Petitioner LGE’s Demonstratives
`
`LGE v. Immervision, IPR2020-00179 and IPR2020-00195 (Patent No. 6,844,990 B2)
`
`Citations to the record are exemplary but not exhaustive
`
`LGE’s Demonstratives / Not Evidence
`
`1
`
`LGE Exhibit 1023
`LGE v. ImmerVision - IPR2020-00179
`
`
`
`LGE v. Immervision, IPR2020-00179 and IPR2020-00195 (Patent No. 6,844,990 B2)
`
`Citations to the record are exemplary but not exhaustive
`
`LGE’s Demonstratives / Not Evidence
`
`1
`
`LGE Exhibit 1023
`LGE v. ImmerVision - IPR2020-00179
`
`
`
`I.
`
`II.
`
`III.
`
`Overview of the ’990 Patent
`
`Tada’s Table 5 and Dr. Chipman’s Analysis Thereof
`
`Prima Facie Obviousness based on Tada
`
`LGE’s Demonstratives / Not Evidence
`
`2
`
`
`
`IV.
`
`V.
`
`VI.
`
`Dispute 1: No Obvious Error in Tada’s Table 5
`
`Dispute 2: Dr. Chipman’s Analysis of Table 5 is Accurate
`
`Dispute 3: Increase Tada’s Max. Divergence as Taught by Baker
`
`VII.
`
`Dispute 4: Increase Tada’s Max. Divergence as Taught by Nagaoka
`
`LGE’s Demonstratives / Not Evidence
`
`3
`
`
`
`I. The ’990 Patent
`
`LGE’s Demonstratives / Not Evidence
`
`4
`
`
`
`’990 Patent: Classical Panoramic Objective Lens
`
`Panoramic Objective Lens 15
`Optical Axis OZ
`Digital Image Sensor 17
`Object points a, b, c, d
`Image points a’, b’, c’, d’
`
`Ex. 1001 at Figure 5; Pet. at 5-6.
`
`LGE’s Demonstratives / Not Evidence
`
`5
`
`
`
`’990 Patent: Linearity with Classical Lens
`
`Ex. 1001 at Figures 4A-4B
`
`LGE’s Demonstratives / Not Evidence
`
`6
`
`
`
`’990 Patent: Lens Systems to Achieve Non-Linearity
`
`Ex. 1001 at Figures 7A-7B; 15-16
`
`LGE’s Demonstratives / Not Evidence
`
`7
`
`
`
`’990 Patent: Image Compression and Expansion with Non-Linear Lens
`
`Ex. 1001 at Figure 9; Pet. at 14
`
`LGE’s Demonstratives / Not Evidence
`
`8
`
`
`
`’990 Patent: Use of Classical Computer-Aided Lens Design Tools
`
`Ex. 1001 at 17:29-34 and 18:52-55; Reply at 18-19
`
`LGE’s Demonstratives / Not Evidence
`
`9
`
`
`
`’990 Patent: Challenged Claim 5 (IPR2020-00179)
`
`Ex. 1001 at Claims 1 and 5; Pet. at 5-6.
`
`LGE’s Demonstratives / Not Evidence
`
`10
`
`
`
`’990 Patent: Challenged Claim 21 (IPR2020-00195)
`
`Ex. 1001 at Claims 17 and 21; Pet. at 5-6.
`
`LGE’s Demonstratives / Not Evidence
`
`11
`
`
`
`’990 Patent: No Criticality of ±10% Maximum Divergence
`
`Ex. 1001 at 9:2-12; Pet. at 37; Institution Decision (ID) at 27.
`
`LGE’s Demonstratives / Not Evidence
`
`12
`
`
`
`’990 Patent: Ind. Claims Canceled in Ex Parte Reexamination
`
`Ex. 1001 at pp. 25-27; Pet. at 16-18.
