IPR2020-00896
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,317,647
`
`IPR2020-00896 | SLIDE 1
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`

`

`Ins$tuted Grounds
`• Ground 2: Claims 1 and 4
`Obviousness over Ogino and Chen II
`• Ground 3: Claims 2, 3, 5, and 8-11
`Obviousness over Ogino, Chen II, and Bareau
`• Ground 4: Claim 6
`Obviousness over Ogino, Chen II, Bareau, and Kingslake
`• Ground 5: Claim 7
`Obviousness over Hsieh and Beich
`• Ground 6: Claim 12
`Obviousness over Chen, Iwasaki, and Beich
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`2
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`

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`Overview of Argument
`• All InsGtuted Grounds: PeGGon Uses Improper Hindsight
`• Pe##on ignores standard industry design prac#ces
`• No mo#va#on to vary only some parameters
`• Stops design when claims are achieved
`•
`Inconsistent arguments re mo#va#on to combine
`• Reduce vigne+ng in some grounds, allow vigne+ng in others
`• All evidence improper hindsight
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`3
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`

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`Overview of Argument
`• Grounds 2-4: No moGvaGon to modify Ogino with Chen to make
`L2 meniscus
`• Stated mo#va#on – to reduce vigne=ng – fails
`• Only change was to make L2 image side surface convex, BUT
`• Whether lens is convex or concave does not affect vigne+ng
`• Vigne+ng is due to aspherics at edge of lens, not meniscus or biconcave shape
`• No evidence POSITA would associate vigne+ng with meniscus shape
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`4
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`

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`Overview of Argument (cont.)
`• Grounds 3-4: No mo#va#on to further modify Ogino with Bareau
`• Overlapping lens elements ignore manufacturability
`• Design process contradicts original mo#va#on
`• Ground 4: No moGvaGon to combine
`•
`Ignores Bareau teaching and decreases rela#ve illumina#on
`• Ground 6 (Claim 12)
`• Fails to demonstrate that all elements are found
`
`IPR2020-00896 | SLIDE 5
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`

`

`Pe##oner Ignores Industry Design
`Prac#ces and Makes Inconsistent
`Arguments for Mo#va#on to Combine
`– Belies Improper Hindsight
`
`IPR2020-00896 | SLIDE 6
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`

`

`Achieving the Best Local Solu$on in Zmax
`
`• Allow parameters to fluctuate
`
`• Avoid unnecessary restricGons
`
`• Allow soSware to guide changes
`
`Ex. 2001, ¶¶ 101-103.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`7
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`

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`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`Dr. Sasian Ignores Standard Prac$ces
`B.
`
`Fig. 2: Ogino Example 5 modified for L2 meniscus shape using
`Zemax (v. 02/14/2011)
`
`1.
`Fig. 2A – Ray Trace Diagram
`Inconsistent with Standard Prac9ce
`Steps for modification:
`Keep all other
`parameters fixed
`1) Adjust L2 to meniscus as per Chen II;
`2) Allow L1:s1:s2 and L2:s2 radii, and aspheric coefficients to vary;
`3) Improve image quality, RI, CRA.
`
`Only
`
`
`
`EFL=5.460, TTL=5.273, and thickness and spacing of L1-L5 remain unchanged
`(data calculated for standard wavelength of 587 nm).
`Ex. 1003, Sasián Decl. at 147 (annotated)
`f1=+2.384 mmm, f2=-5.525 mm, f3=-6.952 mm, f4=+2.736 mm, f5=-2.454 mm
`
`IPR2020-00896 | SLIDE 8
`
`Apple v. Corephotonics
`
`147
`
`APPL-1003
`
`

`

`Sasián Decl.
`Dr. Sasian Ignores Standard Prac$ces
`4.
`Fig. 2D – Prescription Data
`
`Inter Partes Review of U.S. 10,317,647
`
`Sasian Set Value at 100.00
`
`Allowed Only Three Radii
`Parameters to Vary
`
`Ex. 1003, Sasián Decl. at 150 (annotated)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`9
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`

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`Dr. Sasian Ignores Standard Prac$ces
`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`C.
`
`Fig. 3: Ogino Example 5 modified for meniscus L2 and F#=2.8
`using Zemax (v. 02/14/2011)
`
`Inconsistent with Standard Prac9ce
`
`1.
`Fig. 3A – Ray Trace Diagram
`Steps for modification:
`1) Set L2 to be a meniscus as per Chen;
`2) Maintain FOV to +/- 25.9 degrees;
`3) Allow L1:s1:s2 and L2:s2 radii, and aspheric coefficients to vary;
`4) Allow some vignetting;
`5) Software-optimization for speed at F/2.8.
`
`Inconsistent
`
`
`
`EFL=5.569, TTL=5.274, EPD=1.989 mm, F/#=EFL/EPD=2.8, thickness and
`spacing of L2-L5 unchanged (data calculated for standard wavelength of 587 nm).
`Ex. 1003, Sasián Decl. at 151 (annotated)
`f1=+2.659 mm, f2=-6.434 mm, f3=-6.952 mm, f4=+2.736 mm, f5=-2.454 mm
`IPR2020-00896 | SLIDE 10
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`Apple v. Corephotonics
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`151
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`APPL-1003
`
`

