UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.; AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`NEODRON LTD.,
`Patent Owner.
`
`____________
`
`Case No. IPR2020-00308
`U.S. Patent No. 10,365,747 B2
`
`DECLARATION OF RICHARD A. FLASCK
`
`1
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 1
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`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.; AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`NEODRON LTD.,
`Patent Owner.
`
`____________
`
`Case No. IPR2020-00308
`U.S. Patent No. 10,365,747 B2
`
`DECLARATION OF RICHARD A. FLASCK
`
`1
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 1
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`I.
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`1.
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`INTRODUCTION
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`I have been retained as an expert in this case by Neodron Ltd. (“Neodron”). I
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`have been asked to consider and opine on issues of validity regarding U.S.
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`Patent No. 10,365,747 (“the ’747 Patent”).
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`2.
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`In forming my opinions, I have reviewed, considered, and had access to the
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`patent specifications and claims, their prosecution histories, the parties’
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`proposed claim constructions, and the extrinsic evidence cited by the parties
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`in connection with those proposed constructions. I have also relied on my
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`professional and academic experience in the fields of thin film devices, flat
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`panel displays, active matrix, LED, OLED, touchscreens, and touch panels. I
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`reserve the right to consider additional materials as I become aware of them
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`and to revise my opinions accordingly.
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`II. QUALIFICATIONS
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`3.
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`My qualifications for forming the opinions set forth in this Declaration are
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`summarized here and explained in more detail in my curriculum vitae, which
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`is attached as Exhibit 2012.
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`4.
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`I received a Bachelor of Science degree in Physics from the University of
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`Michigan, Ann Arbor, in 1970. I thereafter received a Master of Science
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`degree in Physics from Oakland University in Rochester, Michigan, in 1976.
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`I am the founder and CEO of RAF Electronics Corp., where I developed and
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`2
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
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`patented Liquid Crystal on Silicon (LCOS) microdisplay projection
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`technology using active matrix transistor arrays as well as developed
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`proprietary LED-based Solid State Lighting (SSL) products.
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`5.
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`After receiving my bachelor’s degree, I was employed as a scientist and a
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`manager by Energy Conversion Devices, Inc., from 1970 through 1982. My
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`work at Energy Conversion Devices concerned the development of
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`electroluminescent displays, thin film photovoltaics, ablative imaging films,
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`non-volatile memory, multi-chip modules, and superconducting materials.
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`After leaving Energy Conversion Devices, I founded and served as CEO of
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`Alphasil, Inc., where I developed amorphous silicon thin film transistor (TFT)
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`active matrix liquid crystal displays (AMLCDs). My work at Alphasil
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`included thin film transistor array substrate process and circuit design, data
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`driver and gate driver design, scalers, video circuits, gamma correction
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`circuits, backlighting, and inverter design. At Alphasil I also designed and
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`incorporated touch panel screens into active matrix display devices. The touch
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`panel technologies included surface acoustic wave and capacitive sensing. I
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`worked at Alphasil from 1982 through 1989.
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`6.
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`After leaving Alphasil, I founded RAF Electronics Corp., described above. I
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`have served as CEO of RAF Electronics since that time. At RAF I developed
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`HDTV projection technology including transistor array substrates for LCOS
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`3
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`IPR2020-00308
`Exhibit 2011
`Page 3
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`devices and the associated optical systems. My activities at RAF have
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`included developments in lighting systems using both traditional LED and
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`OLED (Organic Light Emitting Diode) technologies. In 2016 I was granted
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`US Patent 9,328,898 which includes OLED and LED technology and lighting
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`systems. In 2019 RAF received a CalSEED grant from the California Energy
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`Commission to develop ultra-efficient lighting products and explore
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`establishing a Central Valley manufacturing facility.
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`7.
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`In 1997, I took the position of President and COO at Alien Technology
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`Corporation, where I was responsible for completing a Defense Advanced
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`Research Projects Agency (DARPA) contract, and for implementing MEM
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`fluidic self-assembly (FSA) technology. I left that position in 1999.
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`8.
