UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`APPLE INC.,
`Petitioner
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`v.
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`COREPHOTONICS LTD.,
`Patent Owner
`____________
`
`Case IPR2018-00030
`U.S. Patent No. 9,857,568
`____________
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`
`DECLARATION OF DUNCAN MOORE, Ph.D.
`PURSUANT TO 37 C.F.R. §1.68
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`APPL-1030 / Page 1 of 65
`APPLE INC v. COREPHOTONICS LTD.
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`____________
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`
`APPLE INC.,
`Petitioner
`
`v.
`
`COREPHOTONICS LTD.,
`Patent Owner
`____________
`
`Case IPR2018-00030
`U.S. Patent No. 9,857,568
`____________
`
`
`DECLARATION OF DUNCAN MOORE, Ph.D.
`PURSUANT TO 37 C.F.R. §1.68
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`
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`APPL-1030 / Page 1 of 65
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`Table of Contents
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`I. Background ........................................................................................................ 1
`II. Summary of Opinions ........................................................................................ 1
`III. Educational and Employment Background ....................................................... 4
`IV. Level of Ordinary Skill in the Art (POSITA) .................................................... 6
`V. Relevant Legal Standards for Anticipation and Obviousness ............................ 9
`VI. Background ...................................................................................................... 14
`A. Overview of the ’568 Patent ......................................................................... 14
`B. Multiple Element Lens Design ..................................................................... 19
`VII. Claim Construction .......................................................................................... 23
`A. “Total Track Length (TTL)” ........................................................................ 23
`B. “Effective Focal Length” .............................................................................. 34
`VIII.
`Petition Grounds ....................................................................................... 34
`A. Claims 1–5 of the ’032 Patent are Not Rendered Obvious by Ogino .......... 34
`1. Ogino Does Not Disclose a Lens Assembly with TTL / EFL < 1 ........... 34
`2. A POSITA Would Not Modify Ogino Example 6 to Disclose a Lens
`Assembly with TTL / EFL < 1 ................................................................. 40
`3. Ogino Does Not Disclose a Lens Assembly with L11 / L1e < 4 ............ 53
`B. Claims 1–5 of the ’032 Patent are Not Rendered Obvious by Ogino in
`Combination with Beich ............................................................................... 55
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`I.
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`Background
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`1.
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`I have been retained as a technical expert by Patent Owner
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`Corephotonics Ltd. (“Patent Owner” or “Corephotonics”) in this proceeding.
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`Corephotonics has asked me to provide my expert opinions concerning certain
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`technical aspects of imaging lenses and imaging lens design as they relate to the
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`Petitioner Apple Inc.’s petitions for inter partes review of U.S. Patent 9,857,568
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`(“’568 patent”) in Case No. IPR2018-00030 (“’032 IPR”) and the accompanying
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`Declaration of José Sasián. The statements in this declaration summarize my
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`opinions on these matters based on my over 40 years of experience in the design and
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`development of imaging lenses for optical systems, my education, knowledge, skills,
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`and my review and analysis of the materials referenced herein.
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`2.
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`I am being compensated for my work in this matter at the rate of $425
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`per hour. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the outcome of this matter or the substance of my testimony.
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`II.
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`Summary of Opinions
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`3.
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`In the preparation of this declaration, I have reviewed:
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`• The ’568 patent. Ex. 1001;
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`• Prosecution history of the ’568 patent. Ex. 1002;
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`• The Declaration of José Sasián. Ex. 1003;
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`1
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`• The curriculum vitae of José Sasián. Ex. 1004;
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`• U.S. Patent No. 9,128,267 (“Ogino”). Ex. 1005;
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`• Warren J. Smith, Modern Lens Design (1992). Ex. 1006;
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`• U.S. Patent No. 7,918,398 to Li et al. Ex. 1007;
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`• U.S. Patent No. 7,777,972 to Chen et al. (“Chen”). Ex. 1008;
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`• Max Born et al., PRINCIPLES OF OPTICS, 6th Ed. (1980). Ex. 1010;
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`• Prosecution history of the Ogino patent. Ex. 1011;
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`• Ex. 1012, identified as Jane Bareau et al., “The optics of miniature
`digital camera modules,” SPIE Proceedings (2006) (“Bareau”). Ex.