`

`Dr. Sasian Ignores Standard Prac$ces
`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`4.
`
`Fig. 3D – Prescription Data
`
`Allowed Only Three Radii
`Parameters to Vary
`
`Sasian Sets Value
`
`Ex. 1003, Sasián Decl. at 154 (annotated)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`11
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`

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`Dr. Sasian Ignores Standard Prac$ces
`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`D.
`Fig. 4: Ogino Example 5 modified for second meniscus lens, F#=2.8,
`and D7 distance adjusted for D7/f<0.2 using Zemax (v. 02/14/2011)
`
`
`
`Steps for modification:
`1.
`Fig. 4A – Ray Trace Diagram
`1) Start with Ogino Example 5 modified with L2 being meniscus and F#=2.8;
`2) Increase D7 as per Ogino’s conditional expression (10);
`3) Allow L1:s1 and L2:s1,s2 radii, and aspheric coefficients to vary;
`4) Software-optimization for image quality.
`
`Only
`
`EFL=5.569, TTL=5.274, D7=1.085 mm, and thickness and spacing of L2-L5 remain
`Inconsistent with Standard Prac9ce
`otherwise unchanged (data calculated for standard wavelength of 587 nm).
`
`f1=2.578 mm, f2=-5.510 mm, f3=-6.952 mm, f4=2.736 mm, f5=-2.454 mm.
`Ex. 1003, Sasián Decl. at 155 (annotated)
`
`IPR2020-00896 | SLIDE 12
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`Apple v. Corephotonics
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`155
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`APPL-1003
`
`

`

`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`Dr. Sasian Ignores Standard Prac$ces
`4.
`Fig. 4D – Prescription Data
`
`Allowed Only Three Radii
`Parameters to Vary
`
`Sasian Sets Value
`
`Ex. 1003, Sasián Decl. at 158 (annotated)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`13
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`

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`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`Dr. Sasian Ignores Standard Prac$ces
`E.
`Fig. 5: Ogino Example 5 modified for meniscus L2 and F#=2.45
`using Zemax (v. 02/14/2011)
`
`
`
`Inconsistent
`
`Steps for modification:
`1.
`Fig. 5A – Ray Trace Diagram
`1) Start with Example 5 modified with F#=2.8 and meniscus L2;
`2) Open the aperture to F/2.45 to speed the lens up;
`3) Some vignetting is allowed.
`4) Optimize to reduce aberration.
`
`EFL=5.569, TTL=5.274, EPD=2.273 mm, F/#=EFL/EPD=2.45, thickness and
`spacing of L2-L5 unchanged (data calculated for standard wavelength of 587 nm).
`
`f1=+2.659 mm, f2=-6.434 mm, f3=-6.952 mm, f4=+2.736 mm, f5=-2.454 mm.
`Ex. 1003, Sasián Decl. at 159 (annotated)
`Clear aperture of the object side surface of lens L1 is D/2=1.163 mm, or a diameter
`IPR2020-00896 | SLIDE 14
`of D=2.326 mm. (from the semi-diameter column for surface 2 in the prescription
`table in 5D). Fields in the analysis are 0°, 5°, 10°, 15°, 20°, and 25.9°.
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`Apple v. Corephotonics
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`159
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`APPL-1003
`
`

`

`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`Dr. Sasian Ignores Standard Prac$ces
`4.
`Fig. 5D – Prescription Data
`
`Sasian Sets All Values (inconsistent with approach in Grounds 3 & 4)
`
`Ex. 1003, Sasián Decl. at 162 (annotated)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`15
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`

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`Inconsistent Characteriza/on of
`Ogino Example 5 Shows Hindsight
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`IPR2020-00896 | SLIDE16
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`

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`Dr. Sasian’s Ogino Example 5 Changes Based on IPR
`• Relies on Ogino Example 5 in Two Different IPRs
`• Grounds 2-4 of Present ‘896 IPR
`• Ground 2 of Related ‘897 IPR
`• Uses Example 5 as the star;ng point in obviousness
`analysis
`• But inputs different parameters for Example 5 when used ‘896
`IPR than when used in ‘897 IPR
`
`Ex. 2001, ¶¶ 111-113.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`17
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`