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`In 2002, I co-founded and served as COO of Diablo Optics, Inc., where I
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`developed, produced, and commercialized key optical components for HDTV
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`projectors, such as polarization optics, condenser lenses, projection lenses,
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`and ultra-high performance optical interference filters using thin film stacks
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`in conjunction with LED and thin film transistor arrays and devices. I left
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`Diablo in 2007.
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`9.
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`I am listed as an inventor on twenty-six patents issued in the United States and
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`foreign countries, including one United States design patent. My inventions
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`concern technologies including LED devices, semiconductor materials, glass
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`4
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`IPR2020-00308
`Exhibit 2011
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`materials, non-volatile memory cells, thin film transistors, flat panel
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`backplanes and displays, wafer-based active matrices, and various transistor
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`array substrates.
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`10.
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`I have authored or co-authored
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`twenty-five articles or conference
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`presentations, including numerous papers and presentations concerning
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`lighting and display technologies. My curriculum vitae (Exhibit 2012) lists
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`these articles, conference presentations, and patents.
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`11.
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`I am also a member of several professional organizations, including the OSA,
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`SPIE, AES, SID, and the IEEE.
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`12.
`
`In summary, I have almost 50 years of experience in the field of high tech
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`product development including flat panel displays, transistor array substrates,
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`touchscreens and touch panels, and OLED and LED devices.
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`13.
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`In the past twelve years, I have served as an expert witness for patent
`
`infringement litigation (or arbitrations) or PTAB proceedings in the following
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`cases:
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`•
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`•
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`Nichia Corporation v. Seoul Semiconductor, 3:06-cv-0162 (NDCA), on
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`behalf of Seoul Semiconductor Company, Inc.
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`Hewlett Packard v. Acer Incorporated et al., U.S. ITC Investigation
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`No. 337-TA-606, on behalf of Acer Incorporated et al.
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`•
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`•
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`•
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`•
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`Samsung v. Sharp, U.S. ITC Investigation No. 337-TA-631, on behalf
`
`of Samsung.
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`Sharp v. Samsung, U.S. ITC Investigation No. 337-TA-634, on behalf
`
`of Samsung.
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`O2Micro v. Monolithic Power Systems et al., U. S. ITC Investigation
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`No. 337-TA-666, on behalf of O2Micro.
`
`IPR No. IPR2014-0168 of U.S. 7,612,843, on behalf of Petitioner Sony,
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`Corp.
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`Ushijima v. Samsung, 1:12-cv-00318-LY (WDTX), on behalf of
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`Ushijima.
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`Delaware Display Group LLC and Innovative Display Technologies
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`LLC v. Sony Corp. et al., Case No. 1:13-cv-02111-UNA DDEL, on
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`behalf of Sony Corp.
`
`Funai v. Gold Charm Limited, Case No. IPR2015-01468, on behalf of
`
`Petitioner Funai.
`
`Phoenix, LLC v. Exar et al., Case No. 6:15-CV-00436-JRG-KNM., on
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`behalf of Exar et al.
`
`MiiC v. Funai, Case No. 14-804-RGA, on behalf of Funai.
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`Delaware Display Group LLC v. Vizio, Case No. 13-cv-02112-RGA,
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`on behalf of Vizio.
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`6
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`IPR2020-00308
`Exhibit 2011
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`•
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`•
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`ARRIS v. Sony, U.S. ITC Investigation No. 337-TA-1060, on behalf of
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`Sony.
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`BlueHouse Global, LTD. v. Semiconductor Energy Laboratory Co.
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`LTD., IPRs on behalf of BlueHouse Global, LTD.
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`Phoenix, LLC v. Wistron Corp., Case No. 2:17-cv-00711-RWS, on
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`behalf of Wistron Corp.
`
`Ultravision v. Absen et al., ITC Investigation No. 337-TA-1114, on
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`behalf of Absen et al.
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`Viavi Solutions Inc. v. Materion Corp., PGR2019-00017, on behalf of
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`Viavi Solutions, Inc.
`
`NEC v. Ultravision, IPR2019-01123 and IPR2019-01117, on behalf of
`
`NEC.
