IPR2020-00897
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,324,277
`
`IPR2020-00897 | SLIDE 1
`
`

`

`Ins$tuted Grounds
`
`• Ground 1: Claims 1-3 and 5-8
`Obviousness over Ogino Example 4 and Bareau
`
`• Ground 2: Claims 1-24
`Obviousness over Ogino Example 5 and Bareau
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`2
`
`

`

`Overview of Argument
`• All Ins’tuted Grounds:
`•
`Improperly uses ‘277 patent as a guide to obviousness
`• No mo8va8on to modify Ogino Examples
`•
`Ignores standard industry design prac8ces
`• Ground 1:
`•
`Effec8vely Overlapping Lenses and Manufacturability Issues
`•
`Ignores Bareau Teaching of Rela8ve Illumina8on
`• Ground 2:
`• Manufacturability Issues
`•
`Inconsistent Characteriza8on of Ogino Example 5
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`3
`
`

`

`Pe##oner Improperly Uses the
`‘277 Patent as a Guide
`
`IPR2020-00897 | SLIDE 4
`
`

`

`Dr. Sasian Designed Based on ‘277 Patent Claims
`Q: So once you found a spacing between L3
`and L4 that met the claim limita;ons, you just
`stopped; right?
`MS. SIVINSKI: Objec;on. Misstates tes;mony.
`A: I wouldn't characterize like that. I apply the
`teaching of Ogino and change the spacing and
`have probably -- probably three different
`solu;ons, and one of them was within the
`range of -- of -- in thickness as specified in
`the -- in the '277 Patent. The others, maybe
`they weren't within the range of the '277
`Patent.
`Ex. 2003, February 19, 2021, Sasian Dep. Tr., 171:2-13 (objection omitted).
`
`Dr. Jose Sasian
`Pe..oner’s Expert
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`5
`
`

`

`
`
`Declaration of José Sasián, Ph.D. in Support of Petitioner Reply
`
`of keeping these spaces constant, “a POSITA would have allowed spacings
`
`between lens surfaces to vary” because “[t]his would permit better performance to
`be obtained during the design process.” Id., ¶¶99-100. However, Dr. Milster does
`Design Lenses Based on Patent, Not Knowledge of a POSITA
`not provide any example of how Ogino’s Example 4 lens design could have been
`
`• POSITA Would Not
`Look at ‘277 Patent
`
`• POSITA Would Not
`Look at Prior Art
`Patent Claims
`
`improved by varying spacing between lens surfaces, instead relying on the bare
`
`assertion that prohibiting the lens spacings to vary “might have prevented a
`
`POSITA from finding the best performance result.” Ex. 2001, ¶100. Further, a
`
`POSITA would have known that releasing too many variables for optimization
`
`often leads to drastic changes to the lens structure and would have first made
`
`minimum changes to a lens to maintain the lens within the scope of a patent.
`
`6.
`
`Keeping certain variables constant, such as spacing between lenses,
`
`while varying other parameters, is precisely the approach a POSITA would have
`
`taken. See APPL-1017, p.168 (stating that after entering the lens design to be
`
`improved into a design computer program, “each variable is changed a small
`
`amount, called an increment, and the effect to performance is then computed”). Dr.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`IPR2020-00897 | SLIDE
`6
`Milster testified that he took a similar gradual “step-wise process” in modifying
`
`lenses. APPL-1028, 21:6-18. This is also the same process that Patent Owner’s
`
`expert Dr. Moore described when he was deposed in earlier, related proceedings
`
`involving patents in the same family. APPL-1023, 99:6-18 (stating that variables in
`
`

`

`No Mo#va#on to Modify
`Ogino Examples As Suggested
`
`IPR2020-00897 | SLIDE 7
`
`

`

`
`
`
`
`
`
`
`
`
`
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`% 0 | -
`
`U.S. Patent
`
`U.S. Patent
`
`Sep. 8, 2015
`
`Sep. 8, 2015
`
`Sheet 8 of 14
`
`IPR2020-00897 | SLIDE
`
`8
`
`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 | -
`
`APPL-1005 / Page 13 of 28
`APPLE INC. v. COREPHOTONICS LTD.
`
`No Motivation to Modify Ogino Examples 4 and 5 With Bareau
`• Ogino Example 4
`
`
`
`
`• Ogino Example 5
`
`
`
`
`• Apple Would Modify to Fno.=2.8 Based on Bareau Despite Four
`Other Examples in Ogino having an Fno.<2.8
`
`Lu 77 00||O
`UUTÍ
`OO|-
`
`APPL-1005 / Page 12 of 28
`APPLE INC. v. COREPHOTONICS LTD.
`
`APPL-1005 / Page 11 of 28
`APPLE INC. v. COREPHOTONICS LTD.
`
`APPLE INC. v. COREPHOTONICS LTD.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`

