`
`
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`COREPHOTONICS, LTD.,
`Patent Owner.
`____________
`
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`____________
`
`
`PATENT OWNER’S RESPONSE
`
`
`
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`TABLE OF CONTENTS
`
`INTRODUCTION .................................................................. 1
`I.
`II. OVERVIEW OF THE ‘647 PATENT ....................................... 1
`A. Multiple Element Lens Design ........................................................ 7
`III. LEVEL OF ORDINARY SKILL ........................................... 11
`IV. CLAIM CONSTRUCTION ................................................... 11
`OVERVIEW OF THE ASSERTED PRIOR ART .................... 12
`V.
`A. Ogino (Ex. 1005) ........................................................................... 12
`B.
`Chen II (Ex. 1008) ......................................................................... 17
`Bareau (Ex. 1012) ......................................................................... 21
`C.
`D. Kingslake (Ex. 1013) .................................................................... 23
`E.
`Hsieh (Ex. 1025) ........................................................................... 24
`F.
`Beich (Ex. 1007) ........................................................................... 26
`VI. PATENTABILITY OF CHALLENGED CLAIMS .................. 28
`A. GROUND 2 - The Petition Fails to Demonstrate that Ogino in
`view of Chen II renders claims 1 and 4 unpatentable. .................. 28
`1.
`Claim 1 and 4 ........................................................................... 28
`2.
`Dependent claims 2-6. .............................................................. 51
`unpatentable. ................................................................................. 51
`
`GROUND 3 - The Petition Fails to Demonstrate that Ogino in
`view of Chen II and Bareau renders claims 2, 3, 5 and 8-11
`
`B.
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`1.
`2.
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`A POSITA would not have modified Ogino in view of Chen II
`
`A POSITA would not have modified Ogino in view of Chen II
`
`and Bareau to render claims 2, 3 and 5 unpatentable. .............. 52
`and Bareau to render claims 8-11 unpatentable. ...................... 58
`C.
`unpatentable. ................................................................................. 63
`D. GROUND 5 - The Petition Fails to Demonstrate that Hsieh in view
`of Beich renders claim 7 unpatentable. ......................................... 70
`E.
`of Iwasaki and Beich renders claim 12 unpatentable. ................... 73
`VII. PETITIONER FAILS TO MEET ITS BURDEN FOR
`CHALLENGED CLAIM ....................................................... 74
`VIII. CONCLUSION .................................................................... 75
`
`GROUND 4 - The Petition Fails to Demonstrate that Ogino in
`view of Chen II, Bareau and Kingslake renders claim 6
`
`GROUND 6 - The Petition Fails to Demonstrate that Chen in view
`
`
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`Case No. IPR2020-00896
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`Cases
`
`TABLE OF AUTHORITIES
`
`In re Magnum Oil Tools Int’l, Ltd.,
`829 F.3d 1364 (Fed. Cir. 2016) ................................................................ 73
`
`Wasica Finance GMBH v. Continental Auto. Systems,
`853 F.3d 1272 (Fed. Cir. 2017) ................................................................ 74
`
`
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`iii
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`PATENT OWNER’S EXHIBIT LIST
`
`Description
`Declaration of Tom D. Milster, Ph.D.
`Curriculum Vitae of Tom D. Milster, Ph.D.
`Deposition transcript of José Sasián, February 19, 2021
`José Sasián, Introduction to Lens Design (2019)
`Declaration of José Sasián in IPR2020-00897
`McGuire Jr, J. P., & Kuper, T. G. (2012, October). Approaching di-
`rect optimization of as-built lens performance. In Novel Optical Sys-
`tems Design and Optimization XV (Vol. 8487, p. 84870D).
`International Society for Optics and Photonics
`Sturlesi, D., & O'Shea, D. C. (1991). Global view of optical design
`space. Optical engineering, 30(2), 207-218
`Symmons and Schaub, Field Guide to Molded Optics (2016)
`Declaration of Tom Milster in IPR2020-00878
`
`Exhibit No
`2001
`2002
`2003
`2004
`2005
`2006
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`2007
`
`2008
`2009
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`
`
`i
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`I.