`
`Solas OLED Ltd. v. Samsung Display Co., Ltd., et al., Case No. 2:19-
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`cv-00152-JRG, on behalf of Solas.
`
`Solas OLED Ltd. v. LG Display Co., Ltd., et al., Case No. 6:19-cv-
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`00236-ADA, on behalf of Solas.
`
`Neodron v. Lenovo / Motorola, Case No. 3:19-cv-05644-SI, on behalf
`
`of Neodron.
`
`Neodron v. Dell, Case No. 1:19-cv-00819-ADA, on behalf of Neodron.
`
`Neodron v. HP, Case No. 1:19-cv-00873-ADA, on behalf of Neodron.
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`7
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`•
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`•
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`Neodron v. Microsoft, Case No. 1:19-cv-00874-ADA, on behalf of
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`Neodron.
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`Neodron v. Amazon, Case No. 1:19-cv-00898-ADA, on behalf of
`
`Neodron.
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`Neodron v. Samsung, Case No. 1:19-cv-00903-ADA, on behalf of
`
`Neodron.
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`Solas OLED Ltd. v. Dell, Case No. 6:19-cv-00514-ADA, on behalf of
`
`Solas.
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`Solas OLED Ltd. v. Google, Case No. 6:19-cv-00515-ADA, on behalf
`
`of Solas.
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`Solas OLED Ltd. v. Apple, Case No. 6:19-cv-00537-ADA, on behalf
`
`of Solas.
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`Solas OLED Ltd. v. HP, Case No. 6:19-cv-00631-ADA, on behalf of
`
`Solas.
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`LGD v. Solas OLED Ltd., Case No. IPR2020-00177, on behalf of Solas.
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`Samsung Electronics Co. Ltd. et al. v. Neodron Ltd., Case No.
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`IPR2020-00192, -00682, on behalf of Neodron.
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`Samsung Electronics Co. Ltd. et al. v. Neodron Ltd., Case No.
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`IPR2020-00225, on behalf of Neodron.
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`8
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 8
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`•
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`•
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`•
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`•
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`Samsung Electronics Co. Ltd. et al. v. Neodron Ltd., Case No.
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`IPR2020-00234, on behalf of Neodron.
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`Samsung Electronics Co. Ltd. et al. v. Neodron Ltd., Case No.
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`IPR2020-00267, -00653, on behalf of Neodron.
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`Samsung Electronics Co. Ltd. et al. v. Neodron Ltd., Case No.
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`IPR2020-00406, -00716, on behalf of Neodron.
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`Samsung Electronics Co. Ltd. et al. v. Neodron Ltd., Case No.
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`IPR2020-00515, -00731, on behalf of Neodron.
`
`III. TECHNOLOGY BACKGROUND
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`14. The ’747 patent (Ex. 1001) is directed to a capacitive touch sensor with a force
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`sensor. See ’747 patent at Abstract, cl. 1. In general, a force sensor “can be
`
`used to determine an amount of force applied to the sensor.” Id. at 1:61–62.
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`As recognized by the asserted references, there are several different types of
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`force sensors, including resistive, piezoelectric, and capacitive force sensors.
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`See Sarvazyan (Ex. 1005) at [0045] (describing different types of force
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`sensors, “such as resistive, capacitive, piezoelectric, or fiber optic.”) Stacy
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`(Ex. 1004) at [0047]. Although the ’747 patent and claims are directed to
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`resistive force sensors, it is important to contrast that with piezoelectric and
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`capacitive force sensors.
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`9
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`SAMSUNG V. NEODRON
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`Exhibit 2011
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`A. Resistive Force Sensors
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`15. A resistive force sensor uses “a variable resistor whose resistance decreases
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`when the applied force increases.” Force sensitive resistor, Physics and Radio
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`Electronics (Ex. 2001) at 1; see also Force sensing resistor, Wikipedia (Ex.
