Inter Partes Review of
`Patent No. 10,324,277
`
`Apple Inc. v. Corephotonics, LTD., Case No. IPR2020-00897
`
`Michael Parsons
`Jordan Maucotel
`Haynes and Boone, LLP
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`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`1
`
`
`Patent No. 10,324,277
`
`Apple Inc. v. Corephotonics, LTD., Case No. IPR2020-00897
`
`Michael Parsons
`Jordan Maucotel
`Haynes and Boone, LLP
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`1
`
`
`
`Grounds for challenging the claims of the ’277 patent.
`
`Ground Challenged Claims
`
`References
`
`1
`
`2
`
`1-3 and 5-8
`
`1-24
`
`Obvious over Ogino (Ex. 4) and
`Bareau
`Obvious over Ogino (Ex. 5) and
`Bareau
`
`Basis
`
`§ 103
`
`§ 103
`
`Petition at 9.
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`2
`
`2
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`
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`Obviousness only requires a motivation to combine the prior art
`and a reasonable expectation of success in doing so.
`
`• Obviousness is a question of whether a POSITA would have been:
`•
`“motivated to combine the teachings of the prior art references to achieve the
`claimed invention, and
`that the skilled artisan would have had a reasonable expectation of success in
`doing so.”
`
`•
`
`InTouch Techs., Inc. v. VGO Comms., 751 F.3d 1327, 1347 (Fed. Cir. 2014).
`Note that in IPR, the standard is a “preponderance of the evidence.” 35 U.S.C. § 316(e).
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`3
`
`3
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`
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`“Motivation to combine” is whether there is an “apparent reason to
`combine” the prior art “in the fashion claimed” by the patent.
`• The Sur-Reply argues throughout that Apple failed to provide reasons:
`• why a POSITA would have selected Ogino’s Ex. 4 or Ex. 5 in the first place
`(see pp. 9, 12) and
`• why a POSITA would have ended up at Dr. Sasián's examples in the Petition
`(see pp. 5-6, 11-12, 15-16).
`• These arguments fail to apply the proper obviousness standard:
`
`InTouch Techs., Inc. v. VGO Comms., 751 F.3d 1327, 1347 (Fed. Cir. 2014).
`• The claims here are directed to five-lens miniature telephoto lens assemblies and
`Ogino teaches five-lens miniature telephoto lens assemblies in Ex. 4 and Ex. 5. See
`APPL-1005, Figs. 4-5, cited in Petition at 10, 51.
`
`• The only relevant question here is what was presented in the Petition — whether a
`POSITA would have been motivated to modify Ogino’s Ex. 4 and Ex. 5 in “the fashion
`claimed by the patent at issue” — not whether a POSITA could have chosen other
`references or made other unrelated modifications. See Petitioner Reply at 4, 20.
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`4
`
`4
`
`
`
`“Reasonable expectation of success” only means “reasonable
`probability of success,” not absolute certainty.
`
`• The Sur-Reply argues that a POSITA would have used Dr. Milster’s lens modification
`technique (many parameters vary at the same time) and not Dr. Sasián's (few parameters
`vary at the same time) (see pp. 5, 13-14).
`• This argument fails because Dr. Sasián testified that a POSITA would use his
`technique (see APPL-1003, ¶58), and there is no evidence that a POSITA would not
`use it where the POSITA desired to change one limitation (e.g., f-number).
`• When a POSITA chose to use Dr. Sasián's technique, there was a reasonable
`probability of success.
`
`• A “reasonable expectation of success” is simply “a reasonable probability of success” in
`achieving the claims at issue, “not absolute” certainty of achievement. (See case law on
`previous slide)
`
`• A showing of obviousness requires
`only proof of motivation to combine
`in the way set out by the Petition,
`not motivation not to combine in
`some other way.
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`Outdry Techs. v. Geox S.P.A., WL 2603139 (Fed. Cir. 2007).
`
`5
`
`5
`
`
`
`“Reasonable expectation of success” only means “reasonable
`probability of success,” not absolute certainty.
