IPR2020-00878
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,330,897
`
`IPR2020-00878 | SLIDE 1
`
`
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,330,897
`
`IPR2020-00878 | SLIDE 1
`
`
`
`Grounds at Issue
`• Ground 2: Claims 2, 5, 6, 18, and 21–23
`Obviousness over Ogino and Baraeu
`• Ground 3: Claims 3, 8, 19, and 24
`Obviousness over Ogino, Bareau, and Kingslake
`• Ground 4: Claims 16 and 30
`Obviousness over Chen, Iwasaki, and Beich
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00878 | SLIDE 2
`
`
`
`Overview of Argument
`• Ground 2:
`• Proposed modification of Ogino example 5 with reduced F# is:
`• Contrary to the teachings of Bareau
`• Not manufacturable: thin lens edge, large center-to-edge ratio, steep edge angle, lack of oversizing,
`sharp corners
`• Ground 3:
`• No motivation for modification from concave to convex image-side surface
`• Sasián analysis is unreliable
`• Ground 4:
`• Proposed combination requires unachievable manufacturing precision and will leak
`light
`
`IPR2020-00878 | SLIDE 3
`
`
`
`core ' photonics
`
`Ground 2
`Ground 2
`
`IPR2020-00878 | SLIDE 4
`
`
`
`Independent Claims 1 and 17
`
`Ex. 1001, 8:22–37
`
`IPR2020-00878 | SLIDE 5
`
`
`
`Dependent Claims 2, 5, 6, 18, 21, 23 – F#<2.9 or F#=2.8
`
`Ex. 1001, 8:37–10:17
`
`IPR2020-00878 | SLIDE 6
`
`
`
`Ogino Example 5
`
`POR at 19; Ex. 1005, Fig. 5
`
`IPR2020-00878 | SLIDE 7
`
`
`
`Ogino Example 5: F# = 3.94
`
`POR at 19–20; Ex. 1005, Fig. 12
`
`IPR2020-00878 | SLIDE 8
`
`
`
`Bareau “Typical Lens Specifications”
`
`POR at 22, 31; Ex. 1012 at 3
`
`IPR2020-00878 | SLIDE 9
`
`
`
`Ogino Examples: Other F# Values
`
`POR at 30–31; Ex. 1005, Figs. 8–13
`
`IPR2020-00878 | SLIDE 10
`
`
`
`Modifying Ogino Example 5:
`
`POR at 37–38; Ex. 1005, Fig. 5; Ex. 1003 at 104
`
`IPR2020-00878 | SLIDE 11
`
`
`
`Modifying Ogino Example 5: First Lens Element
`
`POR at 37–38; Ex. 1005, Fig. 5; Ex. 1003 at 104
`
`IPR2020-00878 | SLIDE 12
`
`
`
`Modifying Ogino Example 5: Field of View Too Narrow
`Bareau (Ex. 1012 at 3): FOV=60–66 degrees
`
`Ogino Example 5: FOV=51.8 degrees
`
`Dr. Sasián’s Lens: FOV=40 degrees
`
`POR at 31–32; Ex. 1012 at 3; Ex. 1005, Fig. 12; Ex. 1003 at 104
`
`IPR2020-00878 | SLIDE 13
`
`
`
`Ogino Examples: Other Designs Are Closer to Bareau’s F# and FOV
`
`POR at 30–31, 34; Ex. 1005, Figs. 8–13
`
`IPR2020-00878 | SLIDE 14
`
`
`
`Modifying Ogino Example 5: First Lens Element Unmanufacturable
`
`• Microscopic lens edge
`• Steep edge slope
`• High center-to-edge ratio
`• No ability to oversize
`• Sharp corners
`
`Not manufacturable using any
`technique for lens manufacture
`
`POR at 39; SR at 2
`
`IPR2020-00878 | SLIDE 15
`
`
`
`Ogino Lenses Would Preferably Be Plastic Injection Molded
`
`“While Ogino does not specifically indicate that its lens elements
`can be plastic, a POSITA would recognize that the index of
`refraction and Abbe number of the lens elements specified in
`Example 6 of Ogino are within the range of values of plastic
`materials used for cell phone lenses.