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`2008) at 1. Such a force sensor is able to measure force because the resistance
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`of the force sensitive resistor depends on the amount of force applied. If a
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`large amount of force is applied, the resistance of the force sensitive resistor
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`decreases and provides low resistance to the electric current. On the other
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`hand, if little or no force is applied to the force sensitive resistor, the resistance
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`remains the same and provides high resistance to the electric current. Ex. 2001
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`at 2.
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`16. A strain gauge is a device used to measure strain (or force) on an object and
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`is an example of a resistive force sensor. Strain gauge, Wikipedia (Ex. 2002)
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`at 1. It consists of an insulating flexible backing which supports a metallic foil
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`matter. Id. The gauge is attached to an object by an adhesive. Id. As the object
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`is deformed, the foil is deformed, causing its electrical resistance to change.
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`Id. This resistance change is related to the strain (or force) by the quantity
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`known as the gauge factor. Id. This concept is illustrated in the following
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`figure of a metal strain gauge (Ex. 2003):
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`10
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`B.
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` Capacitive Force Sensors
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`17. A capacitive force sensor uses a material whose capacitance changes when a
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`
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`force, pressure or mechanical stress is applied. Force-sensing capacitor,
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`Wikipedia (Ex. 2004). Such a force sensor provides improved sensitivity and
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`repeatability compared to resistive force sensors but require more complicated
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`electronics. See id. (citing Bentley, John P. (1995). Principles of measurement
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`systems (3rd ed.). Harlow [England]: Longman Scientific & Technical, ISBN
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`0470234458, OCLC 30781109). Whereas resistive sensors work by
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`measuring changes in the resistance of a materials, capacitive sensors work
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`11
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`by measuring changes in the gap distance between two electrodes. Tactile
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`capacitive sensors (Ex. 2005) at 3.
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`18. Capacitance is a measure of an object’s ability to store electrical charge and
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`is illustrated through the example of two electrodes with area A separated by
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`an air gap D as shown. Id. at 4. As the air gap decreases, the capacitance C
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`increases (id.):
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`
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`19. A capacitive touch sensor can be created, for example, by arranging electrodes
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`as orthogonal, overlapping strips separated by a proprietary compressible
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`dielectric matrix, which acts as a spring. Id. at 5. A distinct capacitor is formed
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`at each point where the electrode strips overlap. Id. By selectively scanning a
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`single row and column, the capacitance, or local pressure, at that location is
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`measured. Id. at (4–5):
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`20. Capacitive force sensors have specific applications. Force-sensing capacitors
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`can be used to create low-profile force-sensitive buttons. Ex. 2004 at 2.
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`Further, they have been used in medical imaging to map pressures in the
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`esophagus, and to image breast and prostate cancer. Id. at 2.
`
`C.
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`Piezoelectric Force Sensors
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`21. A piezoelectric force sensor uses a material that generates charge or voltage
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`when force is applied. Piezo comes from the Greek word “piezein,” which
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`means “squeeze” or “apply some pressure.” Electronic Design (Ex. 2006) at
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`1. Under pressure, piezoelectricity forms in certain materials, such as crystals.
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`Id. at 2. Thus, the piezoelectric effect is the result of stressing a piezoelectric
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`material to generate a charge or voltage. Id. Piezoelectric materials are in
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`contrast to piezoresistive, which result in changes in resistance when pressure
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`is applied. Id. at 4. Piezoresistive materials are used for the resistive force
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`sensors discussed above.
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`22.
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`In a piezoelectric force sensor, a charge amplifier can convert the charge into
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`a voltage and so the output voltage is proportional to the force applied. How
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`a charge is formed in a piezoelectric crystal is shown below. The left side
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`shows the unstressed molecular crystal lattice (in the center is the charge,
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`which is balanced in this case). On the right side, the crystal is subjected to
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`mechanical stress: the centers of symmetry of the charges move apart and
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`charge can be measured at the top and bottom of the crystal:
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`
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`23. The following figure illustrates the cross-section of a typical quartz force
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`sensor. Introduction to Piezoelectric Force Sensors, PCB Piezotronics (Ex.