`
`• The Sur-Reply argues that a POSITA modifying a lens could have made various
`modifications to achieve the desired goal (e.g., a reduced f-number) and that Petitioner
`must show why a POSITA would have chosen the specific embodiment that meets the
`claim limitation (see pp. 5-6, 11-12, 15-16).
`• These argument fail because they require showing a certainty of success (of
`reaching the claimed limitation).
`
`• A “reasonable expectation of success” is simply “a reasonable probability of success” in
`achieving the claims at issue, “not absolute” certainty of achievement.
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`6
`
`6
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`Pfizer, Inc. v. Apotex, Inc., 480 F.3d 1348, 1364 (Fed. Cir. 2007).
`
`
`
`Discussion Summary
`
`The Sur-Reply argues that Dr. Sasián’s Reply declaration
`improperly relies on the challenged claims. It does NOT.
`
`Ground 1: A POSITA would have modified Ogino’s Ex. 4 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have modified Ogino’s Ex. 5 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have been motivated to further
`modify Ogino’s Ex. 5 lens to achieve a desirable D7 spacing.
`
`Grounds 1 & 2: Patent Owner has not shown that Dr.
`Sasián's examples cannot be made.
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`7
`
`7
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`
`
`Dr. Sasián confirmed in deposition that he did not consider the
`patent at issue in deciding how to modify Ogino’s lens designs.
`
`• Patent Owner’s Sur-Reply argument cites to Dr. Sasián’s deposition testimony as
`support that he used the claims at issue as a roadmap. See Sur-Reply at 3.
`
`• Dr. Sasián's testimony says the opposite:
`
`Ex. 2003 (Sasián depo transcript), 171:1-13 cited in Sur-Reply at 3.
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`8
`
`8
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`
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`The Sur-Reply mischaracterizes Dr. Sasián’s Reply Declaration
`as improperly relying on the claims. This is INCORRECT.
`
`• Patent Owner cites to ¶5 of Dr. Sasián's Reply declaration and alleges that he considered
`the subject’s patent claims “when deciding what modifications to make to the prior art.”
`See Sur-Reply at 1-2, 6, 11-12, 14-16.
`
`• But Patent Owner mischaracterizes the ¶5 discussion—which discusses modifications
`within the scope of the Ogino patent—not the subject patent.
`
`Patent Owner treats the
`phrase “a patent” (referring
`to Ogino) as if it were “the
`patent at issue here”.
`
`Dr. Sasián's ¶5 provided
`the opinion that a POSITA
`would have made minimum
`changes to Ogino’s lenses
`to maintain the lens within
`the scope of Ogino.
`
`APPL-1037 (Declaration in Support of Reply), ¶ 5 cited in Sur-Reply at 1-2.
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`9
`
`9
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`
`
`Discussion Summary
`
`The Sur-Reply argues that Dr. Sasián’s Reply declaration
`improperly relies on the challenged claims. It does NOT.
`
`Ground 1: A POSITA would have modified Ogino’s Ex. 4 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have modified Ogino’s Ex. 5 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have been motivated to further
`modify Ogino’s Ex. 5 lens to achieve a desirable D7 spacing.
`
`Grounds 1 & 2: Patent Owner has not shown that Dr.
`Sasián's examples cannot be made.
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`10
`
`10
`
`
`
`Ground 1: Obvious to modify Ogino Ex. 4 from F=3.04
`to Bareau’s preference of F=2.8.
`
`• A POSITA would have been motivated to start with Ogino’s Ex. 4 because it is
`one of two designs having a telephoto ratio (TTL/EFL<1) and has the lower f-
`number:
`
`Ogino
`
`Ex. 1
`
`Ex. 2
`
`Ex. 3
`
`Ex. 4
`
`Ex. 5
`
`Ex. 6
`
`TTL (mm)
`(+CG)
`TTL/EFL
`
`F-number
`
`4.239
`
`1.027
`
`2.47
`
`4.223
`
`1.025
`
`2.46
`
`4.219
`
`1.025
`
`2.45
`
`4.362
`
`0.958
`
`3.04
`
`5.273
`
`0.885
`
`3.94
`
`4.489
`
`1.005
`
`2.64
`
`See APPL-1005 (Ogino).