`
`INTRODUCTION
`
`Petitioner fails to demonstrate that any claim of the ‘647 patent is un-
`
`patentable. Petitioner proposes optical lens assemblies that were designed in
`
`a manner that a person of ordinary skill in the art (“POSITA”) would never
`
`have accepted or tried to implement. The manner in which Petitioner proposes
`
`to design these lens assemblies is artificial and ignores standard practices that
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`would have been used by a POSITA. Instead, improper hindsight is used to
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`achieve the claimed invention, regardless of the results. Many of these pro-
`
`posed designs would not work because the lenses are overlapping or touching.
`
`As the Board has found in a prior IPR proceeding between these two parties,
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`these types of lens configurations are not enabled. Finally, in some instances
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`the prior art teaches away from the proposed combination, such that a POSITA
`
`would not have designed the optical lens assembly proposed by Petitioner.
`
`Accordingly, the Board should find challenged claims 4 and 6-12 not
`
`unpatentable.
`
`II. OVERVIEW OF THE ‘647 PATENT1
`
`The ‘647 patent is concerned with designs for a “miniature telephoto
`
`lens assembly” of a kind suitable for use in mobile phones and other portable
`
`
`1 See generally Ex. 2001, Milster Decl. ¶¶39-54.
`
`1
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`U.S. Patent No. 10,317,647
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`electronic products. Ex. 1001, ‘647 patent, 1:26–30. The example designs
`
`shown in the ‘647 patent utilize five plastic lens elements, each having a com-
`Case Nos. IPR2020-00878
`U.S. Patent No. 10,330,897
`plex aspheric shape:
`
`
`37. The use of these multiple lens elements with aspheric shapes makes
`The use of these multiple lens elements with aspheric shapes makes
`
`
`
`possible a lens that produces a high-quality image, by minimizing chromatic
`possible a lens that produces a high-quality image, by minimizing chromatic
`
`aberrations and other optical aberrations that would blur or distort the image.
`aberrations and other optical aberrations that would blur or distort the image.
`
`(Ex. 1001, ’897 patent at 2:22–34, 2:51–57.)
`Ex. 1001, ‘647 patent, 2:22–34, 2:51–57.
`
`38. These multi-lens systems with aspheric lens surfaces have a vast range
`These multi-lens systems with aspheric lens surfaces have a vast range
`
`of possible designs. For example, the design in figure 1A from the ’897 patent
`of possible designs. For example, the design in Figure 1A from the ‘647 patent
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`requires several dozen numerical parameters to define the shapes, locations,
`
`and properties of its lens elements:
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`2
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`
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`requires several dozen numerical parameters to define the shapes, locations,
`Case Nos. IPR2020-00878
`and properties of its lens elements:
`U.S. Patent No. 10,330,897
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`
`
`
`
`
`
`(Ex. 1001, ’897 patent, col. 4.)
`Ex. 1001, ‘647 patent, col. 4.
`39. The ’897 patent provides examples of lens designs and their corre-
`The ‘647 patent provides examples of lens designs and their corre-
`sponding numerical parameters, and it also teaches and claims sets of condi-
`sponding numerical parameters, and it also teaches and claims sets of condi-
`tions and relationships among the parameters that help to make a lens system
`tions and relationships among the parameters that help to make a lens system
`with high performance characteristics. The resulting lens designs are thin and
`
`3
`
`18
`
`Exhibit 2001
`IPR2020-00878
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`
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`with high performance characteristics. The resulting lens designs are thin and
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`compact, appropriate for use in mobile devices, and they offer a large focal
`
`length (and thus a large degree of image magnification) for their physical size.
`
`Ex. 1001, ‘647 patent, 2:6–21.
`
`The lens designs in the ‘647 patent are also manufacturable, meaning
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`that they have shapes that can be successfully and repeatably manufactured
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`using the techniques of plastic injection molding that are commonly used for
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`mobile device camera lenses. The ‘647 patent designs avoid features such as
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`overly narrow lens edges that make a lens difficult or impossible to manufac-
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`ture. Ex. 1001, ‘647 patent, 2:35–50.
`
`One of the parameters of a lens design that is discussed in the ‘647 pa-
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`tent and claimed in certain claims is the “f-number” or “F#.” The f-number is
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`a property of a lens that relates to how bright the image formed by the lens is.