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`2007) at 1. When force is applied to this sensor, the quartz crystals generate
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`an electrostatic charge proportional to the input force. Id. at 2. This output is
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`collected on the crystals and is then either routed directly to an external charge
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`amplifier or converted to a low impedance voltage signal within the sensor
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`(id. at 2).
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`24. Piezoresistive sensors are commonly made from thin layers on micro
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`machined silicon wafer as shown here, and are not suitable to distribute over
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`
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`a touch panel.
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`D. Overview of the ’747 Patent
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`25. U.S. Patent No. 10,365,747 (Ex. 1001, “the ’747 patent”) is entitled
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`
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`“Touchsensing panel and force detection.” It teaches a touch position sensor
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`that includes force detection circuity that determines an amount of force
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`applied to a touch panel of the sensor. Id., at Abstract. Specifically, it teaches
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`a mobile electronic device that includes a housing, a capacitive touch sensing
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`panel, a display, a variable resistance electrode, and one or more processors
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`comprising an integrator circuit and a voltage driver that provides an
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`alternating voltage. See id., cls. 1, 10, 16.
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`26.
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`In one embodiment, the ’747 patent teaches and claims a sensor where the
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`force sensor (resistive force sensitive element 30) is disposed between the
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`capacitive touch sending panel and the housing. See id. at 4:20–28 (“With
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`reference back to FIG. 1, a resistive force sensitive element 30 can be used to
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`measure the amount of force applied to the panel. . . The touch position-
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`sensing panel 1 is incorporated in a portable device with the resistive force
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`sensitive element 30 arranged between the touch position-sensing panel 1 and
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`a housing of the device.”).
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`
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`27. The ’747 patent is directed to a resistive force sensor by describing and
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`claiming “a resistive force sensitive element” and a “variable resistance
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`electrode.” Id. at 4:20-22 (“a resistive force sensitive element 30 can be used
`
`to measure the amount of force applied to the panel.”); see also Technical
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`Background above. The ’747 patent teaches that “[t]he resistive force element
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`30, for example, may be formed of a Quantum Tunneling Composite material
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`(QTC). The DC resistance of the QTC material varies in relation to applied
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`force. In one example, the force sensitive element 30 can be formed by
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`printing an ink containing the QTC material.” Id. at 4:29-34; see also id. at
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`5:65-66 (“In this example, the resistive force sensitive element 30 has a
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`resistance RQ . . . .”). “The value of the applied force can in turn be determined
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`from the resistance value RQ of the resistive force sensitive element. The force
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`can be calculated based on the characteristic of the QTC material using the
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`calculated resistance. Id. at 5:34-40.
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`28. The ’747 specification teaches and claims specific resistive force sensor
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`circuitry, including an integrator circuit and a voltage driver configured to
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`provide an alternating voltage. See id. Figs. 2–5, cls. 1, 10, 16. The resistive
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`force sensitive element 30 can modulate the flow of current into a current
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`integrator circuit 22 of the control unit 20. Id. at 4:35–38. And as shown in
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`the figures, the force sensor circuit is in communication with an input of a
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`current integrator 22 of the control unit 20. Id. at 5:48–52. And the alternating
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`voltage is an alternating bi-polar voltage relative to the virtual earth at the
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`current integrator input. See id. at 5:65–6:22:
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`29.
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`I understand that Petitioners argue that Ex. 1004 (“Stacy”) in combination
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`with Ex. 1005 (“Sarvazyan”) discloses or renders obvious the independent
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`claims of the ’747 patent. In my opinion, a POSITA would not find the
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`teachings of the ’747 obvious over the combination of Stacy and Sarvazyan.
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`30. Petitioners point to the posts 77 of Fig. 3 of Stacy as representing the variable
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`resistance electrodes disclosed in the ’747 patent. But the posts 77 of Stacy
`
`cannot be variable resistance electrodes.
`
`31. First, the posts 77 of Stacy are not electrodes within the meaning of that term
`
`as used in the ’747 patent. The posts 77 in Stacy do not conduct electricity
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`from one end of the electrode to the other end. Also, there is no suggestion in
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`19
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`Stacy that the posts 77 are connected to an output of a voltage driver and an
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`input of an integrator circuit.