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`11
`
`11
`
`
`
`Minimal changes are needed to modify Ogino Ex. 4
`from F=3.04 to F=2.8
`
`• Only minimal changes to Example 4 are required:
`(1) Open the aperture (i.e., front opening) to provide F=2.8 and
`(2) Optimize the lens assembly (i.e., allow the software to optimize the design):
`
`APPL-1003 (Sasián decl.) at 115 cited in Petition at 18.
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`12
`
`12
`
`
`
`A POSITA would have decreased the f-number of Ogino’s Ex. 4 to
`2.8 based on Bareau’s lens specifications.
`
`• Bareau teaches typical lens specifications for use in cell phones including an
`f-number of 2.8 which indicates the amount of light preferred for a 1/4” sensor:
`
`APPL-1012 (Bareau) at 3 cited in Petition at 53.
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`13
`
`13
`
`
`
`Lowering the F-number of a lens design is a
`well-known and desirable feature.
`
`• The need for lower f-numbers has been well known since the 1990s:
`
`APPL-1013 (Kingslake) at 104 cited in Petition at 38.
`
`• Patent Owner agrees that the specific f-number of 2.8 was “desirable”:
`
`APPL-1036 (IPR2020-00878 Patent Owner Response at 30) cited in Petitioner
`Reply at 2.
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`14
`
`14
`
`
`
`The claims does not recite anything related to relative illumination
`(RI) and RI preferences are not mandatory to all lens designs.
`
`• The Sur-Reply argues that Ogino Ex. 4 modified to F=2.8 has relative illumination below
`Bareau’s typical specification (see pp. 9-10).
`• Each of Bareau’s specifications are a possible improvement but not required.
`• The RI of Ogino Ex. 4 is low, so its doesn’t apply Bareau’s specification that
`“usually requires a value greater than 50% at the edge of the field.” APPL-1012, p.7
`
`Original Ogino Ex. 4 with F=3.04
`
`Modified Ogino Ex. 4 with F=2.8
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`cited in APPL-1003 ¶ 59; Petition at 19.
`15
`
`15
`
`
`
`Discussion Summary
`
`The Sur-Reply argues that Dr. Sasián’s Reply declaration
`improperly relies on the challenged claims. It does NOT.
`
`Ground 1: A POSITA would have modified Ogino’s Ex. 4 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have modified Ogino’s Ex. 5 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have been motivated to further
`modify Ogino’s Ex. 5 lens to achieve a desirable D7 spacing.
`
`Grounds 1 & 2: Patent Owner has not shown that Dr.
`Sasián's examples cannot be made.
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`16
`
`16
`
`
`
`Ground 2: Obvious to modify Ogino Ex. 5 from F=3.94
`to Bareau’s preference of F=2.8.
`• A POSITA would have been motivated to start with Ex. 5 because it has the
`best telephoto ratio (TTL/EFL) of Ogino’s two telephoto designs:
`
`Ogino
`
`Ex. 1
`
`Ex. 2
`
`Ex. 3
`
`Ex. 4
`
`Ex. 5
`
`Ex. 6
`
`TTL (mm)
`(+CG)
`TTL/EFL
`
`F-number
`
`4.239
`
`1.027
`
`2.47
`
`4.223
`
`1.025
`
`2.46
`
`4.219
`
`1.025
`
`2.45
`
`4.362
`
`0.958
`
`3.04
`
`5.273
`
`0.885
`
`3.94
`
`4.489
`
`1.005
`
`2.64
`
`See APPL-1005 (Ogino).
`
`• The ’277 patent states that a miniature five-lens design having a low telephoto ratio was
`desirable:
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`APPL-1001, 1:43-48.
`
`17
`
`17
`
`
`
`Dr. Sasián showed how a POSITA would have lowered the
`f-number of Ogino’s Ex. 5 to 2.8.