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`A lens that forms brighter images is sometimes referred to as a “faster” lens,
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`because for a given image sensor (or a given type of film) and focal length,
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`the minimum amount of time required to capture an image varies inversely
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`with the brightness of the image. For a single thin lens, the f number is equal
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`to the focal length of the lens divided by the diameter of the lens:
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`4
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`
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`the minimum amount of time required to capture an image varies inversely
`
`with the brightness of the image. For a single thin lens, the f number is equal
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`to the focal length of the lens divided by the diameter of the lens:
`
`!−#$%&'(=
`
`!
`+,-%'.'(
`
`Ex. 1016, Walker, p. 59.
`
`
`
`
`
`19
`The diameter of the lens determines how much total light is collected
`Exhibit 2001
`IPR2020-00878
`per unit time by the lens from a given scene. Under certain approximations,
`Page 22 of 82
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`doubling the diameter increases the amount of light collected by a factor of
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`four. The focal length determines the image size on the sensor and thus deter-
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`mines the size of the distribution area of the collected light. Doubling the focal
`
`length increases the area illuminated in the image by a factor of four and re-
`
`duces the intensity of the light in any given part of the image by a factor of
`
`four. So, if both the diameter and focal length are doubled, then the effects
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`approximately cancel out, and the brightness of the image at the sensor is left
`
`unchanged, although the image is larger. In other words, it is the ratio of the
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`focal length and the diameter that most strongly effects the image brightness.
`
`Because the diameter is in the denominator, a smaller f-number corre-
`
`sponds to a brighter image for a fixed focal length. In more complicated lens
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`systems with multiple lens elements, such as those at issue in this IPR, the
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`amount of light collected no longer depends on the diameter of a single lens
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`(or of a single lens surface), and the effective focal length (EFL) is a function
`Case Nos. IPR2020-00878
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`U.S. Patent No. 10,330,897
`of the lens elements and their spacings. One definition of f number for such
`U.S. Patent No. 10,330,897
`systems instead uses the diameter of the “entrance pupil” (EPD), meaning that
`systems instead uses the diameter of the “entrance pupil” (EPD), meaning that
`systems instead uses the diameter of the “entrance pupil” (EPD), meaning that
`the formula is changed to:
`the formula is changed to:
`the formula is changed to:
`
`
`
`
`
`
`(Ex. 1003, Sasián Decl. at 58–39.)
`Ex. 1003, ¶78.
`(Ex. 1003, Sasián Decl. at 58–39.)
`44. The concept of the “entrance pupil” is illustrated in the following draw-
`The concept of the “entrance pupil” is illustrated in the following draw-
`44. The concept of the “entrance pupil” is illustrated in the following draw-
`ing from Figure 4-2 of Walker:
`ing from Figure 4-2 of Walker:
`ing from Figure 4-2 of Walker:
`
`
`
`
`
`
`
`(Ex. 1016, Walker, p. 61.)
`(Ex. 1016, Walker, p. 61.)
`Ex. 1016, Walker, p. 61.
`45. As shown here, the entrance pupil reflects the size of the bundle of rays
`45. As shown here, the entrance pupil reflects the size of the bundle of rays
`parallel to the optical axis of the lens that can enter the lens, travel through the
`parallel to the optical axis of the lens that can enter the lens, travel through the
`aperture stop, and reach the image plane. Explained another way, the entrance
`aperture stop, and reach the image plane. Explained another way, the entrance
`6
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`As shown here, the entrance pupil reflects the size of the bundle of rays
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`parallel to the optical axis of the lens that can enter the lens, travel through the
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`aperture stop, and reach the image plane. Explained another way, the entrance
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`pupil “is the image of the aperture stop as seen when looking from the object
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`side of the lens.” Ex. 1016, Walker, p. 60.
`
`A. Multiple Element Lens Design
`
`The design parameters of a lens assembly include, among others: 1) the
`
`properties of lens materials (index of refraction, as well as the Abbe number,
`
`which describes the dispersion of refraction in the lens); 2) shapes of the op-
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`tical surfaces of the lenses; 3) thicknesses of each of the lenses; 4) distances
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`between each of the lens elements as well as the face of the image sensor; 5)
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`the precise contours of the front (object-facing) and back (image-facing) sur-
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`faces of the lenses; 6) the aperture stop size and location.