`1012;
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`• U.S. Patent Publication No. 2013/0077183. Ex. 1017;
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`• Schaub, THE DESIGN OF PLASTIC OPTICAL SYSTEMS (2009). Ex. 1018.
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`• Bass et al., Handbook of Optics, vol. II, 2nd ed. (1995). Ex. 1019.
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`• William S. Beich & Nicholas Turner., “Polymer Optics: A
`Manufacturer’s Perspective on the Factors that Contribute to Successful
`Programs,” SPIE Proceedings Vol. 7788 (Aug. 12, 2010) (“Beich”).
`Ex. 1020.
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`• The Declaration of Ingrid Hsieh-Yee, Ph.D. Ex. 1022;
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`• U.S. Patent No. 8,395,851 (“Tang”). Ex. 2007;
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`• U.S. Patent Publication No. 2011/0249346. Ex. 2008;
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`• U.S. Patent Publication No. 2011/0279910, Ex. 2009;
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`• U.S. Patent Publication No. 2011/0261470. Ex. 2010;
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`• Transcript of the February 15, 2019 Deposition of Dr. José Sasián in
`the IPR2018-01140 and IPR2018-01146. Ex. 2011.
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`2
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`• Transcript of the July 2, 2019 Deposition of Dr. José Sasián in
`IPR2018-00030. Ex. 2012.
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`• The Declaration of José Sasián in IPR018-01140, regarding U.S. Patent
`No. 9,402,032 (“’032 patent”) and U.S. Patent No. 9,568,712 (“’712
`patent”). Ex. 2013;
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`• Excerpts from Robert E. Fischer, Biljana Tadic-Galeb, Paul R. Yoder,
`OPTICAL SYSTEM DESIGN, 2nd Ed., 2008, Ex. 2014;
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`• U.S. Patent 9,678,310 (“Iwasaki”), Ex. 2015;
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`• U.S. Patent 8,248,715 (“Asami”), Ex. 2016;
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`• U.S. Patent Publication 20110261471 (“Taniyama”), Ex. 2018;
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`• Humpston et al., “Optical performance of bare image sensor die and
`sensors packaged at the wafer level and protected by a cover glass,”
`Proceedings of SPIE (2008), Ex. 2019;
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`• Excerpts from Symmons & Schaub, FIELD GUIDE TO MOLDED OPTICS,
`SPIE (2016), Ex. 2020;
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`• William S. Beich, “Injection Molded Polymer Optics in the 21st-
`Century,” SPIE Proceedings Vol. 5865 (2005), Ex. 2021;
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`• Luxin Nie, “Patent Review of Miniature Camera Lenses and A Brief
`Comparison of Two Relative Design Patterns” (2017), Ex. 2022;
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`• Excerpts from José Sasián, INTRODUCTION TO ABERRATIONS IN
`OPTICAL IMAGING SYSTEMS (2013), Ex. 2023; and
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`• Kingslake & Johnson, LENS DESIGN FUNDAMENTALS, 2d ed., Ch. 4,
`(2010) Ex. 2024.
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`4.
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`In forming the opinions set forth herein, I have considered:
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`a. The documents listed above.
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`b. My education, knowledge, skills, and experience in the design
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`and development of imaging lenses for optical systems; and
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`c. The level of skill of a person having ordinary skill in the art
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`(POSITA) at the time of the effective filing dates of the ’568
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`patent.
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`5.
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`It is my professional and expert opinion that Ogino does not render
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`obvious claims 1–5 of the ’568 patent, that a POSITA would not have been
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`motivated to combine Ogino and Beich, and that claims 1–5 of the ’568 patent are
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`not obvious over the combination of Ogino and Beich.
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`III. Educational and Employment Background
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`6.
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`As indicated in my Curriculum Vitae, attached as Exhibit 2006, I
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`received my Ph. D. in Optics from the University of Rochester in New York in 1974.
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`I also received an M.S. in Optics from the University of Rochester in 1970 and a
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`B.A. in Physics from the University of Maine in 1969.
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`7.
