IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG DISPLAY CO., LTD.,
`Petitioner,
`
`v.
`
`SOLAS OLED, LTD.,
`Patent Owner.
`
`Patent No. 7,446,338
`
`DECLARATION OF ADAM FONTECCHIO, PH.D.
`
`SAMSUNG EX. 1018 - 1/129
`
`

`

`I.
`
`BACKGROUND AND QUALIFICATIONS ................................................. 2
`
`II. MATERIALS CONSIDERED ........................................................................ 5
`
`III. RELEVANT LEGAL STANDARDS ............................................................. 6
`
`a.
`
`b.
`
`Anticipation ........................................................................................... 7
`
`Obviousness ........................................................................................... 7
`
`IV. TECHNOLOGICAL BACKGROUND ........................................................ 10
`
`a.
`
`b.
`
`c.
`
`Passive vs. Active Matrix OLED Displays ......................................... 10
`
`Lowering Resistance of Components in an AMOLED Display ......... 12
`
`Pixel Circuit Design in AMOLED Displays ....................................... 17
`
`V. OVERVIEW OF U.S. PATENT 7,446,338 .................................................. 26
`
`a.
`
`b.
`
`c.
`
`Summary ............................................................................................. 26
`
`File History .......................................................................................... 34
`
`The Claims at Issue ............................................................................. 36
`
`VI. LEVEL OF ORDINARY SKILL IN THE ART ........................................... 39
`
`VII. CLAIM CONSTRUCTION .......................................................................... 40
`
`“transistor array substrate” (claim 1) .................................................. 40
`
`“a plurality of interconnections which are formed to project from a
`surface of the transistor array substrate” (claim 1) ................... 43
`
`“the pixel electrodes being arrayed along the interconnections
`between the interconnections on the surface of the transistor
`array substrate” (claim 1) .......................................................... 44
`
`VIII. OVERVIEW OF THE PRIOR ART ............................................................. 46
`
`ii
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`a.
`
`b.
`
`c.
`
`Kobayashi (US Patent Application Pub. No. 2002/0158835) (Ex.
`1003) .................................................................................................... 46
`
`Shirasaki (U.S. Patent Application Pub. No. 2004/0113873) (Ex.
`1004) .................................................................................................... 50
`
`Childs (International Publication No. WO 03/079441) ...................... 51
`
`IX. THE COMBINATION OF KOBAYASHI AND SHIRASAKI (CLAIMS 1-
`2, 5-6, 9-11) ................................................................................................... 55
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`Independent Claim 1 ........................................................................... 56
`
`Dependent Claim 2 .............................................................................. 78
`
`Dependent Claim 5 .............................................................................. 79
`
`Dependent Claim 6 .............................................................................. 79
`
`Dependent Claim 9 .............................................................................. 81
`
`Dependent Claim 10 ............................................................................ 83
`
`Dependent Claim 11 ............................................................................ 84
`
`X.
`
`THE COMBINATION OF CHILDS AND SHIRASAKI (CLAIMS 1-3, 5-
`13) .................................................................................................................. 85
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`Independent Claim 1 ........................................................................... 86
`
`Dependent Claim 2 ............................................................................112
`
`Dependent Claim 3 ............................................................................114
`
`Dependent Claim 5 ............................................................................116
`
`Dependent Claim 6 ............................................................................117
`
`Dependent Claim 7 ............................................................................119
`
`Dependent Claim 8 ............................................................................119
`
`iii
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`h.
`
`i.
`
`j.
`
`k.
`
`l.
`
`Dependent Claim 9 ............................................................................119
`
`Dependent Claim 10 ..........................................................................120
`
`Dependent Claim 11 ..........................................................................121
`
`Dependent Claim 12 ..........................................................................122
`
`Dependent Claim 13 ..........................................................................124
`
`iv
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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” or as the “Petitioner.”
`
`2.
`
`I have been asked by counsel for the Petitioner to consider whether the
`
`references listed as Exhibits 1003-1005 below disclose or suggest, alone or in
`
`combination, the limitations recited in the claims of U.S. Patent 7,446,338 (the “’338
`
`patent”). I have also been asked to consider the state of the art and the prior art
`
`available before the filing of the ’338 patent. I have provided my opinions below.
`
`3.
`
`I have been informed that a company known as Solas OLED Ltd. claims
`
`to be the owner of the ’338 patent. To the best of my knowledge, I have no financial
`
`interest in Samsung, Solas OLED Ltd., or the ’338 patent. To the best of my
`
`recollection, I have had no contact with Solas OLED Ltd. or the named inventors of
`
`the ’338 patent: Tomoyuki Shirasaki, Tsuyoshi Ozaki, and Jun Ogura. To the extent
`
`any mutual funds or other investments that I own have a financial interest in
`
`Samsung, Solas OLED Ltd., or the ’338 patent, I am not aware of, nor do I have
`
`control over, any financial interest that would affect or bias my judgment.