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`Dr. Sasian Input Ogino Example 5 Based on Patent to Invalidate
`
`Inter Partes Review of U.S. 10,324,277
`
`Sasián Decl.
`
`Sasián Decl.
`Inter Partes Review of U.S. 10,317,647
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`2.
`
`Fig. 1B – Relative Illumination
`
`2.
`
`Fig. 3B – Relative Illumination
`
`Compare
`
`Compare
`
`
`
`To remove ray aberration, vignetting has been allowed by the aperture on surface
`seven.
`
`
`Ex. 1003, Sasián Decl. at 144.
`
`
`
`
`
`
`Ex. 2005, IPR2020-00897 Sasián Decl. at 120.
`
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`IPR2020-00896 | SLIDE
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`18
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`Apple v. Corephotonics
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`144
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`APPL-1003
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`

`

`Dr. Sasian Cannot Explain Why Different Results for Ogino Example 5
`
`Q: Why did you use two different
`instances or ways to vigneJe when you
`started out on your Ogino Example 5
`regarding the '277 patent and the '647
`patent?
`A: I don't recall the exact reason, but
`again those are opSons. There are many
`opSons that one has in the lens design
`program, and I exercise one opSon at
`one Sme and the other at a different
`Sme.
`
`Ex. 2012, July 16, 2021, Sasian Dep. Tr., 71:12-20
`
`Dr. Jose Sasian
`Pe::oner’s Expert
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00896 | SLIDE
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`19
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`

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`Grounds 2-4: No Mo#va#on to Modify
`Ogino With Meniscus of Chen II
`
`IPR2020-00896 | SLIDE20
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`

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`phones, as evidenced by Bareau (see APPL-1012, p.3) including acceptable values
`
`for relative illumination, ray aberration, and the chief ray angle (CRA) at the
`
`sensor in modern mobile phone applications. APPL-1003, ¶55. A POSITA also
`
`would have been aware, as Ogino recognizes, of the importance of reducing
`Pe$$oner’s Only Stated Mo$va$on to Modify Ogino Example 5 is to
`“deterioration in the light receiving efficiency and occurrence of color mixture due
`Reduce VigneNng
`to increase of incident angle” to “achieve optimum optical performance.” Id.
`
`APPL-1005, 7:21-25.
`
`Modeling Ogino’s Example 5 with lens design software such as Zemax,
`
`however, would have revealed that it suffers from TIR vignetting on the second
`
`Petition for Inter Partes Review of U.S. Patent No. 10,317,647
`surface of the second lens, that it has aberrated rays that would need to be removed
`
`by further vignetting, thereby causing the relative illumination at the edge of the
`26
`field to fall to 40%, and that the CRA for the full field is 38 degrees. APPL-1003,
`
`¶56; see id., Appendix, Fig. 1A. Despite these problems, a POSITA would have
`
`been interested in Ogino’s Example 5 because of its short total track length (5.273
`Petition at 26-27.
`mm), its low telephoto ratio (0.885), and its inclusion with other embodiments
`
`having much lower f-numbers, thus indicating that it was ripe for modification to
`
`IPR2020-00896 | SLIDE 21
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`satisfy the industry trend of more compact and brighter telephoto lenses. APPL-
`
`1003, ¶56.
`
`Accordingly, that POSITA would have been motivated to modify Example 5
`
`

`

`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`No Mo$va$on to Modify Ogino L2 to Be Meniscus
`Allowed Only Three Radii
`4.
`Fig. 2D – Prescription Data
`Parameters to Vary
`Sasian Set Value at 100.00 (makes object surface convex to meet meniscus limitaIon)
`
`Ex. 1003, Sasián Decl. at 150 (annotated)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`22
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`

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`IX. OBVIOUSNESS OF CHALLENGED CLAIMS 4 AND 6-12
`
`A. GROUND 2 - The Petition Fails to Demonstrate that Ogino in
`view of Chen II renders claims 1 and 4 unpatentable.
`
`1.
`Claim 1 and 4
`Pe$$oner’s Mo$va$on Fails Because Nothing Ties Meniscus Lens to
`87. Dr. Sasián describes Chen II as “showing the benefits of the L2 lens
`VigneNng
`being meniscus shape as it provides less vignetting.” (Ex. 1003, Sasián Decl.,
`
`¶46). However, Chen II does not discuss vignetting, nor does it discuss the
`
`advantages of L2 being meniscus with respect to vignetting. The fact that the
`
`front surface of L2 of Example 1 in Chen II is convex with respect to the
`
`object has nothing to do with vignetting. The vignetting in this lens is deter-
`
`mined far away from the center of the lens, near the edge of the L2, as shown
`
`by the arrow from the ‘No Vignetting’ box in the figure in Par 52 of Ex. 1003,
`
`which is reproduced below. The shape of the front surface of L2 in this region
`
`is determined by the strong aspheric coefficients along with the base radius,
`Ex. 2001, ¶ 87.
`while the surface shape in the center of the lens is determined by the radius.
`
`Dr. Tom Milster
`Patent Owner’s Expert
`
`IPR2020-00896 | SLIDE 23
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`