`
`LGE’s Demonstratives / Not Evidence
`
`13
`
`
`
`PO Admits that Nagaoka Discloses ±10% Maximum Divergence
`
`Patent Owner
`
`Ex. 1003 at 331
`
`Pet. at 52-53
`
`LGE’s Demonstratives / Not Evidence
`
`14
`
`Ex. 1003 at 244
`
`
`
`PO Admits that Baker Discloses ±10% Maximum Divergence
`
`Patent Owner
`
`Ex. 1003 at 331
`
`Ex. 1003 at 237
`
`Pet. at 63-66
`
`LGE’s Demonstratives / Not Evidence
`
`15
`
`
`
`II. Tada’s Table 5 and Dr. Chipman’s Analysis Thereof
`
`LGE’s Demonstratives / Not Evidence
`
`16
`
`
`
`Tada’s Table 5
`
`Tada
`
`Ex. 1007 at 8:55-67 and 9:1-29; Pet. at 29-34.
`
`LGE’s Demonstratives / Not Evidence
`
`17
`
`
`
`Tada’s Table 5
`
`Tada
`
`Ex. 1007 at Figure 11; Pet. at 30-32.
`
`LGE’s Demonstratives / Not Evidence
`
`18
`
`
`
`Code V is a Classical Computer-Aided Lens Design Tool
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 51; Pet. at 31-37; Ex. 1015
`
`LGE’s Demonstratives / Not Evidence
`
`19
`
`Exhibit 1015
`
`
`
`Modeling Tada’s Lens Using Table 5 Data
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Data from
`Tada’s Table 5
`
`Ex. 1008 at ¶ 46; Pet. at 31-37.
`
`Software Modeling
`
`Lens Model and Data
`
`LGE’s Demonstratives / Not Evidence
`
`20
`
`
`
`Modeling Tada’s Lens Using Table 5 Data
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 46; Pet. at 31-32
`
`LGE’s Demonstratives / Not Evidence
`
`21
`
`
`
`Modeling Tada’s Lens Using Table 5 Data
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 52; Pet. at 34-37.
`
`LGE’s Demonstratives / Not Evidence
`
`22
`
`
`
`Tada’s Maximum Divergences for Visible Light
`
`Wavelength (nm)
`380
`400
`450
`587
`700
`740
`
`Maximum Divergence (%)
`-9.88
`-9.61
`-9.12
`-8.43
`-8.15
`-8.12
`
`Ex. 1008 at ¶ 68-70; Ex. 1013; Ex. 1012 (visible light definition); Pet. at 47-52
`
`LGE’s Demonstratives / Not Evidence
`
`23
`
`
`
`Modeling Tada’s Lens Using Table 5 Data
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 57; Pet. at 38-39.
`
`LGE’s Demonstratives / Not Evidence
`
`24
`
`
`
`III. Prima Facie Obviousness based on Tada
`
`LGE’s Demonstratives / Not Evidence
`
`25
`
`
`
`Legal Standard: Prima Facie Obviousness
`
`“a prima facie case of obviousness exists when the claimed range and the prior art
`range do not overlap but are close enough such that one skilled in the art would have
`expected them to have the same properties.”
`
`In re Peterson, 315 F.3d 1325, 1329 (Fed. Cir. 2003);
`see also Titanium Metals, 778 F.2d 778, 783 (Fed. Cir. 1985)
`
`“where the general conditions of a claim are disclosed in the prior art, it is not inventive
`to discover the optimum or workable ranges by routine experimentation.”
`In re Aller, 220 F.2d 454, 456 (CCPA 1955)
`
`a finding of prima facie obviousness may be rebutted by establishing that “the claimed
`range is critical, generally by showing that the claimed range achieves unexpected
`results relative to the prior art range.”
`In re Peterson, 315 F.3d at 1330 (quoting In re Geisler,
`116 F.3d 1465, 1469-70 (Fed. Cir. 1997))
`
`ID at 18 and 26; Pet. at 40.
`
`LGE’s Demonstratives / Not Evidence
`
`26
`
`
`
`Petition: Prima Facie Obviousness Based on Tada
`
`Pet. at 40.
`
`LGE’s Demonstratives / Not Evidence
`
`27
`
`
`
`Petition: Prima Facie Obviousness based on Tada
`
`Tada’s Table 5
`
`Software Modeling
`
`Three Zones; Max
`Divergence of -9.88%
`
`Ex. 1008 at ¶ 46; Pet. at 31-37.
`
`LGE’s Demonstratives / Not Evidence
`
`28
`
`
`
`Tada Has Max. Divergence of -8.12% to -9.88%
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 57; Pet. at 38-39.