`• Patent Owner does not dispute Dr. Sasián's opinion that a POSITA would have been
`motivated to modify Ogino’s Ex. 5 to achieve F=2.8.
`
`APPL-1003 at 122 cited in Petition at 54.
`
`• A POSITA would have lowered the f-number of
`Ogino’s Ex. 5 with as few changes to the original
`lens as possible. See APPL-1017 (Fischer) at
`168 cited in Petitioner Reply at 3.
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`18
`
`18
`
`
`
`A POSITA would have decreased the f-number of Ogino’s Ex. 5 to
`2.8 based on Bareau’s lens specifications.
`
`• Bareau teaches typical lens specifications for use in cell phones including an
`f-number of 2.8 which indicates the amount of light preferred for a 1/4” sensor:
`
`APPL-1012 at 3 cited in Petition at 53.
`
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`19
`
`19
`
`
`
`Lowering the F-number of a lens design is a
`well-known and desirable feature.
`
`• The need for lower F-numbers has been well known since the 1990s:
`
`APPL-1013 (Kingslake) at 104 cited in Petition at 13.
`
`• Patent Owner agrees that the specific F-number of 2.8 was “desirable”:
`
`IPR2020-00878 Patent Owner Response at 30 cited in Petitioner Reply at 2.
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`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`20
`
`20
`
`
`
`Patent Owner acknowledges that lenses for mounting in a barrel
`use a mounting flange, not a sharp corner.
`
`• The Sur-Reply complains about Dr. Sasián’s showing that mounting flanges could be
`used with the modified Ex. 5 from the Petition (see p. 12).
`• But Patent Owner acknowledges in the Sur-Reply in IPR2020-00878 that lenses
`include flanges for mounting rather than sharp edges as depicted in design
`program drawings (see pp. 5-7).
`
`• Dr. Sasián's addition of flanges merely shows what Patent Owner already admits, that
`lens designs like the Dr. Sasián's examples would likewise include mounting flanges
`once manufactured and would not have a sharp corner.
`
`flanges
`
`Petitioner Reply at 24 (annotated).
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`21
`
`21
`
`
`
`If a manufacturing consideration was relevant for a particular design, a
`POSITA could have easily modified Ogino’s examples, like thickening
`the edges.
`
`• Dr. Sasián showed how a POSITA would have modified Example 5 to incorporate Dr.
`Milster’s manufacturing considerations for increased edge thickness, if deemed
`necessary by the POSITA.
`
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`22
`
`22
`
`Petitioner Reply at 25.
`
`
`
`Dr. Milster admits that a POSITA would have been motivated to modify
`a lens to increase the edge thickness (i.e., oversize), if necessary.
`
`APPL-1028 (Milster depo), 112:20-113:2.
`
`APPL-1028 (Milster depo), 111:18-112:6.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`23
`
`23
`
`
`
`Discussion Summary
`
`The Sur-Reply argues that Dr. Sasián’s Reply declaration
`improperly relies on the challenged claims. It does NOT.
`
`Ground 1: A POSITA would have modified Ogino’s Ex. 4 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have modified Ogino’s Ex. 5 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have been motivated to further
`modify Ogino’s Ex. 5 lens to achieve a desirable D7 spacing.
`
`Grounds 1 & 2: Patent Owner has not shown that Dr.
`Sasián's examples cannot be made.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`24
`
`24
`
`
`
`A POSITA would have modified the gap between L3 and L4 of
`Ogino’s Ex. 5 according to Ogino’s conditional expression (10)
`
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`25
`
`25
`
`APPL-1005, 12:45-64 cited in Ex. 1003, ¶73;
`Petition at 56.
`
`
`
`Increasing the gap between L3 and L4 of Ogino’s Ex. 5 according
`to conditional expression (10) improves optical performance.
`• Dr. Sasián’s example shows a reasonable expectation of success in applying Ogino’s
`teaching of conditional expression (10) to Ogino’s Ex. 5:
`
`APPL-1003 at 126 cited in Petition at 31.
