`I declare that all statements made herein of my knowledgearetrue,
`
`and that all statements made on information andbelief are believed to be true, and
`
`that these statements were made with the knowledgethat willful false statements
`
`and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Executed on June 4, 2020 in Tucson, Arizona.
`
` Russell Chipman,
`
`LGE Exhibit 1017
`
`LGEv. ImmerVision - IPR2020-00179
`
`oe mo
`
`Page 5 of 5
`
`LGE Exhibit 1017
`LGE v. ImmerVision - IPR2020-00179
`Page 5 of 5
`
`
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