`
`“Further lens elements of the sizes and asphericities described
`in Ogino would preferably be made of plastic via injection
`molding processes. See Ex.1019, p.34.14 (pdf p.80). A POSITA
`would also recognize that when designing lens elements for
`crafting via injection molding, a number of manufacturing
`realities apply that all promote maximizing the thickness of the
`lens element at the edge.”
`
`IPR2020-00878 | SLIDE 16
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`POR at 35; Ex. 2009 at 69
`
`
`
`Bareau Teaches Plastic Injection Molded Lenses
`
`POR at 35–36; Ex. 1012 at 8
`
`IPR2020-00878 | SLIDE 17
`
`
`
`But Dr. Milster’s Manufacturability Analysis
`Addresses All Techniques of Manufacture
`• Injection Molding of Plastic
`(Ex. 2001, ¶¶ 60, 62, 77-78, 103-108, 112, 117, 121)
`• Injection Molding of Glass
`(Id., ¶¶ 60, 63, 103-108, 112, 117, 119, 120)
`• Grinding or Polishing of Glass
`(Id., ¶¶ 60, 63, 104-107, 110, 117, 119, 120)
`• Diamond Turning
`(Id., ¶¶ 104, 107, 117, 120, 121)
`• Any Other Technology
`(Id., ¶¶ 106-107, 117)
`
`Apple does not identify any technique that would
`overcome the manufacturability problems
`
`IPR2020-00878 | SLIDE 18
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`SR at 2; Ex. 2001
`
`
`
`Ground 2 – Narrow Edge
`
`POR at 40-41; Ex. 2001, ¶ 99
`
`0.075 mm
`
`Human Hair
`
`IPR2020-00878 | SLIDE 19
`
`
`
`Ground 2 – Narrow Edge
`
`The edge of Dr. Sasián’s lens is 39.4 microns
`
`POR at 51; Ex. 2006 at 102 (copyright 2016)
`
`IPR2020-00878 | SLIDE 20
`
`
`
`Ground 2 – Narrow Edge
`
`“This is not the edge of a realistic, practical lens”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 41; Ex. 2001, ¶ 99
`
`IPR2020-00878 | SLIDE 21
`
`
`
`Ground 2 – Narrow Edge
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 42; Ex. 2001, ¶ 100
`
`IPR2020-00878 | SLIDE 22
`
`
`
`Ground 2 – Narrow Edge
`
`“Oversizing is necessary because a lens cannot be made
`with perfectly sharp corners and edges. In molded
`lenses, one reason for this is surface tension of the lens
`material. If one attempted to inject plastic or glass into
`a mold with sharp corners such as shown in the Zemax
`drawing, the liquid would not fill the corners, but would
`rather form a rounded surface, which would bend light
`differently than the ideal shape in Zemax”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 41; Ex. 2001, ¶ 99
`
`IPR2020-00878 | SLIDE 23
`
`
`
`Ground 2 – Narrow Edge
`“Even if the surface tension and other limitations of injection
`molding were not a factor, practical lenses will have rounded
`or chamfered corners rather than sharp 90° corners,
`regardless of the technology used to make them. As Dr. Sasián
`notes in his textbook, ‘[i]t is imperative that a bevel, or
`protective chamfer, is specified to avoid the lens edge easily
`chipping.’ (Ex. 2004, Sasián at 112.)
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`“A sharp corner is mechanically much weaker than a rounded
`or chamfered corner. . . . Making extremely sharp corners
`without chipping the lens is difficult regardless of the
`manufacturing technique used.”