`
`LGE’s Demonstratives / Not Evidence
`
`29
`
`
`
`Board: Basis for Prima Facie Obviousness Shown in Petition
`
`ID at 27.
`
`LGE’s Demonstratives / Not Evidence
`
`30
`
`
`
`IV. Dispute 1: No Obvious Error in Tada’s Table 5
`
`LGE’s Demonstratives / Not Evidence
`
`31
`
`
`
`Legal Standard: Obvious Error
`
`“the true test of any prior art relied on to show or suggest that a chemical compound is
`old, is whether the prior art is such as to place the disclosed ‘compound’ in the
`possession of the public … Since the listing of CF(3) CF(2) CHClBr in Clements is an
`error obvious to one of ordinary skill in the art, it cannot be said to describe or suggest
`that compound to those in the art.”
`In re Yale, 434 F.2d 666, 668 (BPAI 1970)
`
`“[A]bsent an obvious error on the face of the reference, a reference is prior art for what
`it discloses, even if the commercial system that the reference describes operated
`differently than disclosed in the reference.”
`In re Clark, 420 F. App’x 994, 998
`(Fed. Cir. 2011) (citing In re Garfinkel, 437 F.2d
`1005, 1008 (C.C.P.A. 1971)).
`LGE’s Demonstratives / Not Evidence
`
`32
`
`Reply at 4-7
`
`
`
`Obvious Errors in PO’s Cases – No Modeling Needed
`
`Typographical error that references to layer 17 should have been layer 16
`
`Ex parte Nutalapati, Appeal 2018-004192 (PTAB July 29, 2019)
`
`Reference to millimeters should have been inches
`Ex Parte Darr, Appeal 2011-0111436 (PTAB Oct. 21, 2013)
`
`Reference to molar “M” should have been millimolar “mM”
`Ex parte Okuda, Appeal 2009-015032 (BPAI May 27, 2010)
`
`Reply at 6-7.
`
`0.35 should have been 0.035
`Ex parte Burger, Appeal 2009-004196 (BPAI Oct. 27, 2009)
`LGE’s Demonstratives / Not Evidence
`
`33
`
`
`
`Obvious Error in ’990 Patent
`
`Pet. at 5.
`
`LGE’s Demonstratives / Not Evidence
`
`34
`
`
`
`Another Obvious Error in ’990 Patent
`
`Ex. 1001 at p. 24.
`
`LGE’s Demonstratives / Not Evidence
`
`35
`
`
`
`Tada
`
`Tada
`
`Ex. 1007 at p.1.
`
`LGE’s Demonstratives / Not Evidence
`
`36
`
`
`
`PO’s Expert Modeled Table 5 Lens in Zemax
`
`PO’s Expert
`Mr. David Aikens
`
`Ex. 2009 at ¶ 73
`
`PO Response at 32.
`
`LGE’s Demonstratives / Not Evidence
`
`37
`
`
`
`After, PO’s Expert Spent Hours on Alleged Error
`
`I had figured out that something was wrong
`probably within two to three hours. Then modeling
`the other embodiments, that took time. And then
`continuing to try to understand how to recreate the
`surface, that took more time.”
`
`Ex. 1018 at 137:7-12
`
`And it was how many hours total did I spend
`creating the correct Embodiment 3 model?
`Probably about 10 hours, maybe 12.
`
`Ex. 1018 at 138:1-3
`
`LGE’s Demonstratives / Not Evidence
`
`38
`
`PO’s Expert
`Mr. David Aikens
`
`Reply at 4
`
`
`
`No Obvious Error, Public in Possession of Tada’s Table as it Stands
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Data from
`Tada’s Table 5
`
`Software
`Modeling
`
`Lens Model
`and Data
`
`Ex. 1019 at ¶ 8; Reply at 3
`
`LGE’s Demonstratives / Not Evidence
`
`39
`
`
`
`V. Dispute 2: Dr. Chipman’s Analysis of Table 5 is
`Accurate
`
`LGE’s Demonstratives / Not Evidence
`
`40
`
`
`
`Dr. Chipman’s Analysis of Table 5 is Accurate
`
`Dr. Chipman Correctly Analyzed
`Full Spectrum of Visible Light
`
`Dr. Chipman Correctly Calculated Tada’s
`Image Point Distribution Function
`
`Even with Mr. Aiken’s Changes, Obvious
`to Modify to Reach ±10%
`
`1 2 3
`
`Pet.at 29-46; Reply at 10-19
`
`LGE’s Demonstratives / Not Evidence
`
`41
`
`
`
`Dr. Chipman Analyzed Full Spectrum of Visible Light
`
`1
` Tada’s surveillance camera operates in full spectrum of visible light.