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`As further described in my Curriculum Vitae, I am the Rudolf and Hilda
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`Kingslake Professor of Optical Engineering at the University of Rochester, and have
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`held that position since 1993. I have been a Professor at the Institute of Optics at the
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`University of Rochester since 1986, and before that I held the titles of Assistant
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`Professor and then Associate Professor at the Institute of Optics at the University of
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`Rochester, starting in 1974. I have also served as Dean of the School of Engineering
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`and Applied Sciences at the University of Rochester from 1995 to 1997. In all, I
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`have conducted optics research and taught optics to both undergraduate and graduate
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`students for more than 40 years.
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`8.
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`I also have extensive professional experience in the fields of optics and
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`engineering. I worked for Western Electric Engineering Research Center from 1969-
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`1971 where I was responsible for the design and fabrication of specialized lens
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`systems. Beginning in 1971, I performed consulting and design services for gradient-
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`index lens systems and conventional lens systems. In 1980, I founded and became
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`President of the Gradient Lens Corporation. From 1997-2000, I was an Associate
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`Director of Technology at the White House Office of Science and Technology
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`Policy. From 2002-2004, I was President and Chief Executive Officer of Infotonics
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`Technology Center. My Curriculum Vitae details various other professional
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`positions I have held in the fields of optics and engineering over the last 40 years.
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`9.
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`I have held several advisory positions, including Special Advisor to the
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`Director, White House Office of Science and Technology Policy, Executive Office
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`of the President in 2001 and Senior Science Advisor to the Optical Society of
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`America from 2001 to 2003. I am a Fellow of the Optical Society of America, the
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`International Society for Optical Engineering (SPIE), American Association for the
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`Advancement of Science, IEEE and the American Institute for Medical and
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`Biological Engineering for my work in optics. I was also the Chairman of the Hubble
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`Space Telescope Independent Optical Review Panel for NASA from 1990 to 1991.
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`This committee determined the correct prescription to repair the Hubble Telescope.
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`I am currently the Chairman of the Product Integrity Team verifying the optics for
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`the future replacement for the Hubble, the James Webb Telescope – which, unlike
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`the Hubble, will not be serviceable.
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`10.
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`I have been awarded numerous honors over the course of my career
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`including Election to the National Academy of Engineering (membership
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`comprising 0.1% of all engineers in the U.S.), Engineer of the Year by Rochester
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`Engineering Society, National Engineering Award from the American Association
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`of Engineering Societies, Optical Society of America Leadership Award, the
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`International Society for Optical Engineering (SPIE) Gold Medal, and the Edwin
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`Land Medal of the Society for Imaging Science and Technology and the Optical
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`Society of America (OSA).
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`11.
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`I have authored or co-authored almost 90 publications in the field of
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`optics, and I was an editor of several books on Optics. I have given over 150
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`presentations on optics. I am an inventor of 17 U.S. patents related to optics.
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`IV. Level of Ordinary Skill in the Art (POSITA)
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`12.
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`I understand that in evaluating the validity of the ‘568 patent claims,
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`the content of a patent or printed publication prior art should be interpreted the way
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`a person of ordinary skill in the art would have interpreted the prior art as of the
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`effective filing date of these challenged patents.
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`13.
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`I understand that factors that may be considered in determining the level
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`of ordinary skill in the art at the time of the effective filing date of the challenged
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`patents include: (1) the educational level of the inventor; (2) type of problems
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`encountered in the art; (3) prior art solutions to those problems; (4) rapidity with
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`which innovations are made; (5) sophistication of the technology; and (6)
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`educational level of active workers in the field.
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`14.
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`In my opinion, a person of ordinary skill in the art (POSITA) of the
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`‘568 patent, at the time of the effective filing date, would have possessed an
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`undergraduate degree in optical engineering, electrical engineering, or physics, with
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`the equivalent of three years of experience in optical design.
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`15.
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`I understand that the ’568 patent is a continuation-in-part of U.S. App.
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`No. 15/170,472, now the ’721 patent, which is a continuation of application U.S.
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`App. No. 14/932,319, now the ’032 patent, which has the benefit of priority to U.S.
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`Provisional App. No. 61/842,987, filed on July 4, 2013. See Ex. 1001, at 1. I
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`understand that the effective filing date of the ’568 patent is July 4, 2013. I note that
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`Dr. Sasián appears to have applied this date in his analysis of the level of ordinary
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`skill as well. Ex. 1003, ¶ 19.