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`32. Second, even if the posts 77 of Stacy are considered to be electrodes (which
`
`they should not be), the posts 77 of Stacy cannot be variable resistance
`
`electrodes. Stacy states that “[t]he posts 77 may be composed of a
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`piezoelectric material through which an electrical change in resistance may be
`
`detected to provide a force signal/force value corresponding to the force
`
`imparted on the touch-sensitive display.” Ex. 1004, at [0054] (emphasis
`
`added). This statement is inherently contradictory. As explained above, a
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`piezoelectric material does not undergo changes in resistance in response to
`
`force, as Stacy suggests. Rather, a piezoelectric material undergoes changes
`
`in voltage in response to force. Therefore, “a piezoelectric material” such as
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`that described by Stacy cannot be “a variable resistance electrode” as required
`
`by the independent claims of the ’747 patent, because there are no variations
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`in resistance that can be measured when applying force to a piezoelectric
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`material.
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`33. While Stacy indicates that the posts 77 “may” be made of a piezoelectric
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`material, Stacy does not disclose any other possible materials of which the
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`posts 77 can be made. And though Stacy mentions other types of force
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`sensors, such as “force sensitive resistors, strain gauges, strain sensors,
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`
`
`20
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 20
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`piezoelectric or piezoresistive devices, [and] pressure sensors,” Stacy
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`describes these other types of force sensors only in association with force
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`sensors imbedded in the touch sensor layers, such as elements 88 and 92; or
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`in the context of a system design having generic force “actuators 37.” See,
`
`e.g., Ex. 1004, at [0047], [0048], [0059]. In my opinion, posts such as those
`
`described in Stacy would only be made of piezoelectric materials if used as
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`variable force sensors. As shown below, a POSITA would know that
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`piezoelectric force sensors are “bulk” piezoelectric technologies, such as the
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`relatively large posts 77 shown in Stacy Fig. 3.
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`Ex. 2013 (Piezoelectric Devices – From Bulk to Thin Film 2019, Yole
`
`
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`Developpement), at 13 (annotation added).
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`
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`21
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 21
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`34. When used as a force sensor, a piezoelectric post or disk has electrodes
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`attached to the top and bottom of a macroscopic (not thin film) crystal like
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`lead zirconate titanate (PZT) or special ceramic disks. The thickness of such
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`
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`22
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 22
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`a sensor is from about 0.2 mm to 20mm, and the lateral width or diameter is
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`about 3 to 100 mm, as shown below.
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`
`
`
`Ex. 2014, http://www.mmech.com.
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`
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`23
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 23
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`35. These piezoelectric force sensors are not continuous films that could
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`reasonably applied over the whole area of a touch screen, but could be
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`provided as discrete posts behind the touch panel as contemplated by Stacy.
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`Therefore, in my opinion, the Stacy 77 posts are piezoelectric force sensors,
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`not piezoresistive force sensors. Indeed, Stacy describes them as such at
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`[0054]: “The posts 77 may be composed of piezoelecric material . . . .”
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`36. Furthermore, a variable resistance electrode would not be shaped as a post, as
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`described in Stacy. A variable resistance electrode would be shaped as a thin
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`wire or ink printed onto film, for example, as shown in Figure 6 of Stacy. Ex.
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`1004, Fig. 6.
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`37. The ’747 describes, as one possible implementation, the use of piezoresistive
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`force sensors, and uses Quantum Tunneling Composite (CTC) as an example.
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`Many piezoresistive force sensors use thin diffusion layers or thin film metals
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`on micro-machined silicon substrates with cantilevers or diaphragms as
`
`shown below.
`
`
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`24
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 24
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`These types of PFSs are not suitable for incorporation into touch panels. As
`
`an example, Bloor, 2006, Applied Physics Letters 88, 102-103 describes
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`Quantum Tunneling Composites in PFSs as being produced in flexible sheets
`
`from 1 to 2 mm in thickness produced by curing a polymer-metal mix. Such
`
`a flexible thin-film structure would be suitable for touch panels. Such PRSs
`
`are fundamentally thick or thin film devices. They are not posts, but films.