`
`Tada
`
`Ex. 1007 at 1:7-9; Reply at 10
`
`LGE’s Demonstratives / Not Evidence
`
`42
`
`
`
`Dr. Chipman Analyzed Full Spectrum of Visible Light
`
`1
` Tada provides sufficient information to model across the full spectrum
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1019 at ¶12; Reply at 11
`
`LGE’s Demonstratives / Not Evidence
`
`43
`
`
`
`1
`
`Dr. Chipman Analyzed Full Spectrum of Visible Light
`
`PO reads its claims on real images in the full visible light spectrum for
`purposes of alleging infringement of the claims.
`
`Patent Owner
`
`Reply at 10; Ex. 1010 at p 2
`
`LGE’s Demonstratives / Not Evidence
`
`44
`
`
`
`1
`
`Dr. Chipman Analyzed Full Spectrum of Visible Light
`
` PO’s argument that Tada likely used a PMMA material and that PMMA would not
`work well below 400 nm is incorrect.
` First, Tada does not specify the material of the lens.
` Second, PO ignores that there were other types of well-known materials with
`similar Abbe and index numbers, such as K-10 glass, that are better
`transmitters at 380 nm (over 90%, rather than 50%). Ex. 1019, 13.
` Even PO admits that PMMA allows at least some transmission of light across
`the full spectrum. No particular level of transmission is specified in the claims.
` Also, at 400 nm (which is undisputedly within the visible spectrum), the
`maximum divergence is -9.61%.
`
`Reply at 11-12
`
`LGE’s Demonstratives / Not Evidence
`
`45
`
`
`
`Dr. Chipman Correctly Calculated Tada’s Image Point Distribution Function
`
`2
` PO argues that Tada was not concerned with an “image point distribution function.”
`
` PO’s expert admits “image point distribution function” not a term of art. Ex. 1018
`at 70:22-71:10.
` Tada includes distortion plots, which convey same information about the
`compression and expansion characteristics of a lens as “image point distribution
`function.” Ex. 1019, ¶15.
`
`Reply at 12-14
`
`LGE’s Demonstratives / Not Evidence
`
`46
`
`
`
`2
`
`Dr. Chipman’s Chief-Ray Analysis Was Appropriate
`
`PO argues that a centroid analysis should have been conducted instead of chief-ray
`analysis.
`
` Chief ray analysis of Tada was appropriate.
` Centroid analysis not supported by ’990 patent.
` Makes no sense as the information needed to account for vignetting was not
`provided by Tada and instead added by Mr. Aikens.
`
`Reply at 12-14
`
`LGE’s Demonstratives / Not Evidence
`
`47
`
`
`
`Assumptions and Eyeballing Required for Centroid Analysis
`A. And I can’t say that I’ve exactly recreated [Tada’s] vignetting. I can’t do
`that, because he didn’t provide the diameters. But I’ve certainly gotten a lot
`closer.
`
`…A
`
`. As I said, you can get the exact numbers on lens 2. But you're talking about
`how did I pick the diameters of lenses 3, 4, 5, 6, and 7, right?
`
`2
`
`PO’s Expert
`Mr. David Aikens
`
`Q. Right.
`A. Yeah. So the way I did that is I literally had a copy of the figure sitting in
`front of me. This is the Figure 11 from Tada.
`
`Q. Yeah.
`A. And then I just started reducing the aperture until I got something that
`looked like Figure 11. Just visually.
`
`Reply at 14
`
`Ex. 1018 at 225:16-19-226:15
`LGE’s Demonstratives / Not Evidence
`
`48
`
`
`
`2
`
`Assumptions and Eyeballing Required for Centroid Analysis
`
`Q. So you don't take any measurements of the figures?
`A. No, I didn't.
`
`PO’s Expert
`Mr. David Aikens
`
`Q. You sort of eyeballed it?
`A. Yeah. I thought it came out okay. I did what any optical designer would do.