`

`VigneNng Has Nothing to Do With L2 Being Convex in Chen II (Ex. 1008)
`
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`• Vigne<ng occurs at the
`edges of the lens
`Shape at the radius has no
`effect on vigne<ng
`
`•
`
`
`
`Ex. 2001, p. 46.
`It is the sign of the radius of the front surface that determines if the
`
`surface is concave (- sign) or convex (+ sign) toward the object side. Ex.
`IPR2020-00896 | SLIDE 24
`
`2001, Milster Decl., ¶88. In Chen II, the fact that the front surface is convex
`
`toward the object side (+ sign) has nothing to do with vignetting, because ei-
`
`ther a plus (+) sign or a minus (-) sign can produce effectively the same result.
`
`The aspheric coefficients can be adjusted in either case to provide no vignet-
`
`

`

`two lenses of Ogino Example 5 (second lens concave object side) and
`
`Ogino/Chen Example 5 (second lens convex object side) (Ex. 1003, Sasián
`
`Decl., ¶147). Figures from these two lenses are shown below with red arrows
`Any VigneNng is Due to Aspherics at Edge, Not Due to Lens Shape at
`and text annotations.
`Radius
`
`•
`
`•
`
`Ray characteris,cs at the radius
`are unchanged from Ogino
`Example 5 to Ogino/Chen
`Example 5
`Aspherics at the lens edges are
`involved in the vigne>ng
`
`
`
`The arrows labeled ‘Radius’ point to centers of the first (object-side)
`Ex. 2001, p. 48.
`
`IPR2020-00896 | SLIDE 25
`surfaces of the second lens in both cases, and both surfaces display a nearly
`
`vertical line shape in that region of the lens. Ex. 2001, Milster Decl., ¶90. No
`
`

`

`Ogino Example 5 can be modified alone (without Chen II and without
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`meniscus L2) to reduce vigneNng and improve rela$ve illumina$on
`Modified Ogino Example 5.
`
`Case Nos. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`Relative Illumination for the Modified Ogino Example 5.
`
`
`
`
`Ex. 2001, p. 50-54.
`
`Case Nos. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`Prescription data for Modified Ogino Example 5
`
`
`
`IPR2020-00896 | SLIDE 26
`
`92. Further, Dr. Sasián’s analysis is incomplete and ignores how a POSITA
`51
`APPLE V. COREPHOTONICS
`would have designed an optical lens assembly. Because of this, a POSITA
`IPR2020-00896
`Exhibit 2001
`Page 54
`would understand that Dr. Sasián’s results are not usable and at best are inter-
`
`
`
`

`

`Grounds 3-4: No Mo#va#on to Further
`Modify Ogino/Chen II with Bareau
`
`IPR2020-00896 | SLIDE27
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`