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`16.
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`I understand that Dr. Saisian states that a POSITA for the ’568 patent
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`would have “approximately three years of experience in designing and/or
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`manufacturing multi-lens optical systems.” Ex. 1003, ¶ 19 (emphasis added).
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`However, in IPR2018-01140, in which Apple is currently challenging claims of the
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`‘032 patent, based upon the same Ogino prior art patent, Dr. Saisian stated that a
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`POSITA would have “approximately three years of experience in designing multi-
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`lens optical systems.” Ex. 2013, ¶ 19 (emphasis added).
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`17.
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`I understand that the ‘032 patent and ‘568 patent are related by
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`continuation-in-part and share largely identical specifications. However, Dr. Sasián
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`states only in the ‘568 patent IPR proceeding that a POSITA would have experience
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`“manufacturing” multi-lens optical systems.
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`18.
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`I understand also that, in his July 2, 2019 deposition, Dr. Sasián
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`confirmed that a person with lens design experience, but no lens manufacturing
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`experience, can meet the requirements to be a POSITA for the ’568 patent. Ex. 2012,
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`20:12-22.
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`19.
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`I do not agree with Dr. Sasián that the definition of a POSITA for the
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`’568 patent requires manufacturing experience. The work of a lens designer does
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`not typically overlap with that of a lens manufacturer, except in the way that the
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`design and production stages of any given product would typically overlap. I also
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`note that the Beich prior art reference, which Dr. Sasián contends may be combined
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`with Ogino, notes the disjoint between engineering teams (that design lenses) and
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`the manufacturers of the lenses. See Ex. 1020, at 2, 10.
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`20. A POSITA for the ’568 patent, for which Apple and Corephotonics
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`both agree would have the equivalent of three years of lens design experience, would
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`have been unlikely to have specialized knowledge specific to the manufacture of
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`lenses, which constitutes a separate field entirely. Dr. Sasián confirmed this view at
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`his July 2, 2019 deposition, where he stated that: (1) he could not recall any course
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`taught by the college of optical sciences where “students obtain experience with
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`injection molding plastic lenses”; (2) could not remember any student, in his 40 years
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`of teaching, who had “experience [with] injection molding plastic lenses prior to the
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`time they graduate[d];” and that (3) the last time he visited a factory where plastic
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`lenses were being injection molded was in 2006. Ex. 2012, at 25:11-15, 26:2-27:11.
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`I also note that Dr. Sasián could not confirm there was a “injection molding
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`machine” at his University.” Id. at 26:2-7.
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`V. Relevant Legal Standards for Anticipation and Obviousness
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`21.
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`I have been informed of the legal standards for establishing patent
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`invalidity in inter partes review proceedings before the Patent Trial and Appeal
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`Board.
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`22.
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`I understand that the petitioner must prove invalidity of a patent claim
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`by a preponderance of the evidence, that is, the evidence must be sufficient to show
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`that a fact or legal conclusion is more likely than not.
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`23.
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`I understand that a claim may be anticipated if (1) the claimed invention
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`was patented, described in a printed publication, or in public use, on sale, or
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`otherwise available to the public before the effective filing date of the claimed
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`invention; or (2) the claimed invention was described in a patent or published
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`application, in which the patent or application names another inventor and was
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`effectively filed before the effective filing date of the claimed invention.
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`24.
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`I understand that, once the claims of a patent have been properly
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`construed, the next step in determining anticipation of a patent claim requires a
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`comparison of the properly construed claim language to the prior art on a limitation-
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`by-limitation basis.
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`25.
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`I understand that a prior art reference “anticipates” an asserted claim,
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`and thus renders the claim invalid, if all elements of the claim are disclosed in that
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`prior art reference. In determining whether every one of the elements of the claimed
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`invention is found in the prior art, I understand that one should take into account
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`what a person of ordinary skill in the art would have understood from his or her
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`examination of the particular prior art. I also understand that the prior art reference
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`alleged to be anticipatory must also enable one of ordinary skill in the art to make
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`the claimed invention without undue experimentation.
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`26.