`When you're -- when you've got a heavily vignetted wide field lens and you
`don't know what the vignetting is, you've got to kind of dial it in.
`
`Reply at 14
`
`Ex. 1018 at 229:13-22
`LGE’s Demonstratives / Not Evidence
`
`49
`
`
`
`Routinely Optimize to Reach ±10%
`
`3
` Even with changes, PO’s expert calculates a max. divergence of 7.6%.
`
` Prima facie obviousness remains. No showing that ±10% is critical.
` 7.6% “on the order of 10%,” as greater than the “few percent” “due to the
`possible design errors or manufacturing errors” and provides for “a
`substantial improvement in the definition obtained.” Ex. 1001 at 9:2-12;
`Pet. at 37-46.
`
` Even if ±10% is critical, POSA would routinely optimize to reach that value.
`
`Reply at 14-16
`
`LGE’s Demonstratives / Not Evidence
`
`50
`
`
`
`VI. Dispute 3: Increase Tada’s Max. Divergence
`as Taught by Baker
`
`LGE’s Demonstratives / Not Evidence
`
`51
`
`
`
`PO Admits that Baker Discloses ±10% Maximum Divergence
`
`Patent Owner
`
`Ex. 1003 at 331
`
`Ex. 1003 at 237
`
`Pet. at 63-66
`
`LGE’s Demonstratives / Not Evidence
`
`52
`
`
`
`Petitioner’s Expert Agrees Baker Discloses ±10%
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Pet. at 64-67; Ex. 1008 at ¶ 96
`
`LGE’s Demonstratives / Not Evidence
`
`53
`
`
`
`Motivation Existed to Increase Tada’s Max. Divergence as Taught by Baker
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 99; Pet. at 67-72
`
`LGE’s Demonstratives / Not Evidence
`
`54
`
`
`
`Motivation Existed to Increase Tada’s Max. Divergence as Taught by Baker
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 103; Pet. at 67-72
`
`LGE’s Demonstratives / Not Evidence
`
`55
`
`
`
`PO Argues That Baker Teaches Away
`
`Patent Owner
`
`PO Resp. at 68-69
`
`…
`
`PO Resp. at 68-69
`
`LGE’s Demonstratives / Not Evidence
`
`56
`
`
`
`Baker Claims An Intermediate Zone of Interest
`
`Baker
`
`Ex. 1005 at 19:9-13
`
`Reply at 20-21
`
`LGE’s Demonstratives / Not Evidence
`
`57
`
`
`
`Baker Broadly Applies to Enhanced Portions of Images
`
`Baker
`
`Ex. 1005 at 12:48-55
`
`Pet. at 70
`
`LGE’s Demonstratives / Not Evidence
`
`58
`
`
`
`PO’s Teaching Away is Undermined by Baker and its Expert
`
`Baker
`
`PO’s Expert
`Mr. David Aikens
`
`Reply at 20-22
`
`Ex. 1005 at 13:60-65
`
`Q. [in Baker] So we’re trying -- we’re trying to enhance the image by
`expanding where the people are, right?
`A. Right.
`Q. And if you expand some[]where you got to compress somewhere
`else so we are sort of losing image quality of the ceiling and we’re
`getting better image quality of the people, right?
`A. That is what Baker says, yes.
`
`Ex. 1018 at 268:8-17
`LGE’s Demonstratives / Not Evidence
`
`59
`
`
`
`PO’s Teaching Away is Undermined by Baker and its Expert
`
`A. … The participants are found along the 10- to 30-degree or 45-degree
`segment of the horizon. So he’s saying small table, maybe it’s 45 degrees; big
`table, maybe it’s, you know, 10 or even -- you know, 10 to 30 degrees
`depending on how big the table would be.
`Q. Right.
`
`A. So I took that as a -- anywhere from 80 degrees to 90 or from all the way to
`45 degrees to 90. That’s the potential range of what Baker is talking about.
`
`Q. Well, hold on a second. I mean, it says here found with the image along a
`10 to 30 degrees or 45 degrees. So that’s from 10 to 30 or from 10 to 45,
`right?
`A. Oh, I see your point. Yeah, yeah. So that would be from 80 to 60 degrees.