`

`No Mo$va$on to Modify Ogino Examples 4 and 5 With Bareau (cont.)
`– 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 Ogino Example 5
`
`IPR2020-00897 | SLIDE 9
`
`

`

`Pe##oner Ignores
`Industry Design Prac#ces
`and Manufacturability
`
`IPR2020-00897 | SLIDE10
`
`

`

`Achieving the Best Local Solu$on in Zmax
`
`• Allow parameters to fluctuate
`
`• Avoid unnecessary restrictions
`
`• Allow software to guide changes
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`11
`
`

`

`Case No. IPR2020-00897
`Dr. Sasian Ignores Standard Prac$ces
`U.S. Patent No. 10,324,277
`Sasián Decl.
`
`Inter Partes Review of U.S. 10,324,277
`
`4.
`
`Fig. 4D – Prescription Data
`
`
`
`Ex. 1003, Sasián Decl. at 125.
`
`Ex. 1003, Sasián Decl. at 125.
`The values for all of these entries in the First Modified Example 5 are
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`IPR2020-00897 | SLIDE
`identical to those found in the unmodified Example 5 of Ogino with the ex-
`
`12
`
`ception of the first “Thickness” entry. Compare Ex. 1003, Sasián Decl., Fig
`
`2D at 116, with Ex. 1005 at col. 21, Table 9. However, even the first “Thick-
`
`ness” entry is set, and is not allowed to vary. Ex. 2001, Milster Decl., ¶111.
`
`

`

`better performance to be obtained during the design process. However, as
`
`shown in the Prescription Data for in the Second Modified Example 5 in Fig.
`
`5D, only the radius of the surfaces of the first lens have been allowed to vary,
`
`as they are the only entries with a “V” next to them. Ex. 2003, February 19,
`Dr. Sasian Ignores Standard Prac$ces (cont.)
`2021, Sasián Dep. Tr. at 135:8-22.
`Inter Partes Review of U.S. 10,324,277
`Sasián Decl.
`4.
`Fig. 5D – Prescription Data
`
`
`
`Ex. 1003, Sasián Decl. at 129.
`
`51
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`13
`
`

`

`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
`Petitioner’s Expert
`
`IPR2020-00897 | SLIDE 14
`
`

`

`Board Has Already Spoken About Manufacturability Considerations:
`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 Wri_en Decision, at
`44 (quo;ng Ex. 1020 (Ex. 1007 of the present IPR) at 7)
`
`IPR2020-00897 | SLIDE 15
`
`

`

`Ground 1: Ogino Example 4 in
`view of Bareau
`
`IPR2020-00897 | SLIDE16
`
`

`

`Petitioner’s Reply
` IPR2020-00897 (Patent No. 10,324,277)
`
`the L4 and L5 lens elements of the modified Example 4 do not touch or overlap as
`
`
`
`
`
`
`
`shown by the zoomed in ray trace of these lens elements below. APPL-1037, ¶14
`Ground 1 – Ogino Example 4 in view of Bareau
`Q: In looking at that blowup of the ray
`trace there in Figure 3B, what is the
`distance between lenses L4 and L5 at
`that closest point?
`A: Well, I don't have that number with
`me, but it's bigger than 0.
`Q: Okay. Is it bigger -- I mean, is it 1
`millimeter?
`A: … And so the radii where the lenses
`get closer may be in the order of several
`micrometers.
`
`Ex. 2012, July 16, 2021, Sasian Dep. Tr., 25:11-26:10
`(omiKng discussion of calcula.ons).
`APPL-1037, ¶14. Thus, Patent Owner’s statements regarding overlapping lenses
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`IPR2020-00897 | SLIDE
`
`are untrue.
`
`
`
`17
`
`C. Manufacturing considerations are not required by the claims nor
`can they be imported to avoid unpatentability.
`1.
`
`Patent Owner seeks to import manufacturing requirements
`
`