`POR at 45-46; Ex. 2001, ¶ 106-107
`
`IPR2020-00878 | SLIDE 24
`
`
`
`Ground 2 – The Need to Oversize
`
`POR at 46; Ex. 1019, at 34.16
`
`IPR2020-00878 | SLIDE 25
`
`
`
`Ground 2 – The Need to Oversize
`
`POR at 47; Ex. 2006 at 103
`
`IPR2020-00878 | SLIDE 26
`
`
`
`Ground 2 – The Need to Oversize
`
`Petitioner’s Expert
`POR at 47–48; Ex. 2004 at 111
`
`IPR2020-00878 | SLIDE 27
`
`
`
`Ground 2 – Impractical Slope
`
`POR at 40, 53; Ex. 2006 at 94; Ex. 2001, ¶ 98
`
`IPR2020-00878 | SLIDE 28
`
`
`
`Ground 2 – Impractical Slope
`
`“While this discussion appears in the section on glass
`molding, each of these problems applies equally to
`molding plastic and indeed to almost any
`manufacturing technique. . . . A POSITA would
`recognize that the 58.86° slope in Dr. Sasián’s modified
`lens is not practical.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 53; Ex. 2001, ¶ 121
`
`IPR2020-00878 | SLIDE 29
`
`
`
`Ground 2 – Limits of Manufacturing Precision
`
`Beich Manufacturing Tolerances
`
`POR at 48; Ex. 1007 at 7
`
`IPR2020-00878 | SLIDE 30
`
`
`
`Ground 2 – Limits of Manufacturing Precision
`
`“While this discussion appears in the section on glass
`molding, each of these problems applies equally to
`molding plastic and indeed to almost any
`manufacturing technique. . . . A POSITA would
`recognize that the 58.86° slope in Dr. Sasián’s modified
`lens is not practical.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 53; Ex. 2001, ¶ 121
`
`IPR2020-00878 | SLIDE 31
`
`
`
`Ground 2 – Limits of Manufacturing Precision
`
`“Tolerances for glass molding are similar. (Ex. 2006,
`Symmons at 95.) As the Field Guide notes, ‘high
`repeatability from component to component’ is an
`advantage of molded lenses over other techniques, so
`other techniques have tolerance issues as well. (Ex.
`2006, Symmons at 2.)”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 48–49; Ex. 2001, ¶ 112
`
`IPR2020-00878 | SLIDE 32
`
`
`
`Ground 2 – Limits of Manufacturing Precision
`
`“Manufacturing tolerances add up. . . . [T]hese four
`variances add under the root sum square rule to yield
`an error that goes as the square root of the number of
`errors. (Ex. 2004, Sasián at 116–117.) Even if the first
`lens is slightly oversized, these additive errors can
`easily lead to a situation where there is an open gap
`between the first lens and the aperture, allowing light
`to leak through and adding a diffuse haze to the image,
`something that is highly undesirable.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 48–49; Ex. 2001, ¶ 112
`
`IPR2020-00878 | SLIDE 33
`
`
`
`Ground 2 – Center-to-Edge Thickness
`“These many issues with thin lens edges lead to a rule of thumb in
`the Beich paper, which Dr. Sasián himself cites as something that a
`POSITA would be motivated to follow: the ‘Center Thickness to Edge
`Thickness Ratio’ should be less than 3:1. (Ex. 1007, Beich at 7; Ex.
`1003, Sasián Decl., ¶ 78.) Dr. Sasián’s textbook gives a similar rule of
`thumb, saying ‘the ratio of lens central thickness to edge thickness
`should [not be more] than than 3.2.’ (Ex. 2004, Sasián at 194.) My
`chapter in the Handbook of Optics likewise says to use ‘a center/edge
`thickness ratio less than 3.’ (Ex. 2008, Handbook of Optics at 7.11.) By
`contrast, Dr. Sasián’s design has a ratio of 0.6 mm / 0.039375 mm =
`15.238, far outside the range of what a POSITA would consider
`manufacturable.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 51—52; Ex. 2001, ¶ 118
`
`IPR2020-00878 | SLIDE 34
`
`
`
`Ground 2 – Center-to-Edge Thickness
`“While that rule of thumb applies to plastic lenses, a POSITA would
`recognize that the tiny edge thickness is similarly problematic for
`glass lenses. For example, the Field Guide states that ‘Very small edge
`thicknesses (<0.4 mm) should be avoided, as these lenses become
`very difficult to handle and can chip easily.’ This chipping issue is not
`unique to molded glasses, but will also apply to glass lenses formed
`other ways. Bareau recognizes this as a general problem for glass
`lenses when it warns that ‘[f]or glass elements, the edge thicknesses
`will become too thin to be fabricated without chipping.’ (Ex.