`
`LGE’s Demonstratives / Not Evidence
`
`60
`
`Ex. 1018 at 268:3-269:4
`
`PO’s Expert
`Mr. David Aikens
`
`Reply at 20-22
`
`
`
`Petitioner’s Expert Agrees: Baker Does Not Teach Away
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Reply at 20-22
`
`LGE’s Demonstratives / Not Evidence
`
`61
`
`Ex. 1019 at ¶ 27
`
`
`
`Petitioner’s Expert Agrees: Baker Does Not Teach Away
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Reply at 20-22
`
`Ex. 1019 at ¶¶ 27-28
`LGE’s Demonstratives / Not Evidence
`
`62
`
`
`
`PO’s Expert: Easy to Go From Two Zones to Three Zones
`Q. But this lens [Figs. 15 and 16 of ’990 patent] doesn’t have a
`compressed center. It has an expanded center. We just looked at
`Figure 7, right?
`
`PO’s Expert
`Mr. David Aikens
`
`A. But there are subtle differences. The design form is the right idea.
`Once you know what you’re trying to do, it’s actually not that hard
`to manipulate the lens to get it to do what you want.
`Two Zones
`Three Zones
`Expanded Center
`Compressed Center
`
`Ex. 1018 at 192:16-195:14
`
`Ex. 1001 at Figures 7B and 9; Reply at 24
`
`LGE’s Demonstratives / Not Evidence
`
`63
`
`
`
`VII. Dispute 4: Increase Tada’s Max. Divergence as
`Taught by Nagaoka
`
`LGE’s Demonstratives / Not Evidence
`
`64
`
`
`
`PO Admits that Nagaoka Discloses ±10% Maximum Divergence
`
`Patent Owner
`
`Ex. 1003 at 331
`
`Pet. at 52-53
`
`LGE’s Demonstratives / Not Evidence
`
`65
`
`Ex. 1003 at 244
`
`
`
`Petitioner’s Expert Agrees Nagaoka Discloses ±10%
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Pet. at 56-58; Ex. 1008 at ¶ ¶ 79-82
`
`LGE’s Demonstratives / Not Evidence
`
`66
`
`
`
`Petitioner’s Expert Agrees Nagaoka Discloses ±10%
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Pet. at 56-58; Ex. 1008 at ¶ ¶ 79-82
`
`LGE’s Demonstratives / Not Evidence
`
`67
`
`
`
`Motivation Existed to Increase Tada’s Max. Divergence as Taught by Nagaoka
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 85; Pet. at 58-63
`
`LGE’s Demonstratives / Not Evidence
`
`68
`
`
`
`Motivation Existed to Increase Tada’s Max. Divergence as Taught by Nagaoka
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Ex. 1008 at ¶ 88; Pet. at 58-63
`
`LGE’s Demonstratives / Not Evidence
`
`69
`
`
`
`Nagaoka Teaches that Greater the Slope, Greater the Benefit
`
`Nagaoka
`
`Ex. 1004 at 2:43-53
`
`Reply at 22
`
`Ex. 1004 at 6:60-65
`LGE’s Demonstratives / Not Evidence
`
`70
`
`
`
`Nagaoka Does Not Teach Away
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Reply at 22-24
`
`LGE’s Demonstratives / Not Evidence
`
`71
`
`Ex. 1019 at ¶ 29
`
`
`
`Nagaoka Does Not Teach Away
`
`Petitioner’s Expert
`Dr. Russell Chipman,
`Professor of Optical Sciences
`
`Reply at 22-24
`
`Ex. 1019 at ¶¶ 31-32
`LGE’s Demonstratives / Not Evidence
`
`72
`
`
`
`PO’s Expert: Easy to Go From Two Zones to Three Zones
`Q. But this lens [Figs. 15 and 16 of ’990 patent] doesn’t have a
`compressed center. It has an expanded center. We just looked at
`Figure 7, right?
`
`PO’s Expert
`Mr. David Aikens
`
`A. But there are subtle differences. The design form is the right idea.
`Once you know what you’re trying to do, it’s actually not that hard
`to manipulate the lens to get it to do what you want.
`Two Zones
`Three Zones
`Expanded Center
`Compressed Center
`
`Ex. 1018 at 192:16-195:14
`
`Ex. 1001 at Figures 7B and 9; Reply at 24
`
`LGE’s Demonstratives / Not Evidence
`
`73
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