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`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
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`spherical aberrations, astigmatism, and other problems with image quality,
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`lens assemblies employ “aspheric” lens shapes, which are more complex than
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`ordinary spherical lenses. The “aspheric coefficients” are parameters of a
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`mathematical equation that defines a curve in space. The curve defined by that
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`equation defines the curvature of the lens. The equation that defines the cur-
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`vature of lenses is provided in the ‘647 patent at col. 4, line 5 as follows:
`
`
`42.
`
`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
`In the above equation, r is distance from (and perpendicular to) the op-
`the (cid:302)(cid:182)s are aspheric coefficients. Each surface (front and back) of each lens is defined
`tical axis, k is the conic coefficient, c=1/R where R is the radius of curvature,
`by a combination of numbers for each of the above parameters. Calculating the
`and the α’s are aspheric coefficients. Each surface (front and back) of each
`above equation will generate a curve that defines the surface. The sum total of all of
`lens is defined by a combination of numbers for each of the above parameters.
`the parameters of a lens system, including the gaps between lenses, the curvature
`Calculating the above equation will generate a curve that defines the surface.
`parameters, indices of refraction, and Abbe numbers, all together are sometimes
`The sum total of all of the parameters of a lens system, including the gaps
`called a (cid:179)le(cid:81)(cid:86) (cid:83)(cid:85)e(cid:86)c(cid:85)i(cid:83)(cid:87)i(cid:82)(cid:81).(cid:180) See, e.g., Ex. 1006, 62-63. The pathway of light through
`between lenses, the curvature parameters, indices of refraction, and Abbe
`the lenses is defined by the incidence of rays on the surface of each lens, and then
`numbers, all together are sometimes called a “lens prescription.” See, e.g., Ex.
`how the material properties of the lenses bends the rays that pass through them.
`
`1006, 62-63. The pathway of light through the lenses is defined by the inci-
`These are shown mathematically, for example, in the ray-trace plots below for
`
`various lens system designs.
`dence of rays on the surface of each lens, and then how the material properties
`43. The emb(cid:82)dime(cid:81)(cid:87)(cid:86) i(cid:81) (cid:87)he (cid:182)032 a(cid:81)d (cid:182)712 (cid:83)a(cid:87)e(cid:81)(cid:87)(cid:86) describe an arrangement
`of the lenses bends the rays that pass through them. These are shown mathe-
`of at least five aspheric lens elements. As a result, there are at least the following
`matically, for example, in the ray-trace plots below for various lens system
`parameters that can be varied: the gaps between the five lenses, the sensor, the stop,
`designs.
`and window covering the sensor, and thicknesses of these elements (13 parameters
`Apple v. Corephotonics
`Exhibit 2013
`IPR2018-01146
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`Exhibit 2013 Page 21 of 113
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`The embodiments in the ‘647 patent describe an arrangement of at least
`
`five aspheric lens elements. As a result, there are at least the following param-
`
`eters that can be varied: the gaps between the five lenses, the sensor, the stop,
`
`and window covering the sensor, and thicknesses of these elements (13 pa-
`
`rameters as shown in the tables describing embodiments of the ’647 patent);
`
`the aspheric coefficients and a conic coefficient, k, and radius of curvature, r,
`
`for each lens (7 parameters per lens surface or 70 total), and Abbe numbers
`
`and refractive indices for each lens (or 10 total for 5 lenses). Therefore, there
`
`are 93 parameters that can be independently varied. This leads to a nearly in-
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`finite variety of possible lens designs. For example, considering just ten pos-
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`sible values for each of these parameters would require evaluating 1093
`
`combinations of parameter values. This is greater than the number of elemen-
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`tary particles in the observable universe,2 and vastly more designs than could
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`ever be feasibly evaluated.