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`I understand that anticipation must be found in a single reference,
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`device, or process. In other words, anticipation does not allow an additional
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`reference to supply a missing claim limitation. I further understand that the prior art
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`reference must disclose all elements of the claim within the four corners of the
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`document. I further understand that the reference must disclose those elements
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`arranged as in the claim, and that the disclosure not be so sparse and ambiguous for
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`a person of ordinary skill to understand it to be disclosing the claim. I understand
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`that in order for an element to be considered inherently disclosed by a reference, it
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`must necessarily, and not simply likely, be present in light of the disclosure.
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`27. Moreover, I understand that any differences between a prior art
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`reference and a claimed invention invoke the question of obviousness, not
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`anticipation. In other words, I understand it is not sufficient for a prior art reference
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`to disclose part of a claimed invention or that it includes multiple distinct teachings
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`that one of ordinary skill in the art might somehow combine to achieve the claimed
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`invention. The prior art reference must disclose the claimed invention without any
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`need for combining various disclosures not directly related to each other. I further
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`understand that an ambiguous prior art reference cannot be anticipatory.
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`28.
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`I understand that even if a patent claim is not anticipated, it may still be
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`invalid if the differences between the claimed subject matter and the prior art are
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`such that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person of ordinary skill in the pertinent art.
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`29.
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`I also understand that a patent may be rendered obvious based on an
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`alleged prior art reference or a combination of such references plus what a person of
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`ordinary skill in the art would understand based on his or her knowledge and the
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`references. It is also my understanding that in assessing the obviousness of claimed
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`subject matter one should evaluate obviousness over the prior art from the
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`perspective of one of ordinary skill in the art at the time the invention was made (and
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`not from the perspective of either a layman or a genius in that art).
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`30.
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`I understand that a patent claim composed of several elements is not
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`proved obvious merely by demonstrating that each of its elements was known in the
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`prior art. There must be a reason for combining the elements in the manner claimed.
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`That is, there must be a showing that a person of ordinary skill in the art at the time
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`of the invention would have thought of either combining two or more references or
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`modifying a reference to achieve the claimed invention.
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`31.
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`I understand
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`that an obviousness determination
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`includes
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`the
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`consideration of the following factors: (1) the scope and content of the prior art, (2)
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`the differences between the prior art and the claims at issue, (3) the level of ordinary
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`skill in the art, and (4) objective evidence of nonobviousness.
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`32.
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`I understand that the burden is on the petitioner to explain how specific
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`references could be combined, which combinations of elements in specific
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`references would yield a predictable result, and how any specific combination would
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`operate or read on the claims. I further understand that the petitioner cannot rely on
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`conclusory statements but must instead provide a reasoned explanation supported by
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`evidence. I also understand that obviousness does not exist where the prior art
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`discourages or teaches away from the claimed invention.
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`33.
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`I understand that it is impermissible to use hindsight to arrive at the
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`claimed invention. My understanding is that the inventor’s own path never leads to
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`a conclusion of obviousness. I also understand that, when assessing whether there
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`was a motivation to combine references to teach a claim element, defining the
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`problem in terms of its solution reveals improper hindsight.
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`34.
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`I also understand that in evaluating whether patent claims are invalid as
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`obvious, objective indicia of nonobviousness are considered. Such objective indicia
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`of nonobviousness can include unexpected results, and, (a) long-felt and unmet need
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`in the art that was satisfied by the invention of the patent; (b) failure of others to
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`achieve the results of the invention; (c) commercial success or lack thereof of the
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`products and processes covered by the invention; (d) deliberate copying of the
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`invention by others in the field; (e) taking of licenses under the patent by others; (f)
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`whether the invention was contrary to the accepted wisdom of the prior art; (g)
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`expression of disbelief or skepticism by those skilled in the art upon learning of the
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`invention; (h) unexpected results achieved by the invention; (i) praise of the
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`invention by others skilled in the art; and (j) lack of contemporaneous and
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`independent invention by others.
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`35.
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`I understand that, in this proceeding, prior art to the ’568 patent includes
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`patents and printed publications in the relevant art that predate the effective filing
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`date of the ‘568 patent’s challenged claims, which I understand to be July 4, 2013.
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`VI. Background
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`A. Overview of the ’568 Patent
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`36.