`1012, Bareau at 1.) A POSITA would recognize that the edge of Dr.
`Sasián’s lens (0.0394 mm) is too small by a factor of ten for a glass
`lens.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 52; Ex. 2001, ¶ 119
`
`IPR2020-00878 | SLIDE 35
`
`
`
`Ground 2 – Apple’s Argument that a POSITA Would Not Have
`Known It Was Impossible to Manufacture the Proposed Lens
`
`SR at 4–5; Ex. 2004 at 111–112, 194
`
`IPR2020-00878 | SLIDE 36
`
`
`
`Ground 2 – Apple’s Arguments Based on Konno and Mercado Fail
`
`Ground 2 Lens
`
`Konno Lens
`
`Mercado Lens
`
`POR at 38; SR at 6; Ex. 2001, ¶ 95; Ex. 1035, Fig. 11; Ex. 1036, Fig. 13
`
`IPR2020-00878 | SLIDE 37
`
`
`
`Ground 2 – Apple’s Arguments Based on Konno and Mercado Fail
`
`Konno Lens
`Drawing
`
`Dr. Sasián’s Simulation
`of Konno Lens
`
`SR at 6-8; Ex. 1035, Fig. 11; IPR2020-00906, Ex. 1021 at 31
`
`IPR2020-00878 | SLIDE 38
`
`
`
`Ground 2 – Apple’s Arguments Based on Konno and Mercado Fail
`
`Q. So at least to the extent that Figure 11 of Konno is
`describing an injection-molded plastic lens, one skilled
`in the art would understand that the lens actually being
`represented by Figure 11 wouldn’t have the front and
`back surfaces of the first lens meeting at a sharp edge,
`but there would be some other shape there, right?
`A. Yes. They would incorporate a flange, F-L-A-N-G-E.
`They would adjust the lens for the fabrication process at
`hand.
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`SR at 8; Ex. 2012 at 115:3–24
`
`IPR2020-00878 | SLIDE 39
`
`
`
`Ground 2 – Apple’s Arguments Based on Konno and Mercado Fail
`
`Q. And so one skilled in the art, looking at Figure 13 of
`Mercado, and wanting to build that lens using injection-
`molded plastic, would they understand that the actual
`shape of the lens outside of the clear aperture would be
`different than what's shown in Figure 13 so that the lens
`could have, for example, a flange?
`A. I wouldn’t say that would understand. They would
`adjust the lens for the fabrication process at hand.
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`SR at 8-9; Ex. 2012 at 117:11–118:1
`
`IPR2020-00878 | SLIDE 40
`
`
`
`core ' photonics
`
`Ground 3
`
`IPR2020-00878 | SLIDE41
`
`
`
`Dependent Claims 3, 8, 19, and 24 – Image-Side Surface
`
`Ex. 1001, 8:40–10:19
`
`IPR2020-00878 | SLIDE 42
`
`
`
`Modifying Ogino Example 5, Again: First Lens Element
`
`POR at 57–58; Ex. 1003 at 104, 108
`
`IPR2020-00878 | SLIDE 43
`
`
`
`Modifying Ogino Example 5, Again: First Lens Element
`Q. Am I correct that the only values on Page 11 from the
`rows defining the first lens element that match any
`values in Ogino Example 5 are the index of refraction
`and the Abbe number of the glass used?
`
`A. And the question refers to the first lens?
`Q. Correct.
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`A. Yes. I believe so.