`

`US 10 , 317 , 647 B2
`10
`7 . The lens assembly of claim 2 , wherein the lens assem
`( TTL ) of 6 . 0 millimeters or less and wherein the lens
`bly further includes a ratio between a largest optical axis
`assembly has a ratio TTL / EFL < 1 . 0 , wherein a f - num
`Claim 8 Requires Fno. < 2.9
`thickness L11 and a circumferential edge thickness Lle of
`ber F # of the optical lens assembly is smaller than 2 . 9 ,
`US 10 , 317 , 647 B2
`lens element Ly of L11 / Lle < 3 .
`wherein f , is smaller than TTL / 2 , wherein lens ele
`8 . An optical lens assembly comprising five lens elements , 5
`ments Lz and L4 are separated by a gap greater than
`10
`TTL / 5 , wherein lens elements L4 and L , are separated
`in order from an object side to an image side :
`7 . The lens assembly of claim 2 , wherein the lens assem
`( TTL ) of 6 . 0 millimeters or less and wherein the lens
`by a gap smaller than TTL / 20 , and wherein the five lens
`a ) a first lens element Ly with positive refractive power
`bly further includes a ratio between a largest optical axis
`assembly has a ratio TTL / EFL < 1 . 0 , wherein a f - num
`and a focal length f / ;
`elements are made of plastic .
`thickness L11 and a circumferential edge thickness Lle of
`ber F # of the optical lens assembly is smaller than 2 . 9 ,
`9 . The optical lens assembly of claim 8 , wherein F # = 2 . 8 .
`lens element Ly of L11 / Lle < 3 .
`wherein f , is smaller than TTL / 2 , wherein lens ele
`b ) a second lens element L2 with negative refractive
`power and having a meniscus shape with convex " 10
`10 . The optical lens assembly of claim 8 , wherein the ratio
`8 . An optical lens assembly comprising five lens elements , 5
`ments Lz and L4 are separated by a gap greater than
`TTL / EFL is between 0 . 85 and 0 . 95 .
`TTL / 5 , wherein lens elements L4 and L , are separated
`in order from an object side to an image side :
`object - side surface ;
`by a gap smaller than TTL / 20 , and wherein the five lens
`a ) a first lens element Ly with positive refractive power
`11 . The lens assembly of claim 8 , wherein a combined
`c ) a third lens element Lz ;
`and a focal length f / ;
`elements are made of plastic .
`power of lens elements L2 and Lz is negative .
`9 . The optical lens assembly of claim 8 , wherein F # = 2 . 8 .
`d ) a fourth lens element La ; and
`b ) a second lens element L2 with negative refractive
`12 . The lens assembly of claim
`8 , wherein the lens
`power and having a meniscus shape with convex " 10
`10 . The optical lens assembly of claim 8 , wherein the ratio
`e ) a fifth lens element Ls ,
`Dal length 15 assembly further includes a ratio between a largest optical
`wherein the lens assembly has an effective focal length 15
`TTL / EFL is between 0 . 85 and 0 . 95 .
`object - side surface ;
`axis thickness L11 and a circumferential edge thickness Lle
`11 . The lens assembly of claim 8 , wherein a combined
`( EFL ) , wherein a lens system that includes the lens
`c ) a third lens element Lz ;
`of lens element .
`power of lens elements L2 and Lz is negative .
`assembly plus a window positioned between the fifth
`d ) a fourth lens element La ; and
`12 . The lens assembly of claim
`8 , wherein the lens
`lens element and an image plane has a total track length
`e ) a fifth lens element Ls ,
`Dal length 15 assembly further includes a ratio between a largest optical
`wherein the lens assembly has an effective focal length 15
`axis thickness L11 and a circumferential edge thickness Lle
`( EFL ) , wherein a lens system that includes the lens
`of lens element .
`assembly plus a window positioned between the fifth
`lens element and an image plane has a total track length
`
`IPR2020-00896 | SLIDE 28
`
`

`

`Petition for Inter Partes Review of U.S. Patent No. 10,317,647
`Sole Mo$va$on For Fno. < 2.9 is to Make Brighter
`2.
`Reasons to combine Ogino and Bareau
`
`A POSITA would have found it obvious to modify Ogino’s Example 5 lens
`
`assembly based on Bareau’s specifications for cell phone camera lenses desiring an
`
`F#=2.8 or less for ¼” and smaller pixel image sensors. APPL-1003, ¶74. Such a
`
`combination would have been nothing more than applying Bareau’s specification
`
`for a bright lens system, according to known lens design and modification methods
`
`(as taught in APPL-1017, p.172), to yield a predictable result of Ogino’s Example
`
`5 lens assembly likewise supporting an f-number of 2.8 or lower for a ¼” sensor
`
`format. APPL-1003, ¶74; see id., pp.3-4. A POSITA would have found it obvious
`
`to lower the f-number of Example 5 whether original or modified with a meniscus
`Pet. at p. 47.
`
`L2 lens for the same reasons discussed below. APPL-1003, ¶74. This is shown in
`
`IPR2020-00896 | SLIDE 29
`
`the modified design in Appendix Fig. 3A, working at F#=2.8 and using the L2 lens
`
`with a meniscus shape. See id., Appendix. Fig. 3A. Id.
`
`Bareau published in 2006 and by 2013 (the priority date of the ’647 Patent),
`
`

`

`No Mo$va$on to Further Modify Ogino Example 5 with Bareau:
`Ogino Contains Four Examples with Fno. < 2.9
`
`
`
`
`
`
`
`
`
`• Ogino Example 5
`
`
`
`
`• Apple Would Modify to Fno.=2.8 Based on Bareau Despite Four
`Other Examples in Ogino having an Fno.<2.8
`
`APPL-1005 / Page 11 of 28
`APPLE INC. v. COREPHOTONICS LTD.
`
`APPL-1005 / Page 14 of 28
`APPLE INC. v. COREPHOTONICS LTD.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1005 / Page 13 of 28
`APPLE INC. v. COREPHOTONICS LTD.
`
`U.S. Patent
`
`U.S. Patent
`
`Sep. 8, 2015
`
`Sep. 8, 2015
`
`Sheet 8 of 14
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`IPR2020-00896 | SLIDE
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`30
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`Sheet 9 of 14
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`US 9,128.267 B2
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`% 0 | -
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`Uu??
`00||O UU 77 00 | -
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`HNIT-p–
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`% 0 | -
`
`