`
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`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 ’338 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-
`
`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
`
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`

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`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.
`
`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
`
`3
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`

`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
`
`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
`
`4
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`what the state of this field was at the relevant time up to the time that the ’338 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 1019).
`
`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 ’338 patent—both its claims and its specification—
`
`as well as the associated file history for the application that led to the ’338 patent.
`
`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:
`
`Exhibit Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`U.S. Patent No. 7,446,338 (the “’338 patent”)
`
`File History for U.S. Patent No. 7,446,338
`
`U.S. Patent Application Pub. No. 2002/0158835 (“Kobayashi”)
`
`U.S. Patent Application Pub. No. 2004/0113873 (“Shirasaki”)
`
`5
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`Exhibit Description
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`1017
`
`International Publication No. WO 03/079441 (“Childs”)
`
`European Patent Application No. EP 1331666 (“Yamazaki”)
`
`U.S. Patent Application Pub. No. 2004/0165003 (“Shirasaki II”)
`
`Japanese Patent Publication No. 2004-258172
`
`U.S. Patent Application Pub. No. 2003/0151637 (“Nakamura”)
`
`International Publication No. WO 03/079442 (“Hector”)
`
`International Publication No. WO 03/079449 (“Young”)
`
`Tsujimura, Takatoshi. OLED Display Fundamentals and Applications:
`Fundamentals and Applications, John Wiley & Sons, Incorporated,
`2012 (“Tsujimura”)
`
`Crawford, Gregory P. Flexible flat panel display technology. Vol. 3.
`West Sussex: Wiley, 2005 (“Crawford”)
`
`U.S. Patent Application Pub. No. 2003/0127657 (“Park”)
`
`U.S. Patent No. 7,498,733 (“Shimoda”)
`
`U.S. Patent Application Pub. No. 2002/0000576 (“Inukai”)
`
`U.S. Patent Application Pub. No. 2002/0009538 (“Arai”)
`
`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.
`
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`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
`
`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
`
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`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
`
`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;
`
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`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
`
`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 a
`
`person of ordinary skill in the art (“POSA”), consistent with the disclosure and the
`
`prosecution history.
`
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`IV.
`
`TECHNOLOGICAL BACKGROUND
`25. According to the face of the ’338 patent, the ’338 patent was filed in
`
`the United States on September 26, 2005. Ex. 1001 at cover. However, the ’338
`
`patent claims priority to a Japanese patent application (2004-283824), which the
`
`’338 patent states was filed on September 29, 2004. Ex. 1001 at cover. Accordingly,
`
`for purposes of my discussion below, I assume that the timeframe of the purported
`
`invention of the ’338 patent was September 2004, and have provided an overview
`
`of the technological background of active matrix OLED matrix displays by this
`
`September 2004 timeframe. In particular, I have provided a discussion of the state
`
`of the art of active matrix OLED technology in September 2004, particularly as
`
`relates to the technology described in the ’338 patent.
`
`a. Passive vs. Active Matrix OLED 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.
`
`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
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`significant limitations, such as the inability to create a ring structure, or a structure
`
`with a cutout in the center.
`
`27. 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”)
`
`technology. Originally demonstrated as a potential driving element in 1966 by RCA,
`
`transistors act as individual on-off switches at each pixel.
`
`28.
`
`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.
`
`29. 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.
`
`30. 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, active matrix technology has taken over from passive
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`matrix displays, and it is unusual to find passive matrix drive methods in any
`
`significant display technology today.
`
`31. 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 ’338 patent and the prior art.
`
`32.
`
`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.”
`
`b. Lowering Resistance of Components in an AMOLED Display
`33. As I have discussed above, AMOLED displays were widely known by
`
`the September 2004 timeframe of the ’338 patent. One well-known issue presented
`
`by such AMOLED displays, however, was the potential for what is known as
`
`“voltage drop” across the relatively thin conductive components of an AMOLED
`
`display. “Voltage drop” refers to the decrease in electrical potential along the path
`
`of a current flowing through a conductive element, due to the internal resistance of
`
`the conductive element itself. This internal resistance to electron flow is due to the
`
`properties of the material itself, and is a fundamental characteristic known as
`
`“resistivity.”