`
`POR at 58; Ex. 2003 at 48:15–24
`
`IPR2020-00878 | SLIDE 44
`
`
`
`Ogino Examples: Other F# Values
`
`POR at 60; Ex. 1005, Figs. 8–13
`
`IPR2020-00878 | SLIDE 45
`
`
`
`Ogino First Lens Element Has Concave Image Surface
`
`POR at 56–57; Ex. 1005 at 7:31–37
`
`IPR2020-00878 | SLIDE 46
`
`
`
`Ogino First Lens Element Has Concave Image Surface
`“The fact that the first lens element has a
`concave image-side surface is a feature of
`every example in Ogino and is described by
`Ogino as a defining feature of its invention.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 56; Ex. 2001, ¶ 126
`
`IPR2020-00878 | SLIDE 47
`
`
`
`Dr. Sasián Produced a Convex Image-Side Surface
`By Fixing the Radius of Curvature to Be Negative
`“The blank box to the right of the radius of curvature for this
`image-side surface indicates that this value was fixed (and
`thus that that surface was fixed to be convex) during the run
`of Zemax that produced the screen capture:”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 61; Ex. 2001, ¶ 136; Ex. 1003 at 111
`
`IPR2020-00878 | SLIDE 48
`
`
`
`Dr. Sasián Did Not Explain and Could Not Remember
`How He Obtained a Negative Radius of Curvature
`Q. So is it correct that they were generated automatically by the program and then
`you told Zemax to stop changing them as you performed further optimization?
`A. Probably.
`Q. And so the particular output we see on Page 111 reflects an optimization step
`where the aspheric coefficients were allowed to vary but the radii and thicknesses
`were not; is that right?
`A. Perhaps. Perhaps.
`Q. Why do you say, "Perhaps"?
`A. It appears so that -- because I don't remember exactly the -- the sequence. . . .
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`POR at 62; Ex. 2003 at 50:18–53:9
`
`IPR2020-00878 | SLIDE 49
`
`
`
`No Motivation or Explanation for
`Changing Ogino’s Lens from Concave to Convex
`• No explanation for why a POSITA would ignore Ogino’s teachings on lens
`shape
`• Only explanation for even changing radius of curvature is vague statement
`“due to location of the aperture”
`• No examples cited of prior art with bi-convex first lens shape
`• No benefits or other motivation cited for bi-convex shape
`• The fact that the Board found it obvious to change Ogino Example 6’s second
`lens from biconcave to menicus based on Chen II in IPR2018-01140 does not
`make it obvious to change the shape of Ogino Example 5’s first lens based on
`nothing at all.
`
`POR at 63; SR at 13–15
`
`IPR2020-00878 | SLIDE 50
`
`
`
`What F# Did Dr. Sasián Actually Use? 2.45 or 2.12?
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`POR at 60–61; SR at 16–17; Ex. 1003 at 108
`
`IPR2020-00878 | SLIDE 51
`
`
`
`What F# Did Dr. Sasián Actually Use? 2.45 or 2.12?
`
`San-serif, proportional font
`Manually typed by Sasián
`from memory
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`SR at 16–17; Ex. 1037, ¶ 33
`
`Serif, fixed-width font
`Zemax screen shoot
`
`IPR2020-00878 | SLIDE 52
`
`
`
`What F# Did Dr. Sasián Actually Use? 2.45 or 2.12?
`Q. If I could -- yeah. I mean, if I could interrupt, I think the EFL, TTL, and F1 values
`in that list of five values match, subject to rounding values, from the screen capture
`below that list of values. But I don't see the entrance pupil diameter or the f-number
`in that table.
`A. Okay.
`Q. So -- and -- yeah. And I was just wondering where this came from. It doesn't
`seem to be the font that ZEMAX uses in its output. It looks like ZEMAX uses a serif
`font, and this font is sans serif. So where did this list of five values in your paragraph
`33 come from?
`A. Yes. The font is not the same, because I manually wrote those lines on --
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`SR at 16–17; Ex. 2012 at 101:1–15
`
`IPR2020-00878 | SLIDE 53
`
`
`
`What F# Did Dr. Sasián Actually Use? 2.45 or 2.12?
`Q. And the f-number equal to 2.45, what were you looking at when you typed in
`those numbers?
`A. I think, in this case, you have to tell the program what would be the f-number, and
`you just request the f-number to be 2.45, and then you know it's 2.45.
`Q. So 2.45, you believe, is a number that you typed into ZEMAX sometime back in
`April or May of 2020, when you were doing the original work for the original
`declaration?
`A. As I recall right now, yes.