`

`No Mo$va$on to Further Modify Ogino Example 5 With Bareau
`– POSITA mo*vated to have fno. = 2.8 as taught by
`Bareau would have made a small modifica*on to
`one of Ogino Examples 1-3 and 6
`
`– Would not have made the large modifica*ons to
`the fno. = 3.94 in Modified Ogino Example 5
`
`IPR2020-00896 | SLIDE 31
`
`

`

`Grounds 3 and 4: Inconsistency with
`Original Mo#va#on Shows Hindsight
`
`IPR2020-00896 | SLIDE32
`
`

`

`Ground 3 (Claims 2, 3, and 5) – Contradicts Sole Ra$onal for Modifying
`Ogino Example 5 with Meniscus L2
`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`C.
`Fig. 3: Ogino Example 5 modified for meniscus L2 and F#=2.8
`using Zemax (v. 02/14/2011)
`Steps for modification:
`Fig. 3A – Ray Trace Diagram
`1) Set L2 to be a meniscus as per Chen;
`2) Maintain FOV to +/- 25.9 degrees;
`3) Allow L1:s1:s2 and L2:s2 radii, and aspheric coefficients to vary;
`4) Allow some vignetting;
`5) Software-optimization for speed at F/2.8.
`
`1.
`
`Inconsistent
`
`
`
`EFL=5.569, TTL=5.274, EPD=1.989 mm, F/#=EFL/EPD=2.8, thickness and
`spacing of L2-L5 unchanged (data calculated for standard wavelength of 587 nm).
`Ex. 1003, Sasián Decl. at 151.
`f1=+2.659 mm, f2=-6.434 mm, f3=-6.952 mm, f4=+2.736 mm, f5=-2.454 mm
`
`Apple v. Corephotonics
`
`151
`
`APPL-1003
`IPR2020-00896 | SLIDE 33
`
`

`

`Ground 4 – Contradicts Sole Ra$onal for Modifying Ogino Example 5
`Inter Partes Review of U.S. 10,317,647
`Sasián Decl.
`
`E.
`
`Fig. 5: Ogino Example 5 modified for meniscus L2 and F#=2.45
`using Zemax (v. 02/14/2011)
`
`1.
`
`Fig. 5A – Ray Trace Diagram
`Steps for modification:
`1) Start with Example 5 modified with F#=2.8 and meniscus L2;
`2) Open the aperture to F/2.45 to speed the lens up;
`3) Some vignetting is allowed.
`4) Optimize to reduce aberration.
`
`Inconsistent
`
`
`
`EFL=5.569, TTL=5.274, EPD=2.273 mm, F/#=EFL/EPD=2.45, thickness and
`spacing of L2-L5 unchanged (data calculated for standard wavelength of 587 nm).
`
`f1=+2.659 mm, f2=-6.434 mm, f3=-6.952 mm, f4=+2.736 mm, f5=-2.454 mm.
`Ex. 1003, Sasián Decl. at 159.
`Clear aperture of the object side surface of lens L1 is D/2=1.163 mm, or a diameter
`of D=2.326 mm. (from the semi-diameter column for surface 2 in the prescription
`IPR2020-00896 | SLIDE 34
`table in 5D). Fields in the analysis are 0°, 5°, 10°, 15°, 20°, and 25.9°.
`
`
`
`Apple v. Corephotonics
`
`159
`
`APPL-1003
`
`