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`I understand that the patent at issue in this case is Patent Owner
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`Corephotonics’ ’568 patent. Ex. 1001.
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`37. The ’568 patent is directed to fixed-focal length telephoto lens
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`assembly
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`technology with a small
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`thickness and good quality
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`imaging
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`characteristics. Ex. 1001 at 1:43-45. The ’568 patent advantageously teaches and
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`claims such compact telephoto assemblies for application in digital camera modules
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`that are used in digital camera modules used in mobile devices, such as cellular
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`telephones. Id. at 1:29-31. The ’568 patents state that they thus provide a miniature
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`lens assembly with a small total track length (TTL) and small ratio of TTL to the
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`effective focal length (EFL) of the lens assembly to meet the need of a small camera
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`for use in mobile devices and with better image quality than existing lens assemblies.
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`Id. at 1:29-45, 2:4-8.
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`38. The total track length (TTL) determines how long or thick a camera
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`will be. The smaller the TTL, the thinner and more compact the camera. The
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`effective focal length (EFL) determines how well the camera performs at capturing
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`images of small or distant objects, as opposed to closer objects. A lens with a greater
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`EFL is able to capture images of such objects at greater distances and create a
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`magnified image. By increasing the EFL, the field of view (FOV) is narrowed. This
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`allows the camera to view things that are further away, which allows them to be
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`resolved better because the focal length has changed. If a sensor size stays constant,
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`then the field of view gets smaller. This means, for example, that if the user sees
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`trees farther away, the camera with a longer focal length lens will provide an image
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`that can resolve precise features like the tree branches. An increase the focal length
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`will reduce the FOV. In a system with two cameras with different fixed focal lengths,
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`then each camera will show a different level of magnification of objects in the scene.
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`The one with a higher magnification will appear to be “zoomed in.”
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`39. The ’568 patent explains that the prior art conventional assemblies did
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`not have good image quality or TTL/EFL properties suitable for use in telephoto
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`cameras in mobile devices. Ex. 1001 at 1:36-42. In particular, the ’568 patent is
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`directed to providing a ratio of TTL to EFL (TTL / EFL) less than 1, which means
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`the lens is a telephoto lens which provides a narrower field of view than a standard
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`camera. The ’568 patent also provides a small TTL, which is suitable for use in a
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`mobile device, such as a cell phone. Ex. 1001, 1:33-36 (“Cameras in cellphone
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`devices in particular require a compact imaging lens system for good quality imaging
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`and with a small total track length (TTL).”); 5:2-3; 6:42-46, 7:63-65 (embodiments
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`providing TTL of 5.904 mm, 5.9 mm, and 5.904 mm respectively). A system that
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`combines a telephoto lens (which has a TTL/EFL ratio of less than 1) with a wide
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`angle lens (which has a TTL/EFL ratio greater than 1) provides the optical zoom
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`feature found on many modern smartphones.
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`40. The ’568 patent is also directed to a low F-number (F#). The F# in a
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`single lens element is the ratio of the focal length of a lens to the aperture diameter
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`of the lens. The F# determines the exposure time of the lens system, i.e., how much
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`light the sensor will be exposed to. The F# is also related to lens resolution and
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`depth of field. All of the exemplary embodiments in the ’568 patents have a F# less
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`than 3.2. Ex. 1001 at 2:8-9.
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`41. The ’568 patent’s embodiments and claims describe lens assemblies
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`that follow design rules for the shapes of lens surfaces (convex, concave, meniscus),
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`the focal lengths of individual lenses, thicknesses of lenses, air gaps between lenses,
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`and material properties. The ’568 patents’ claims describe ranges and relationships
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`between the properties of the lenses in the assembly. For example, claim 1 of the
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`’568 patent provides as follows:
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`1. A lens assembly, comprising: a plurality of refractive lens elements
`arranged along an optical axis with a first lens element on an object
`side, wherein at least one surface of at least one of the plurality of lens
`elements is aspheric, wherein the lens assembly has an effective focal
`length (EFL), a total track length (TTL) of 6.5 millimeters or less, a
`ratio TTL/EFL of less than 1.0, a F number smaller than 3.2 and a ratio
`between a largest optical axis thickness L11 and a circumferential edge
`thickness L1e of the first lens element of L11/L1e<4.