`
`Moreover, the interrelationships between these parameters creates in-
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`creased complexity. Although a computer program can predict what will hap-
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`pen when rays of light go through a lens system, when just looking at the
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`
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`2 https://en.wikipedia.org/wiki/Elementary_particle
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`parameters without running a simulation, the relationship between the varia-
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`bles can be nonlinear and unpredictable. The result is a huge design space for
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`a lens designer to explore. And, while computer simulation and optimization
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`techniques can help in aspects of the process, ultimately a significant degree
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`of manual and hand-driven modification is required to arrive at an acceptable
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`design. Also, computational optimization techniques may get trapped in local
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`minima because of the highly multidimensional space. See, e.g., Ex. 2004, pp.
`
`167-70. So, it will be impossible to have it actually converge on an optimal
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`design. This is equivalent to looking up in a valley surrounded by mountains.
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`The designer may not know whether there is valley at a lower altitude on the
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`side of one of the mountains. A POSITA would understand that purely com-
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`puter-aided design may be appropriate for doublets or triplets (2- or 3- lens
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`systems), but once there are more than three lenses, systems become too com-
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`plex. See, e.g., Ex. 2004, p. 173.
`
`A POSITA would also understand that there are also a lot of factors that
`
`go beyond even the performance of image parameters that would need to be
`
`optimized. These include tolerance sensitivity, packaging, viability of materi-
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`als, number of elements, and others. This makes the design problem even
`
`harder. Ex. 2004, p. 171.
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`III. LEVEL OF ORDINARY SKILL
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`Petitioner offers that a “person having ordinary skill in the art
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`(“POSITA”) would include someone who had, at the priority date of the ’647
`
`Patent, (i) a Bachelor’s degree in Physics, Optical Sciences, or equivalent
`
`training, as well as (ii) approximately three years of experience in designing
`
`multi-lens optical systems.” Pet. at 7. Further, “[s]uch a person would have
`
`had experience in analyzing, tolerancing, adjusting, and optimizing multi-lens
`
`systems for manufacturing, and would have been familiar with the specifica-
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`tions of lens systems and their fabrication.” Id. Petitioner also submits that “a
`
`POSITA would have known how to use lens design software such as Codev,
`
`Oslo, or Zemax, and would have taken a lens design course or had equivalent
`
`training.” Id. Patent Owner does not disagree with Dr. Durand’s definition of
`
`a POSITA. Ex. 2001, Milster Decl., ¶20.
`
`IV. CLAIM CONSTRUCTION
`
`Petitioner notes that two terms, “Effective Focal Length (EFL)” and
`
`“Total Track Length (TTL),” have previously been construed in relation to
`
`other patents that share a common specification with the ‘647 Patent. Pet. at
`
`8. Specifically, the Board construed these two terms in IPR2018-01140 as fol-
`
`lows:
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`• Effective Focal Length (EFL): “the focal length of a lens assembly.”
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`• Total Track Length (TTL): “the length of the optical axis spacing be-
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`tween the object-side surface of the first lens element and one of: an
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`electronic sensor, a film sensor, and an image plane corresponding to
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`either the electronic sensor or a film sensor.”
`
`Patent Owner does not dispute these constructions. For all other terms,
`
`Patent Owner agrees with Petitioner that their plain and ordinary meaning, as
`
`they would have been understood by a POSITA, as of the effective filing date,
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`in the context of the ‘647 patent, should be used. Pet. at 8; Ex. 2001, Milster
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`Decl., ¶59.
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`V. OVERVIEW OF THE ASSERTED PRIOR ART3
`
`A. Ogino (Ex. 1005)
`
`Ogino issued on September 8, 2015 as U.S. Patent No. 9,128,267 Ex.
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`1005. Petitioner contends that Ogino has an effective filing date of March 29,
`
`2013, based upon the filing date of the corresponding Japanese patent appli-
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`cation. Petition at 10.
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`As described in Ogino’s abstract, its invention is a system of five lenses
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`with a particular set of shapes:
`
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`3 See generally Ex. 2001, Milster Decl., ¶¶60-86.