`
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`34. Because the conductive elements of an AMOLED display (such as the
`
`lines that carry a supply current and/or a signal current, or the electrodes of the
`
`OLED elements in each pixel) are each relatively thin, they have a relatively high
`
`resistance (a conductive element with a smaller cross-section will have a higher
`
`resistance than a conductive element made from the same material but with a larger
`
`cross-section). Accordingly, because of the high resistance of each of these
`
`conductive elements, the energy supplied to these conductive elements will dissipate
`
`along their length, resulting in a disparity between the power available at the
`
`beginning of the conductive element as compared to the power available at its end.
`
`35. To remedy this issue, it was well known by the September 2004
`
`timeframe of the ’338 patent to supplement and/or replace conductive elements in
`
`an AMOLED structure with added or “auxiliary” low-resistance conductive material
`
`(often of larger cross-section than the original conductive element) that would bring
`
`down the resistance of those conductive elements. For example, European Patent
`
`Application No. EP 1331666 to Yamazaki et al. (“Yamazaki”) (Ex. 1006) explains
`
`that at least one of the anode or cathode of the OLED pixel element is made out of a
`
`“transparent conductive film (typically ITO or ZnO),” Ex. 1006 at ¶ [0029], but that
`
`these materials have a “relatively high resistance value” and thus cannot transmit
`
`power uniformly, making it “difficult to achieve a large screen,” Ex. 1006 at ¶
`
`[0059].
`
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`36. To solve this problem, Yamazaki discloses electrically connecting
`
`lower-resistance “auxiliary electrodes” to the transparent pixel electrode, which
`
`“function to decrease an electric resistance value” of the pixel electrode and allow
`
`“the thickness of the transparent conductive film [to] be reduced” even further. Ex.
`
`1006 at ¶ [0059]. Yamazaki provides several examples of such “auxiliary
`
`electrodes” (which can be formed of a number of different metals, including
`
`aluminum and copper, Ex. 1006 at ¶ [0060]), such as “auxiliary electrodes 821”
`
`formed on transparent cathode 20 so that “the cathode . . . can be decreased in
`
`resistance in its entirety” and “can be made thin,” Ex. 1006 at ¶ [0106], as illustrated
`
`by Fig. 10A of Yamazaki:
`
`
`
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`37. Other contemporary prior art similarly described such auxiliary
`
`conductive elements. International Publication No. WO 03/079442 (“Hector”) (Ex.
`
`1010) described such “auxiliary wiring for reducing the resistance of (and hence the
`
`voltage drops across) the common upper electrode of the electroluminescent
`
`elements,” Ex. 1010 at 1:30-2:2, as did International Publication No. WO 03/079449
`
`(“Young”) (Ex. 1011), Ex. 1011 at 2:3-7.
`
`38. Further, in addition to auxiliary electrodes that decrease the resistance
`
`of OLED electrodes, both Hector and Young also described supplemental
`
`“interconnections” designed to decrease the resistance of other conductive lines in
`
`the OLED structure. Hector, for example, explained that the thin-film transistor
`
`array of the AMOLED device is connected to various “voltage supply lines,” but
`
`that “[v]oltage drops along these two supply lines can result in incorrect drive
`
`currents for individual pixels. This can lead to a decrease in emission intensity (i.e.
`
`fading of the image) from pixels in the center of the display. Indeed, with large-area
`
`displays, the effect may be so bad that no emission occurs at the center, so limiting
`
`the acceptable display size.” Ex. 1010 at 2:3-16. To solve this problem, Hector
`
`proposed electrically connecting the supply lines to thick “conductive barrier
`
`material,” which causes “the electrical resistance along the drive supply line (and
`
`consequential voltage drops)” to “be significantly reduced” and “the image quality
`
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`[to] be improved.” Ex. 1010 at 3:1-23. Such “conductive barriers” are illustrated,
`
`for example, by elements 240 in Fig. 1 of Hector, Ex. 1010 at 10:24-32:
`
`
`
`39. Young similarly discloses such supplemental interconnections to
`
`reduce line resistance/voltage drop, explaining that “line resistance can be
`
`significantly reduced by using conductive barrier material 240, 240x to replace or to
`
`back up a conductor line (for example, 140, 150, or 160) of the circuit substrate 10.”
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`Ex. 1011 at 16:5-7.
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`40. Other prior art references by the September 2004 timeframe of the ’338
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`patent similarly discussed decreasing the resistance of the conductive lines within
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`the OLED structure by increasing their thickness. U.S. Patent Application Pub. No.
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`2003/0151637 (“Nakamura”) (Ex. 1009), for example, disclosed how its “wirings,
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`such as signal line 504, a common electricity supplying line 505, and a scan line
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`503” were to be “formed in sufficient thickness with regardless of the necessary
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`thickness for wirings,” Ex. 1009 at ¶ [0327], as illustrated by Fig. 40 of Nakamura
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`depicting the relatively thick conductive lines 504 and 505:
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`
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`c. Pixel Circuit Design in AMOLED Displays
`41. As I have noted above, in an active matrix display, each individual pixel
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`contains at least one thin film transistor and a storage capacitor. The TFT substrate,
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`containing the individual TFTs and all the necessary connections and bussing lines,
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`can also be referred to as an “active matrix backplane” or a “transistor array
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`substrate.”