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`SR at 13–15
`
`No motivation provided for modifying
`Ogino Example 5 to have an F# of 2.12
`
`IPR2020-00878 | SLIDE 54
`
`
`
`core ' photonics
`
`Ground 4
`Ground 4
`
`IPR2020-00878 | SLIDE55
`
`
`
`Dependent Claims 16 and 30 – F# 2.9 and L11/L1e < 3
`
`Ex. 1001, 8:37–10:37
`
`IPR2020-00878 | SLIDE 56
`
`
`
`Setting Chen’s Unspecified Object-Side Lens Diameter
`
`1.2375 mm = Semi-Diameter First Lens Object-Side Surface
`
`1.2333 mm = Semi-Diameter of Aperture Stop
`
`Difference = 0.0042 mm
`
`POR at 64, 66; Ex. 1003 at 115; Ex. 2001, ¶ 142
`
`IPR2020-00878 | SLIDE 57
`
`
`
`Setting Chen’s Unspecified Object-Side Lens Diameter
`“As this shows, the bundle, and thus the entrance pupil,
`extends all the way across the left surface of the lens. Apple
`has not proposed making the lens smaller, but if it had, the
`lens cannot be made smaller without reducing the entrance
`pupil diameter and increasing the f-number.
`
`“Likewise, Apple has not proposed making the lens larger.
`But, if it had, the largest that the lens semi-diameter could be
`without increasing the center-to-edge thickness ratio above 3
`would be less than 1.249 mm, approximately 0.012 mm larger
`(less than 1% larger) than Dr. Sasián proposes.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 65–66; Ex. 2001, ¶¶ 144–145
`
`IPR2020-00878 | SLIDE 58
`
`
`
`Apple’s Ground 4 Obviousness Theory Rests on
`Beich and on Using Injection Molded Plastic
`“Since Example 1 would preferably have been
`manufactured via injection molding, as discussed
`above, and to the extent that Chen does not provide
`manufacturing parameters, a POSITA would have
`looked to polymer injection molding references such as
`Beich, which ‘discuss[es] the polymer optics
`manufacturing process and examine[s] the best
`practices to use when working with a polymer optics
`manufacturer.’”
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`POR at 6; Ex. 1003, ¶ 81
`
`IPR2020-00878 | SLIDE 59
`
`
`
`Ground 4 – Limits of Manufacturing Precision
`Beich Manufacturing Tolerances:
`
`Difference in diameter between first lens
`and aperture stop is only 0.008 mm.
`
`POR at 66–67; Ex. 1007 at 7
`
`IPR2020-00878 | SLIDE 60
`
`
`
`Ground 4 – Theory Requires Unachievable Manufacturing Precision
`“As noted above, the semi-diameter of the first lens is only 0.004 mm
`larger than the stop. If the lens is too small by 0.020 mm in diameter
`(0.010 mm in semi-diameter), this will make the semi-diameter of the
`first lens smaller than the semi-diameter of the stop by 6 μm [0.006
`mm]. This is even without taking into account other sources of
`variation in the diameter of the stop and the alignment of the
`components. A first lens smaller than the stop will mean that light will
`leak and scatter around the lens and cause a haze in the image
`that is highly undesirable. For this reason alone, a POSITA would make
`the first lens from Chen larger in diameter than Dr. Sasián proposes,
`something that Dr. Sasián does not consider.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 66–67; Ex. 2001, ¶ 147
`
`IPR2020-00878 | SLIDE 61
`
`
`
`Ground 4 – Theory Requires Unachievable Manufacturing Precision
`“But even if Dr. Sasián had proposed increasing the size of the
`lens to be as large as possible while keeping the thickness
`ratio under 3, the largest possible semidiameter (under 1.249
`mm) would be less than 0.016 mm larger than the stop. A
`POSITA would recognize that this is unacceptable, given the
`multiple sources of manufacturing variation of the order of
`0.010 mm in semidiameter and adding under the root sum
`square rule. (Ex. 2004, Sasián at 116–117.)”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 67; Ex. 2001, ¶ 148
`
`IPR2020-00878 | SLIDE 62
`
`
`
`Ground 4 – Theory Requires Unachievable Manufacturing Precision
`“The lens is unacceptable even without taking into
`account the need to oversize ‘considerably beyond the
`clear apertures’ (Ex. 1019, Handbook of Optics, Vol. 2 at
`34.16.) or by around 4–10% (Ex. 2006, Symmons at
`103), or the need for room for rounded corners,
`discussed in connection with ground 2.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 67; Ex. 2001, ¶ 149
`
`IPR2020-00878 | SLIDE 63
`
`
`
`Ground 4 – Theory Requires Unachievable Manufacturing Precision
`“[A] POSITA would recognize that the combination of
`Chen, Iwasaki, and Beich proposed by Dr. Sasián would
`not be a practical lens, based on the very
`manufacturing rules of thumb in Beich, among other
`reasons. Even if a POSITA was motivated to make a lens
`with center-to-edge thickness ratio less than 3, that
`POSITA would not have been motivated to make the
`Chen Example 1 lens with that ratio, as proposed by Dr.