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`An imaging lens substantially consists of, in order from an ob-
`ject side, five lenses of a first lens that has a positive refractive
`power and has a meniscus shape which is convex toward the
`object side, a second lens that has a biconcave shape, a third
`lens that has a meniscus shape which is convex toward the ob-
`ject side, a fourth lens that has a meniscus shape which is con-
`vex toward the image side; and a fifth lens that has a negative
`refractive power and has at least one inflection point on an im-
`age side surface. Further, the following conditional expression
`(1) is satisfied.
`
`1.4<f/f1<4 (1)
`
`Ex. 1005, Ogino, Abstract.
`
`This same set of shapes and conditions is described as the “imaging lens
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`of the present invention” in Ogino’s “Summary of the Invention” section. Ex.
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`1005, Ogino, 2:1–16.
`
`As shown in the embodiments, by making the first lens L1,
`which is a lens closest to the object, have a positive refractive
`power and have a meniscus shape which is convex toward the
`object side in the vicinity of the optical axis, the position of the
`rear side principal point of the first lens L1 can be set to be
`close to the object, and thus it is possible to appropriately re-
`duce the total length.
`
`Ex. 1005, Ogino, 7:31–37.
`
`Petitioner’s grounds utilizing Ogino are all based on Ogino’s “Example
`
`5” or modifications to that example. Ex. 1003, Sasián Decl., ¶¶ 48-50, 61; Ex.
`
`2003, February 19, 2021, Sasián Dep. Tr. at 20:1-5; 21:12-21; 22:19-23:5. The
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`lens elements of Example 5 are shown in Ogino, Figure 5:
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`13
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`
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`or modifications to that example. (Ex. 1003, Sasián Decl., ¶¶ 46, 51, 61.) The
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`lens elements of Example 5 are shown in Ogino, Figure 5:
`U.S. Patent No. 10,317,647
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`Ex. 1005, Ogino, Figure 5.
`(Ex. 1005, Ogino, Figure 5.)
`Figure 12 of Ogino provides certain optical characteristics of Example
`55. Figure 12 of Ogino provides certain optical characteristics of Example
`
`5, including its f-number of 3.94 and half-angle of view ω=25.9°:
`5, including its f-number of 3.94 and half-angle of view ω=25.9°:
`
`
`
`
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`25
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`14
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`Exhibit 2001
`IPR2020-00878
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`Ex. 1005, Ogino, Figure 12.
`56. The lens prescription for Example 5 is given in Ogino Tables 9 and 10:
`The lens prescription for Example 5 is given in Ogino Tables 9 and 10:
`
`
`
`15
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`26
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`Exhibit 2001
`IPR2020-00878
`Page 29 of 82
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`
`
`Case No. IPR2020-00896
`Case Nos. IPR2020-00878
`U.S. Patent No. 10,317,647
`U.S. Patent No. 10,330,897
`
`Case Nos. IPR2020-00878
`U.S. Patent No. 10,330,897
`
`
`
`
`
`(Ex. 1005, Ogino, column 21.)
`
`27
`
`
`
`
`
`Exhibit 2001
`IPR2020-00878
`Page 30 of 82
`
`B.
`
`Bareau
`
`16
`57. Bareau is an article by Jane Bareau and Peter P. Clark, titled “The Op-
`
`tics of Miniature Digital Camera Modules.” (Ex. 1012.) Dr. Sasián states that
`
`
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`Ex. 1005, Ogino, column 21.
`
`B.
`
`Chen II (Ex. 1008)
`
`Chen II issued on July 31, 2012 as U.S. Patent No. 8,233,224 (Ex.
`
`1008.) As described in Chen II’s abstract, its invention is a system of five
`
`lenses with a particular set of shapes:
`
`This invention provides an imaging lens system including, in
`order from an object side to an image side: a first lens with pos-
`itive refractive power having a convex object-side surface; a
`second lens with negative refractive power; a third lens having
`a concave image-side surface; a fourth lens with positive refrac-
`tive power; a fifth lens with negative refractive power having a
`concave image-side surface, at least one surface thereof having
`at least one inflection point; and an aperture stop disposed be-
`tween an imaged object and the third lens. The on-axis spacing
`between the first lens and second lens is T12, the focal length of
`the imaging lens system is f, and they satisfy the relation:
`
`0.5<(T12/f) x 100<15.