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`42. The ’568 patent discloses three exemplary embodiments. Below this
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`paragraph is a reproduction of Fig. 3A from the ’568 patent, which shows
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`embodiment “300.” Ex. 1001, 7:23-8:19. In this diagram, the “object” side, where
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`the scene or object being viewed would be, i.e., in front of the camera, is to the left,
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`and the “image” side, where the image is projected, i.e., back of the camera, is to the
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`right. Fig. 3A also shows the result of a ray-trace simulation through the lens
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`assembly of embodiment 300. The specification discloses that embodiment 300
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`provides an EFL of 6.84 mm and TTL of 5.904 mm. The specification discloses that
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`the lens assembly has a FOV (field of view) of 44 degrees, and that the TTL/EFL
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`ratio is 0.863. Ex. 1001, 7:63-66.
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`43.
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`In Fig. 3A, the “object-side” of the lens assembly is on the left, and the
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`“image-side” of the lens assembly (i.e., where the image of the object is projected
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`onto the surface of a sensor) is on the right. The thickness of the first lens on the
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`object-side, L11, is 1.5127mm, while the edge thickness of that lens, L1e, is
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`0.298mm, thus yielding a center-to-edge thickness ratio of 3.08.
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`44. Element 312 in Fig. 3A above is a cover glass, which is positioned
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`before the image sensor location. Element 312 is a cover glass (also known as cover
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`glass window or cover plate). The cover glass has at least two important functions
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`in a lens system. 1) The cover glass protects the sensitive surface of the electronic
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`sensor. This is particularly important because in the manufacturing process, there
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`can be damage to the electronic sensor, for example because of dust, which will
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`block light from reaching portion of the sensor and make it unusable. This problem
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`is described, for example, in the Bareau article, which Apple included as an exhibit
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`to its petitions, and which points to “contamination” close to image sensor as a
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`particular problem for miniature cameras. Ex. 1012, 2-3. The cover glass also may
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`be coated with a layer that cuts off infrared light before reaching the sensor. This
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`ensures that the sensor responds only to visible light from the objects that the user
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`takes a picture of, so that the resulting image accurately shows the visible light in
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`the scene. As a practical matter, cover glass windows are included, by design, as
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`integral and permanently-attached components of the electronic image sensors at
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`issue. Humpston et al., “Optical performance of bare image sensor die and sensors
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`packaged at the wafer level and protected by a cover glass,” Proceedings of SPIE
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`(2008) (Ex. 2019), at 12 (“a packaged image sensor must have a cover glass as an
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`additional component in the optical train”) (emphasis added).
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`B. Multiple Element Lens Design
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`45. The design parameters of a lens assembly include, among others: 1) the
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`properties of lens materials (index of refraction, as well as the Abbe number, which
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`describes the dispersion of refraction in the lens); 2) shapes of the optical surfaces
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`of the lenses; 3) thicknesses of each of the lenses; 4) distances between each of the
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`lens elements as well as the face of the image sensor; 5) the precise contours of the
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`front (object-facing) and back (image-facing) surfaces of the lenses; 6) the aperture
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`stop size and location.
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`46. The optical surfaces of the lenses are determined by radii of curvature
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`and “aspheric coefficients.” To achieve improved performance by reducing spherical
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`aberrations, astigmatism, and other problems with image quality, lens assemblies
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`employ “aspheric” lens shapes, which are more complex than ordinary spherical
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`lenses. The “aspheric coefficients” are parameters of a mathematical equation that
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`defines a curve in space. The curve defined by that equation defines the curvature of
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`the lens. The equation that defines the curvature of lenses is provided in the ’568
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`patents as follows:
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`
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`47.
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`In the above equation, r is distance from (and perpendicular to) the
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`optical axis, k is the conic coefficient, c=1/R where R is the radius of curvature, and
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`the α’s are aspheric coefficients. Each surface (front and back) of each lens is defined
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`by a combination of numbers for each of the above parameters. Calculating the
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`above equation will generate a curve that defines the surface. The sum total of all of
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`the parameters of a lens system, including the gaps between lenses, the curvature
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`parameters, indices of refraction
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