`Sasián.”
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`POR at 68; Ex. 2001, ¶ 151
`
`IPR2020-00878 | SLIDE 64
`
`
`
`Apple’s Response: Manufacturing Considerations Do Not Matter
`
`But manufacturing considerations are the entire
`justification for combining Chen and Iwasaki with Beich
`
`SR 18-20; Reply at 28
`
`IPR2020-00878 | SLIDE 65
`
`
`
`Apple’s Argument That ’897 Patent Examples Are Unmanufacturable
`Ignores Its Disclosures and Rests on Faulty Calculations
`Q. So the numbers in the patent are a little different than the
`numbers that you calculated. In particular, for Example Number
`2, according to paragraph 40 of your declaration, you
`calculated an L11/L1e ratio of 3.049, whereas the patent says
`that ratio is 2.916; would you agree?
`. . .
`A. Okay. Thank you. Yeah, I see there is a difference.
`
`Dr. Jose Sasian
`Petitioner’s Expert
`SR at 24–25;
`Ex. 2012, 88:13–89:15
`
`Q. Prior to the last few minutes, were you aware of this
`difference between the numbers that you gave for the ratio in
`your declaration and the number given for the ratio in the
`patent itself?
`A. No, I wasn't aware of the difference.
`
`IPR2020-00878 | SLIDE 66
`
`
`
`Apple’s Argument That ’897 Patent Examples Are Unmanufacturable
`Ignores Its Disclosures and Rests on Faulty Calculations
`Q. So would one explanation for the difference be that the calculation of
`L11/L1e that resulted in the values in Column 2 of the patent used
`diameters that weren’t exactly the values shown in the tables but simply
`round to be the values in the table?
`A. Well, rounding could be the answer. Yes, it could be a rounding issue.
`Q. So to speak concretely about Example 2 from the patent, in Table 3,
`the first and second surfaces of the first lens are listed as having a
`diameter of 2.6, but if the -- and that's what you used to calculate the
`ratio in your declaration. But if the lens diameter were a little bit less
`than 2.6 but greater than 2.55, somewhere in there, you might get the
`centered-edge-thickness ratio that's reported in Column 2 of the patent?
`A. Yeah, that would be the case.
`
`Dr. Jose Sasian
`Petitioner’s Expert
`SR at 26–27;
`Ex. 2012, 90:17–91:14
`
`IPR2020-00878 | SLIDE 67
`
`
`
`’897 Patent Examples Are Manufacturable
`
`SR at 23; Ex. 1001, 2:43–50
`
`IPR2020-00878 | SLIDE 68
`
`
`
`’897 Patent Examples Are Manufacturable
`
`SR at 26, 28–29; Ex. 1001, 6:5–24
`
`’897 Patent Example 2
`first lens semi-diameter
`is 0.050 mm greater
`than stop semi-
`diameter.
`
`Ground 4 combination
`first lens semi-diameter
`is only 0.004 mm
`greater than stop semi-
`diameter.
`
`Beich semi-diameter
`tolerance is ±0.010 mm.
`
`IPR2020-00878 | SLIDE 69
`
`
`
`core ' photonics
`
`Thank You
`Thank You
`
`IPR2020-00878 | SLIDE70
`
`
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