`

`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 arm
`tooling may be required to remove of the parts from the press, degate them from the runner, and package them into trays
`for final shipment. Degating is the process whereby the optical elements themselves are removed from the runner
`system.
`
`3. TYING IT ALL TOGETHER
`
`Beich 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
`posiNoned that
`close to each other
`
`As noted above, 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 optics. In general terms, overall shape and
`tolerances of the optic will drive cost and manufacturability. There are some general guidelines: thicker parts take
`longer to mold than thinner parts. Optics with extremely thick centers and thin edges are very challenging to mold.
`William S. Beich*a, Nicholas Turnera
`Negative optics (thin centers with heavy edges) are difficult to mold. Optics with very tight tolerances may not be
`aG-S Plastic Optics, 408 St. Paul Street, Rochester, NY 14605
`manufacturable at all in a one cavity mold, much less in a mold with more than one cavity. There are some other
`general tolerances that can describe the limits of fabrication in an ideally designed optic.
`
`
`
`
`
`
`
`Attribute
`Radius of Curvature
`EFL
`Center Thickness
`Diameter
`Wedge (TIR) in the Element
`S1 to S2 Displacement (across the parting line)
`Surface Figure Error
`Surface Irregularity
`Scratch-Dig Specification
`Surface Roughness (RMS)
`Diameter to Center Thickness Ratio
`Center Thickness to Edge Thickness Ratio
`Part to Part Repeatability (in a one cavity mold)
`
`Table 2. Rules of thumb.
`
`Rules of Thumb Tolerances
`± 0.50%
`± 1.0%
`± 0.020mm
`± 0.020mm
`< 0.010mm
`< 0.020mm
`(cid:1) 2 fringes per 25.4mm (2 fringes = 1 wave @ 632nm)
`(cid:1) 1 fringes per 25.4mm (2 fringes = 1 wave @ 632nm)
`40-20
`(cid:1) 100 Å
`< 4:1
`< 3:1
`< 0.50%
`
`IPR2020-00897 | SLIDE 18
`
`Copyright 2010 Society of Photo-Optical Instrumentation Engineers. This paper was published in Polymer Optics
`Design, Fabrication, and Materials, edited by David H. Krevor, William S. Beich, Proceedings of SPIE Vol. 7788, and
`is made available as an electronic reprint with permission of SPIE. One print or electronic copy may be made for
`personal use only. Systematic or multiple reproduction, distribution to multiple locations via electronic or other means,
`Proc. of SPIE Vol. 7788 778805-6
`duplication of any material in this paper for a fee or for commercial purposes, or modification of the content of the
`paper are prohibited.
`
`APPL-1007 / Page 7 of 10
`
`

`

`$10 (est.)
`
`$0.50 (est.)
`
`$1 (est.)
`
`Cost:
`
`If we were able to simply scale the 35 mm lens design by 1/10x, we would encounter a few issues:
`
`1) Smaller entrance pupil: Depth of field will be much greater, but diffraction will limit performance sooner than with
`larger formats.
`
`2) Surface figure tolerances: Figure tolerances (fringes of irregularity, for example) will be somewhat tighter, because
`spatial frequencies of interest are higher, but because the surfaces are smaller, they will be easier to achieve in practice.
`3) Geometric tolerances: Scaling the system’s size requires linear tolerances to scale as well. So center thickness
`curves. The effect of mismatch is a drop in light collection efficiency or decreased relative illumination at the image, or
`tolerances and surface and element decenter tolerances will be tighter by a factor of ten. This proves to be the greatest
`cross-talk between microlenses and adjacent pixels, resulting in false coloration.
`challenge of producing these lenses.
`
`4) Angular tolerances: Lens tilt tolerances do not scale down, but small defects on flanges or mounting surfaces will
`Rela$ve Illumina$on Results Violate 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 2
`
`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.
`IPR2020-00897 | SLIDE 19
`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
`
`

`

`Case No. IPR2020-00897
`U.S. Patent No. 10,324,277
`Sasián Decl.
`
`Inter Partes Review of U.S. 10,324,277
`
`Relative Illumination Results Violate Bareau (cont.)
`
`2.
`
`Fig. 2B – Relative Illumination
`
`• Rela@ve Illumina@on of
`Approx. 30% at 32.5°
`
`•
`
`Ignores Teaching in Bareau
`
`Ex. 1003, Sasián Decl. at 116.
`
`
`
`
`
`IPR2020-00897 | SLIDE 20
`
`
`
`Ex. 1003, Sasián Decl. at 116.
`
`As can be seen, the relative illumination for the Modified Example 4 of
`
`Ogino dips below 50% at about 28°. Ex. 2001, Milster Decl., ¶97. The farthest
`
`edge of the field at 32.5° has a relative illumination of only about 30%. This
`
`result is in direct contrast to the teachings of Bareau, which provide that for
`
`

`

`Ground 2: Ogino Example 5 in
`view of Bareau (Claims 11-17)
`
`IPR2020-00897 | SLIDE21
`
`

`

`
`
`
`
`Petitioner’s Reply
`
` IPR2020-00897 (Patent No. 10,324,277)
`Ground 1 – Ogino Example 4 in view of Bareau
`Q: And in par;cular, I want you to look at
`lens elements L2 and L3. What is the
`distance between lens L2 and L3 at the
`closest point in the blown-up figure?
`A: I didn't calculate it, but I will give the
`same answer as before for the
`other case. It may be in the order of
`several micrometers.
`
`
`
`Ex. 2012, July 16, 2021, Sasian Dep. Tr., 60:20-61:2.
`APPL-1037, ¶41.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`IPR2020-00897 | SLIDE
`The zoomed-in ray trace of lens elements L2 and L3 above clearly shows
`
`22
`
`space between these lens elements. APPL-1037, ¶42. Therefore, the allegation that
`
`the first modified Example 5 has overlapping lenses is without merit.
`
`
`
`