`
`Therefore, the posts 77 of Stacy are not piezoresistive devices, but
`
`piezoelectric.
`
`38. The posts 77 in Figure 3 of Stacy are the only instance in which Stacy arguably
`
`teaches disposing a force sensor between the capacitive touch sensing panel
`
`and the housing. As I have explained, the posts 77 cannot be variable
`
`resistance electrodes within the meaning of the ’747 patent. Therefore, Stacy
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`
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`25
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 25
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`does not disclose disposing a variable resistance electrode between the touch
`
`panel and the housing.
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`39. Nor would it be obvious to a POSITA to dispose a variable resistance
`
`electrode between the capacitive touch sensing panel and the housing. For the
`
`reasons I have already discussed, the only instance in which Stacy arguably
`
`discloses any kind of force sensor as being disposed between a capacitive
`
`touch sensitive panel and a housing involves touch sensors that cannot be
`
`variable resistance electrodes.
`
`40. Furthermore, although Stacy mentions the use of variable resistance
`
`electrodes, Stacy teaches disposing such variable resistance electrodes only
`
`on the same layer as one of the capacitive touch sensor layers or between the
`
`two capacitive touch sensor layers. See, e.g., Ex. 1004, Figs. 6-7. In Stacy,
`
`Figures 6 and 7, the force sensors are clearly disposed on the same layer as a
`
`capacitive touch sensor layer. See also id. at [0047] (“The touch sensor layer
`
`92 may also include at least one force sensor 140 . . . . In the example of FIG.
`
`6, the force sensor comprises a continuous, serpentine pattern disposed in the
`
`gaps between the vertical touch sensor members 124. . . . The force sensor
`
`140 may be formed in the same manner, of the same materials, and/or at the
`
`same time as the touch sensor members 124. Alternatively, the force sensor
`
`140 may be disposed within the other touch sensor layer 8. Integrating the
`
`
`
`26
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 26
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`
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`force sensor 140 in a touch sensor layer 88, 92 is an inexpensive way to
`
`implement a force sensor because the force sensor 140 may be formed of the
`
`same material during the same process without requiring separate discrete
`
`components that take up space outside the touch-sensitive display 33.”); id. at
`
`[0051] (“[In Fig. 7,] the touch-sensitive display 33 is divided into five
`
`zones . . . . Ten discrete force sensors 740 are shown with two force sensors
`
`740 located in each of the five zones”).
`
`41.
`
`It is my understanding, based on a review of the Petition and the Declaration
`
`of Dr. Andrew Wolfe, that Petitioners rely on the combination of Stacy with
`
`
`
`
`
`27
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 27
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`
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`Sarvazyan only to add the elements of a voltage driver and integrator that
`
`Petitioners admit are absent from Stacy but are required by the independent
`
`claims of the ’747 patent. I further understand that Petitioners do not contend
`
`that Sarvazyan teaches or suggests disposing a variable resistance electrode
`
`between the housing and the capacitive touch sensitive display. In my opinion,
`
`Sarvazyan contains no such teaching or suggestion; therefore, combining
`
`Stacy with Sarvazyan cannot add the missing element of disposing a variable
`
`resistance electrode between the housing and the capacitive touch sensitive
`
`display.
`
`42. For all the reasons set forth above, it is my opinion that Stacy, either alone or
`
`in combination with Sarvazyan, does not disclose or suggest disposing a
`
`variable resistance electrode between a capacitive touch sensitive display and
`
`a housing, and therefore does not render obvious the teachings of the
`
`independent claims of the ’747 patent.
`
`IV. LACK OF MOTIVATION TO COMBINE
`
`43.
`
`In my opinion, a POSITA would not have been motivated to combine Stacy
`
`with Sarvazyan in the manner posited by Petitioners and Dr. Wolfe.
`
`44.