`
`Apple’s grounds utilizing Chen II are all based on Chen II’s “Example
`
`1” or modifications to that example. Ex. 1003, Sasián Decl., ¶¶52; Ex. 2003,
`
`Sasián Dep. Tr., 20:6-13; 22:5-13; 23:7-25 The lens elements of Example 1
`
`are shown in Chen II, Figure 1:
`
`17
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`U.S. Patent
`Jul. 31, 2012
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`Sheet 1 of 13
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`US 8,233,224 B2
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`111-122-1 / 132
`112-131-1 141
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`Fig. 1
`
`
`
`Ex. 1008, Chen II, Figure 1.
`
`Figure 7 of Chen II provides certain optical characteristics of Example
`APPL-1008 / Page 2 of 21
`APPLE INC. v. COREPHOTONICS LTD.
`5, including its focal length is 5.44 mm, an f-number of 2.9 and half-angle of
`
`18
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`
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`U.S. Patent
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`Jul. 31, 2012
`
`Sheet 7 of 13
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`US 8,233,224 B2
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`view ω=33.0°. Figures 7 and 8 also provides the lens prescription table for
`
`Example 1 of Chen II:
`
`TABLE 1
`(Embodiment 1)
`f = 5.44 mm, Fno - 2.9, HFOV = 33.0 deg.
`Curvature Radius Thickness Material
`Index
`Plano
`Infinity
`Plano
`-0.295
`1.54469 (ASP)
`0.544
`5.13230 (ASP)
`0.070
`285.35120 (ASP)
`O.300
`5.07630 (ASP)
`O408
`2.37564 (ASP)
`0.277
`2.18085 (ASP)
`O.86
`-1.60878 (ASP)
`0.492
`-1.26807 (ASP)
`0.100
`3.00470 (ASP)
`0.644
`1.73617 (ASP)
`OOO
`Plano
`O.300
`Plano
`0.975
`Plano
`
`Plastic
`
`1544
`
`Plastic
`
`1.544
`
`Glass
`
`1517
`
`Plastic
`
`544
`
`Plastic
`
`1.632
`
`Plastic
`
`544
`
`Surface #
`O
`1
`2
`3
`4.
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`
`Object
`Ape. Stop
`Lens 1
`
`Lens 2
`
`Lens 3
`
`Lens4
`
`LenSS
`
`IR-filter
`
`Image
`
`Abbe it
`
`h
`
`55.9
`
`23.4
`
`3.85
`
`-8.18
`
`55.9
`
`-97.98
`
`7.29
`
`-9.2
`
`55.9
`
`55.9
`
`64.2
`
`Fig.7
`
`
`
`Ex. 1008, Chen II, Figure 7.
`
`APPL-1008 / Page 8 of 21
`APPLE INC. v. COREPHOTONICS LTD.
`19
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
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`TABLE 2
`Aspheric Coefficients
`6
`5
`2
`3
`4.
`2.14772E-01 - 1.00000E-00 3.631.16E--04 8.10223E-00 - 1.00000E--00
`-1.31489E-02 -8.93237E-02 - 1.04367E-02 5. 70855E-02
`-10 1292E-01
`-147658E-02 2.0551 E-02 9.85 187E-02
`143963E-Ol
`-2.43027E-02
`-5.67815E-03 3.53580E-02
`-3.99988E-02 - 14282E-01
`8.3545 E-03
`2.5 1805E-03
`1.01 047E-01
`- 19594OE-03
`-383556E-O2 2.3340OE-02
`-8.61299E-03
`-2.21901 E-02
`180 139E-03
`-7.42997E-04
`
`10
`9
`8
`7
`
`-OOOOOE-00-100.000E-00-100000E-00-187192E-01 -9.57921 E-00
`-4.40404E-02.
`-3.40218E-02
`-7.4961 1 E-02 6.76904E-02 7.92341 E-02
`-2.73159E-02 -2.41658E-02 -2.37275E-02 5,54721E-03
`9.60671 E-03
`-3.22066E-04
`-2.0233E-03
`38402E-O2
`-5.78439E-03 5.08 192E-03
`-152799E-05
`2.30078E-04
`-6.47005E-03 8.16669E-03
`1.03756E-03
`-9.93068E-06
`-3.48727E-03 -4.41 16OE-04
`-2.91448E-07
`
`Surface #
`k =
`A4 =
`A6 =
`A8 =
`A 10=
`A12==
`A 14=
`A 16
`Surface it
`k
`A4 F
`A6 =
`A8 =
`A10s
`Al2=
`Al4 =
`
`R
`
`Fig.8
`
`
`
`Ex. 1008, Chen II, Figure 8.