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`42. The backplane
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`is
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`fabricated prior
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`to deposition of
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`the
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`electroluminescent material on the backplane. Due to the high temperatures and
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`etchants involved in fabricating the TFT structures, the active matrix components
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`must be fabricated using semiconductor fabrication technology on a substrate,
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`conventionally made of glass. By using a substrate to build up the TFT and circuit
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`components, the active EL materials can be deposited on the completed substrate
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`using solution or vapor deposition methods.
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`43. After deposition of the EL material on the backplane, the counter
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`substrate and data driver are attached to complete the module. This process of having
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`the “…OLED device fabricated on the surface of a glass substrate” is illustrated in
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`Fig. 4.1 (b) of Tsujimura (Ex. 1012):
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`44. A typical example of the specific steps of fabrication for an OLED are
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`discussed in Crawford (Ex. 1013), which provides the general process steps for a
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`passive matrix PMOLED assembly where the active EL materials are denoted as
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`HITL (Hole Injection and Transport Layer) and LEP (Light Emitting Polymer):
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`The fabrication of an OLED onto a composite plastic
`barrier substrate can be subdivided into three parts.
`Substrate patterning is the first part and it consists of the
`following steps:
`
`
`• deposit and pattern the transparent anode;
`• deposit and pattern the metal bus lines;
`• deposit and pattern any color confinement and/or
`cathode separating structures that may be used.
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`The polymer or active materials are then deposited as
`follows:
`
`
`• apply HITL material;
`• apply LEP material.
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`The device is then completed with these steps:
`
`
`• deposit and, if needed, pattern the cathode;
`• encapsulate the device.
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`
`Ex. 1013 at p. 299.
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`45. Crawford goes on to observe that “[i]n a plastic AMOLED, an AM
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`array is fabricated on the transparent plastic substrate. The AM array consists of
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`patterned ITO and the TFT circuitry. The active materials can then be applied in the
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`same manner as in a PMOLED.” Ex. 1013 at p. 304. The process is very similar in
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`that the circuitry is incorporated into an underlying substrate, and then the active EL
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`material is applied.
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`46. One example of a AMOLED display structure was disclosed by U.S.
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`Patent Application Publication No. 2003/0127657 to Park (Ex. 1014). Figure 4 of
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`Park illustrates “a cross sectional view of an exemplary active matrix organic
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`electroluminescent display device,” Ex. 1014 at ¶ [0034]:
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`47.
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`In Park, a thin-film transistor (“drain and source regions 122 and 123”
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`and “gate electrode 131”) is formed “on a substrate 100,” Ex. 1014 at ¶¶ [0034]-
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`[0035], and the “drain electrode 171 and source electrode 172” connecting to that
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`transistor are covered by insulating “passivation layer 180,” Ex. 1014 at ¶ [0036],
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`where that “passivation layer 180” has “a planar upper surface,” Ex. 1014 at ¶
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`[0036]. “A first electrode 190 made of a transparent conductive material may be
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`disposed on the planar upper surface of the passivation layer 180,” Ex. 1014 at ¶
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`[0036], an “organic electroluminescent layer 220,” Ex. 1014 at ¶ [0037], with an
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`opaque “second electrode 230” formed on
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`the surface of
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`that organic
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`electroluminescent layer 220,” Ex. 1014 at ¶ [0037].
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`48. By the September 2004 timeframe of the ’338 patent, a number of
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`AMOLED designs had been disclosed in which each individual pixel contained at
`
`least two transistors and a storage capacitor. Fig. 35 of Nakamura, for example,
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`illustrated a design in which each “pixel area 501” contained a “switching thin film
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`transistor 509” and a “current thin film transistor 510” connected to “pixel electrode
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`511,” Ex. 1009 at ¶ [0317]:
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`49. Yamazaki described a similar circuit structure for each pixel, in which
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`each pixel contained a “TFT switching element” as well as a “driver element” TFT.
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`Ex. 1006 at ¶ [0005].
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`50. Hector and Young, too, each disclosed two-transistor circuits for each
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`pixel of their AMOLED displays, with “driving TFT T1” and “addressing TFT T2,”
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`as illustrated by Fig. 3 of Hector and Fig. 1 of Young, below, Ex. 1011 at 7:20-32:
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`51. However, by the September 2004 timeframe of the ’338 patent, other
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`pixel circuit designs for AMOLED ele