`
`I disagree with Dr. Wolfe that Stacy and Sarvazyan are directed to a common
`
`field. Stacy addresses a touch sensitive display screen such as that used in a
`
`mobile phone or other device. By contrast, Sarvazyan describes its invention
`
`
`
`28
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 28
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`
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`as “a method and apparatus for mass breast screening and detecting early
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`changes in mechanical properties of breast tissue that are indicative of breast
`
`cancer and other breast pathologies, and, even more specifically, to the
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`utilization of a hand-held self-palpation device for detecting and locating
`
`lesions in breast tissue.” Ex. 1005 (“Sarvazyan”) at [0003].
`
`45.
`
`It is my opinion, based on my years of experience with touch sensor displays
`
`and design thereof, that a POSITA attempting to solve a problem in designing
`
`a touch sensor display such as that disclosed in the ’747 patent would be
`
`highly unlikely to look to the field of medical diagnostic devices for guidance.
`
`The two fields are so divergent, and involve such different parameters and
`
`problems, that a POSITA would be highly unlikely to seek to combine art
`
`from the two fields.
`
`46. Furthermore, a POSITA would not be motivated to combine the teachings of
`
`Stacy and Sarvazyan because Sarvazyan teaches only the use of capacitive
`
`force sensors, and the force sensors at issue in Stacy, that is, posts 77, are
`
`never identified as capacitive force sensors in Stacy, but rather as piezoelectric
`
`force sensors, as I have discussed above.
`
`47. As I mentioned earlier, Stacy describes a variety of different possible kinds of
`
`force sensors: “force sensitive resistors, strain gauges, piezoelectric or
`
`piezoresistive devices, pressure sensors, or other suitable devices.” Ex. 1004,
`
`
`
`29
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 29
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`
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`at [0047]. Similarly, in describing the kinds of measurements that may be
`
`made by the force sensors, Stacy lists “pressure, deformation, stress, strain,
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`force density, force-area relationships, thrust, and torque” as possibilities. Id.
`
`Stacy provides these broad ranges of examples of force sensors and
`
`measurements—however, Stacy never mentions capacitive force sensors or
`
`capacitance with respect to force measurements.
`
`48. By contrast, Sarvazyan’s teachings are limited to a capacitive force sensor
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`array. Sarvazyan at [0045] (“FIG. 7 shows a block diagram of a capacitive
`
`pressure sensor array 74.”). There is no teaching or suggestion by Sarvazyan
`
`of using a force sensor other than a capacitive force sensor.
`
`49. Because Stacy excludes the use of capacitive force sensors, and because
`
`Sarvazyan discloses only the use of capacitive force sensors, a POSITA would
`
`not be motivated to combine the two as argued by Petitioners.
`
`50. Similarly, Sarvazyan discloses the use of a voltage driver and integrator only
`
`in the context of a capacitive force sensor. Sarvazyan states that FIG. 7 “shows
`
`a block diagram of a capacitive pressure sensor array 74 and a corresponding
`
`analog measurement system.” Sarvazyan at [0045]. Both are shown together
`
`in FIG. 7 and described in paragraph [0045]. In that paragraph, Sarvazyan
`
`describes the capacitive sensors’ “base capacitance” (from 10 to 100 pF) and
`
`the relative change in capacitance (from 5% and 20%) and then immediately
`
`
`
`30
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`SAMSUNG V. NEODRON
`IPR2020-00308
`Exhibit 2011
`Page 30
`
`
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`describes the analog measurement system in the context of those values. Id.
`
`Then Sarvazyan discusses comparing the output signal with “a signal from a
`
`reference capacitor,” before amplification and sending. Id. Certainly, it would
`
`make no sense to compare a non-capacitive value (such as a resistive value)
`
`against a reference capacitor.
`
`51. Furthermore, Stacy gives no indication that its circuitry needs improvement
`
`or modification. It provides no details on the implementation of its force
`
`circuitry, and therefore no suggestion that the force circuitry of Stacy
`
`contained problems that needed solving. Nor does Stacy discuss problems of
`
`efficiency, performance, or cost that would allegedly be improved by the
`
`addition of a voltage driver or integrator. On the contrary, Stacy suggests that
`
`additional circuitry would be undesirable because Stacy emphasizes the
`
`desirability of making its force sensor more “inexpensive,” such
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