`
`
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`APPL-1008 / Page 9 of 21
`APPLE INC. v. COREPHOTONICS LTD.
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`20
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`
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`C. Bareau (Ex. 1012)
`
`Bareau is an article by Jane Bareau and Peter P. Clark, titled “The Op-
`
`tics of Miniature Digital Camera Modules.” Ex. 1012. Dr. Sasián states that
`
`this was presented at an International Optical Design Conference in June 2006
`
`and that it was published in SPIE Proceedings Vol. 6342 “a few months after
`
`the conference.” Ex. 1003, Sasián Decl., ¶70.
`
`Apple does not rely on any detailed lens design from Bareau or any
`
`teachings of how a lens designer would create a detailed lens design. Rather,
`
`Apple and Dr. Sasián rely on Bareau listing an f-number of 2.8 in its “typical
`
`lens specifications for a 1⁄4′′ sensor format.” Ex. 1003, Sasián Decl., ¶¶71–
`
`73; Ex. 1012, Bareau at 3–4.
`
`Other parts of Bareau illustrate an important point relevant to this IPR:
`
`the fact that you can simulate a lens design in lens design software such as
`
`Zemax does not mean that you can build that design. As Bareau explains:
`
`Layout drawings can be very misleading. Many times we find
`ourselves surprised when the mechanical layout of a lens barrel
`that looked reasonable on paper turns out to be very difficult or
`impossible to fabricate. Tabs on a barrel that appear substantial
`in a drawing, are found to be too flimsy to function on the ac-
`tual part, sharp edges on molded stops don’t fill completely be-
`cause the features are too small.
`
`Ex. 1012, Bareau at 1.
`
`21
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`Bareau explains aspects of the shape and size of lens elements, be they
`
`made out of plastic or glass, that are particularly problematic when producing
`
`miniature lenses like those at issue in this IPR:
`
`Scaling down such a lens will result in a system that is unmanu-
`facturable. If the design includes molded plastic optics, a scaled
`down system will result in element edge thicknesses shrinking
`to the point where the flow of plastic is affected. For glass ele-
`ments, the edge thicknesses will become too thin to be fabri-
`cated without chipping.
`
`Ex. 1012, Bareau at 1.
`
`Bareau explains that the issue of “geometric tolerances, including both
`
`in the size and shape of individual lens elements and their alignment within
`
`the overall system, “proves to be the greatest challenge of producing these
`
`lenses.” Ex. 1012, Bareau at 3.
`
`Bareau explains that there are limits to achievable shapes in miniature
`
`lens. For molded lenses, these limits arise from the properties of the lens ma-
`
`terial, both in liquid form and in solid form, and from the techniques used to
`
`make the mold inserts that the lens parts are formed in. According to Bareau:
`
`Plastic injection molded optics have minimum edge thick-
`nesses, minimum center thicknesses and range of acceptability
`for their center to edge thickness ratio that must be met in order
`that they can be molded. Additionally, the maximum slope that
`can be diamond-turned in mold inserts and measured in either
`the lens or the mold is around 45 degrees.
`
`22
`
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`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`Ex. 1012, Bareau at 8.
`
`As Bareau explains, similar limitations apply to glass lens elements:
`
`“Traditional glass lenses have similar types of requirements but with different
`
`values.” Ex. 1012, Bareau at 8. In molded glass lenses, “surfaces with in- flec-
`
`tions can only be used under very limited circumstances and flanges can only
`
`be formed in a restricted range of shapes, no sharp corners or abrupt changes
`
`in slope are allowed.” Ex. 1012, Bareau at 8.
`
`D. Kingslake (Ex. 1013)
`
`Kingslake is a text by Rudolf Kingslake titled “Optics of Photography.”
`
`Ex