`

`$10 (est.)
`
`$0.50 (est.)
`
`$1 (est.)
`
`Cost:
`
`If we were able to simply scale the 35 mm lens design by 1/10x, we would encounter a few issues:
`
`1) Smaller entrance pupil: Depth of field will be much greater, but diffraction will limit performance sooner than with
`larger formats.
`
`2) Surface figure tolerances: Figure tolerances (fringes of irregularity, for example) will be somewhat tighter, because
`spatial frequencies of interest are higher, but because the surfaces are smaller, they will be easier to achieve in practice.
`3) Geometric tolerances: Scaling the system’s size requires linear tolerances to scale as well. So center thickness
`curves. The effect of mismatch is a drop in light collection efficiency or decreased relative illumination at the image, or
`tolerances and surface and element decenter tolerances will be tighter by a factor of ten. This proves to be the greatest
`cross-talk between microlenses and adjacent pixels, resulting in false coloration.
`challenge of producing these lenses.
`
`4) Angular tolerances: Lens tilt tolerances do not scale down, but small defects on flanges or mounting surfaces will
`Pe$$oner Ignores Rela$ve Illumina$on Teachings of Bareau
`Today, maximum CRA specifications for different sensor formats are readily available in the <12 degree to <26 degree
`
`have a larger effect on tilt.
`range, with the larger CRA allowances corresponding to smaller VGA formats (2.2um, 3.6um). The demand for shorter
`5) Stray light considerations: An aperture or baffle feature that has an acceptably small dimension at the large scale
`TTL’s is putting pressure on sensor manufacturers to increase their maximum allowable CRA values. Added constraints
`should be scaled down by 1/10. However, some parts cannot be made thin enough, or they may become translucent, so
`and fewer elements are lessening the lens designer’s ability to deliver good image quality performance and low CRA’s.
`they will cause a larger fraction of the light to scatter from their edges, resulting in flare or veiling glare.
`The Optics of Miniature Digital Camera Modules
`
`6) Scratch/Dig and Contamination: The smaller system is much more sensitive to defects and contamination causing
`Relative Illumination – The relative illumination is the level of light energy incident at the image plane for a given field
`
`shadowing on the image. Acceptable defect dimensions scale with the format size, and the situation is often worse in
`point relative to that at the center of the image.
`Jane Bareau and Peter P. Clark
`practice, because the back focal distance is very short and defects close to the image are more visible.
`Flextronics Optical Technology Center, 1 Upland Road, Norwood, MA, USA 02062
`
`Relative Illumination vs Field Angle
`
`
`
`
`
`20
`15
`10
`Field Angle (degrees)
`
`1.1
`4. Specifications
`1
`0.9
`The following are typical lens specifications for a ¼” sensor format:
`ABSTRACT
`0.8
`0.7
`
` Rel. Ill.
`0.6
`0.5
`FOV
`60 degrees
`cos^4
`Designing lenses for cell phone cameras is different from designing for traditional imaging systems; the format poses
`0.4
`Image Circle
`4.6 mm diam.
`0.3
`unique challenges. Most of the difficulty stems from the scale of the system, which is based on the size of the sensor.
`0.2
`TTL
`5.0mm
`0.1
`
`0
`f/no
`f/2.8
`Keywords: Optical design, lens design, digital cameras
`Distortion
`<2%
`1. INTRODUCTION
`<22 degrees
`Chief Ray Angle
`
`
`>50%
`Relative Illumination
`The scale of cell phone camera systems creates particular challenges for the lens designer that are unique to this format.
`Fig.8: Relative Illumination and Cos^4 as a Function of Field Angle
`
`Both the size and the low-cost requirements have many implications for the design, fabrication and assembly processes.
`Ex. 1012 - Bareau at 3.
`
`FOV - The field of view for these systems is typically 60 to 66 degrees across the sensor diagonal, but the design must
`The blue curve in fig.8 is a typical relative illumination plot. Lens specifications usually require a value greater than
`include a slightly larger angle to allow for correction over the image circle.
`50% at the edge of the field. This corresponds roughly to cos^4, so there is rarely enough corner illumination to allow
`
`vignetting for aberration control. If relative illumination meets the requirements, the final image is corrected
`Image Circle - This is the diameter of the image over which the lens has to be well corrected to allow for lateral
`electronically. Also, it’s important that the drop in the relative illumination curve is not precipitous towards full field, or
`displacement of the sensor relative to the optical axis. Lens to sensor centration errors are caused mostly by uncertainty
`a slight decenter of the sensor relative to the optical axis will cause one corner of an image to appear noticeably dark.
`in the placement of the sensor on its circuit board. To allow for those errors, the lens image circle is increased by at least
`0.2 mm. As sensors get smaller sensor placement accuracy must improve.
`Ex. 1012 - Bareau at 7.
`5. Designing
`
`TTL- The total track length is the distance from the front of the barrel to the image plane, this has to be longer than the
`When first beginning a lens design, it is not obvious how many elements to use or which materials. The biggest
`optical track length by at least 0.050mm in order to protect the front of the lens. This is extremely important to the cell
`challenge in designing these systems is to create a lens that is insensitive to tolerances and will perform well when built.
`IPR2020-00896 | SLIDE 35
`phone designers because of the market pressure to produce thinner phones.
`Each additional element adds tolerances that will degrade the as-built performance. But each element also adds
`
`variables that can be used to increase nominal performance while meeting system and manufacturing constraints.
`
`
`Fig.1: This 3.6um pixel VGA camera module is 6.05 x 6.05 x 4.5 mm.
`The most critical dimension is the 4.5 mm axial length.
`
`
`For those of us who have been involved in the design and manufacturing of consumer and commercial imaging systems
`using lens elements with diameters in the 12-40mm range, the switch to much smaller elements with diameters in the 3-
`5mm range takes some adjustment. When designing a camera module lens, it is not always helpful to begin with a
`traditional larger-scale imaging lens. Scaling down such a lens will result in a system that is unmanufacturable. If the
`design includes molded plastic optics, a scaled down system will result in element edge thicknesses shrinking to the
`SPIE-OSA/ Vol. 6342 63421F-3
`
`
`
`0
`
`5
`
`25
`
`30
`
`Relative Illumination
`
`