`

`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 arm
`tooling may be required to remove of the parts from the press, degate them from the runner, and package them into trays
`for final shipment. Degating is the process whereby the optical elements themselves are removed from the runner
`system.
`
`3. TYING IT ALL TOGETHER
`
`Beich Teaches Against Lens Effec$vely Touching
`Polymer Optics: A manufacturer’s perspective on the factors that
`contribute to successful programs
`
`• Manufacturing
`tolerances would
`not allow lenses to
`positioned that
`close to each other
`
`As noted above, 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 optics. In general terms, overall shape and
`tolerances of the optic will drive cost and manufacturability. There are some general guidelines: thicker parts take
`longer to mold than thinner parts. Optics with extremely thick centers and thin edges are very challenging to mold.
`William S. Beich*a, Nicholas Turnera
`Negative optics (thin centers with heavy edges) are difficult to mold. Optics with very tight tolerances may not be
`aG-S Plastic Optics, 408 St. Paul Street, Rochester, NY 14605
`manufacturable at all in a one cavity mold, much less in a mold with more than one cavity. There are some other
`general tolerances that can describe the limits of fabrication in an ideally designed optic.
`
`
`
`
`
`
`
`Attribute
`Radius of Curvature
`EFL
`Center Thickness
`Diameter
`Wedge (TIR) in the Element
`S1 to S2 Displacement (across the parting line)
`Surface Figure Error
`Surface Irregularity
`Scratch-Dig Specification
`Surface Roughness (RMS)
`Diameter to Center Thickness Ratio
`Center Thickness to Edge Thickness Ratio
`Part to Part Repeatability (in a one cavity mold)
`
`Table 2. Rules of thumb.
`
`Rules of Thumb Tolerances
`± 0.50%
`± 1.0%
`± 0.020mm
`± 0.020mm
`< 0.010mm
`< 0.020mm
`(cid:1) 2 fringes per 25.4mm (2 fringes = 1 wave @ 632nm)
`(cid:1) 1 fringes per 25.4mm (2 fringes = 1 wave @ 632nm)
`40-20
`(cid:1) 100 Å
`< 4:1
`< 3:1
`< 0.50%
`
`IPR2020-00897 | SLIDE 23
`
`Copyright 2010 Society of Photo-Optical Instrumentation Engineers. This paper was published in Polymer Optics
`Design, Fabrication, and Materials, edited by David H. Krevor, William S. Beich, Proceedings of SPIE Vol. 7788, and
`is made available as an electronic reprint with permission of SPIE. One print or electronic copy may be made for
`personal use only. Systematic or multiple reproduction, distribution to multiple locations via electronic or other means,
`Proc. of SPIE Vol. 7788 778805-6
`duplication of any material in this paper for a fee or for commercial purposes, or modification of the content of the
`paper are prohibited.
`
`APPL-1007 / Page 7 of 10
`
`

`

`Dr. Sasian’s Ogino Example 5 Changes Based on IPR
`• Relies on Ogino Example 5 in Two Different IPRs
`• Ground 2 of Present ‘897 IPR
`• Grounds 2-4 of Related ‘896 IPR
`• Uses Example 5 as the star@ng point in obviousness
`analysis
`• But different lens results in Example 5 when used in ‘897 IPR
`than when used in ‘896 IPR
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`24
`
`

`

`Dr. Sasian’s Ogino Example 5 Changes Based on IPR (cont.)
`
`Sasián Decl.
`
`Sasián Decl.
`Inter Partes Review of U.S. 10,317,647
`
`Inter Partes Review of U.S. 10,324,277
`
`2.
`
`Fig. 1B – Relative Illumination
`
`2.
`
`Fig. 3B – Relative Illumination
`
`Ex. 2005, IPR2020-00896, Sasián Decl. at 144.
`
`
`
`To remove ray aberration, vignetting has been allowed by the aperture on surface
`seven.
`
`
`
`
`
`
`
`Ex. 1003, Sasián Decl. at 120.
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`25
`
`Apple v. Corephotonics
`
`144
`
`APPL-1003
`
`

`

`Dr. Sasian Cannot Explain Why Different Results for Ogino Example 5
`
`Q: Why did you use two different
`instances or ways to vigne_e 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 op;ons. There are many
`op;ons that one has in the lens design
`program, and I exercise one op;on at
`one ;me and the other at a different
`;me.
`
`Ex. 2010, July 16, 2021, Sasian Dep. Tr., 71:12-20 (objec.on omiNed).
`
`Dr. Jose Sasian
`Petitioner’s Expert
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00897 | SLIDE
`
`26
`
`

`

`IPR2020-00897
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,324,277
`
`IPR2020-00897 | SLIDE27
`
`