`

`Original Mo$va$on to Modify Ogino in View of Chen II Was Allegedly to
`Improve Rela$ve Illumina$on
`
`Inter Partes Review of U.S. 10,317,647
`
`Sasián Decl.
`
`2.
`
`Fig. 2B – Relative Illumination at F/3.94 at CRA=31.8°
`
`• Rela;ve Illumina;on of
`Approx. 70% at 25.9°
`
`• Consistent with Teaching in
`Bareau
`
`
`
`
`
`Ex. 1003 at at 148.
`
`
`
`IPR2020-00896 | SLIDE 36
`
`

`

`Ground 4 Ignores Bareau’s Rela$ve Illumina$on Teaching
`
`• Ground 4 results in a decreased Rela1ve
`Illumina1on to Approx. 45% at 25.9°
`
`• About the Same Rela1ve Illumina1on as in
`Original Ogino Example 5
`
`IPR2020-00896 | SLIDE 37
`
`

`

`Sasián Decl.
`
`Rela$ve Illumina$on Is Essen$ally Unchanged
`
`Inter Partes Review of U.S. 10,317,647
`
`Sasián Decl.
`
`Inter Partes Review of U.S. 10,317,647
`
`2.
`
`Fig. 1B – Relative Illumination
`
`2.
`
`Fig. 5B – Relative Illumination
`
`
`
`
`
`Ex. 1003, Sasián Decl. at 144, 160.
`To remove ray aberration, vignetting has been allowed by the aperture on surface
`seven.
`
`
`
`
`
`
`IPR2020-00896 | SLIDE 38
`
`

`

`Grounds 3 & 4: Pe//oner Ignores
`Manufacturability
`
`IPR2020-00896 | SLIDE39
`
`

`

`A POSITA Would Consider Manufacturability
`A POSITA “would have had experience in
`analyzing, tolerancing, adjus$ng, and
`op$mizing mul$-lens systems for
`manufacturing, and would have been
`familiar with the specifica$ons of lens
`systems and their fabrica$on.”
`
`Ex. 1003, SasianDecl. at ¶ 19.
`
`Dr. Jose Sasian
`Pe::oner’s Expert
`
`IPR2020-00896 | SLIDE 40
`
`

`

`Board Has Already Spoken About Manufacturability Considera$ons:
`We disagree that a person having ordinary skill in op3cal lens
`design at the 3me of the ’568 patent would not consider “the
`limits of fabrica3on” such as those discussed in Beich,
`par3cularly in light of Beich’s disclosure that “it is important
`that the designer has a basic understanding of the
`manufacturing process and of the limits of size and tolerances
`that might be expected of the finished op3cs.”
`
`IPR2019-00030, Paper No. 32, Final WriJen Decision, at
`44 (quoSng Ex. 1020 (Ex. 1007 of the present IPR) at 7)
`
`IPR2020-00896 | SLIDE 41
`
`

`

`Beich (Ex. 1007) Teaches Against Lenses Effec$vely Touching
`Polymer Optics: A manufacturer’s perspective on the factors that
`contribute to successful programs
`
`• Manufacturing
`tolerances would
`not allow lenses to
`be posiGoned
`closer than 40
`microns (0.020 mm
`x 2)
`
`Ex. 1007 at 7.
`
`accumulates at the end of the screw it is injected at an appropriate speed and pressure into the mold. This causes the
`material to flow into the mold to fill the cavities. The molding machine provides complete control over this process,
`governing the size of the shot, injection speed, injection pressure, backpressure, cushion, and other critical variables that
`will determine the final outcome of the optic. After an appropriate cooling time, the moveable platen moves away from
`the fixed platen, and the mold opens. This allows the optics (still attached to the runner system) to be removed. After
`the shot is removed, the cycle starts over again.
`
`Other equipment is often found along side the molding machine. For parts that require a large amount of material, auto
`loading hoppers are used to feed material into the machine. Also, the thermoplastics must be dried before being fed into
`the injection unit. It is common to see desiccating equipment located near the press for this purpose. Once the molding
`cycle is completed it is desirable to promptly remove the shot so that the entire molding process may be repeated with
`regularity. To aide in this, a robotic arm is frequently used to ensure that the removal is done on time. This enables the
`entire process to go into a steady state. Depending on the nature of the program, additional automation or end of