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`26
`
`26
`
`
`
`Discussion Summary
`
`The Sur-Reply argues that Dr. Sasián’s Reply declaration
`improperly relies on the challenged claims. It does NOT.
`
`Ground 1: A POSITA would have modified Ogino’s Ex. 4 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have modified Ogino’s Ex. 5 to
`F=2.8 based on Bareau’s typical lens specifications.
`
`Ground 2: A POSITA would have been motivated to further
`modify Ogino’s Ex. 5 lens to achieve a desirable D7 spacing.
`
`Grounds 1 & 2: Patent Owner has not shown that Dr.
`Sasián's examples cannot be made.
`
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`27
`
`27
`
`
`
`An inability to mass manufacture lenses would not have
`discouraged a POSITA from using a modified lens design.
`• The Sur-Reply argues that a POSITA would have considered various possible mass
`manufacturing considerations when designing a lens, and that Dr. Sasián's designs are not
`manufacturable (see pp. 4-5, 6-9, 11-14). This fails for several reasons including:
`(1) It is undisputed that a lens assembly like Dr. Sasián's examples can be useful for other
`purposes outside of large-scale manufacturing (see slide 29);
`(2) It is undisputed that diamond turning can be used to manufacture Dr. Sasián's lens
`examples, particularly if large-scale manufacturing is not required (see slides 30-32);
`(3) The ’277 patent does not recite any limitations directed to how the lens assembly is to
`be made, i.e., the Rules of Thumb provided in Beich or any others provided by Dr. Milster
`(see slide 33);
`(4) The specification does not limit the claims to any type of manufacturing (indeed, the
`embodiments are not manufacturable under the rules Patent Owner seeks to import) (see
`slides 34);
`(5) Patent Owner argued the exact opposite in IPR2019-00030 — that a POSITA would not
`know or care about manufacturing when designing a lens (see slide 35); and
`(6) Even if injection molding manufacturing preferences were required, tolerances are more
`forgiving than in Beich’s rules, down to 0.5 µm (0.0005 mm) (see slide 36).
`
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`28
`
`28
`
`
`
`(1) Dr. Sasián’s modifications of Ogino’s Ex. 4 and Ex. 5 are
`suitable for purposes outside of large-scale manufacturing.
`
`• Patent Owner does not dispute that a POSITA could and would have modified Ogino’s
`examples for purposes other than mass-manufacturing, such as research, academic
`applications, prototyping, and small-scale manufacturing.
`
`• Dr. Milster even agrees that a POSITA would design lenses for applications that do
`not involve any large-scale manufacturing, such as an international lens conference:
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`29
`
`29
`
`APPL-1028, 182:3-14 cited in Petitioner Reply at 14.
`
`
`
`(2) Patent Owner does not dispute that the Dr. Sasián's examples
`can in fact be made using diamond turning.
`• Patent Owner does not dispute Dr. Sasián's opinion or the evidence cited in the Reply
`that his examples can be made via diamond turning technology.
`
`•
`
`Instead, Patent Owner only complains
`that diamond turning may take more
`time to produce, which is not a
`limitation in the claims:
`
`• Patent Owner’s expert does not
`dispute that the claims are not limited
`to mass manufacturing or the other
`purposes given by Dr. Sasián:
`
`. . .
`
`Sur-Reply at 13.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`APPL-1028, 185:25-186:19.
`30
`30
`
`
`
`(2) Dr. Sasián’s showed, as referenced in the Reply, that his
`examples can in fact be made using diamond turning.
`
`• Diamond turning technology has been used for decades, can shape edge slope up to
`60 degrees, and can achieve tolerances of 10ths to 100ths of microns.
`
`APPL-1038 at 3 cited in Petitioner Reply at 24.
`
`APPL-1040 at 3 cited in Petitioner Reply at 24.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`APPL-1039 at 11 cited in Petitioner Reply at 24.
`31
`
`31
`
`
`
`(2) Dr. Milster admits that his opinion on “manufacturing” only
`considered injection molding for large-scale production.
`
`APPL-1028, 83:18-25.
`
`APPL-1028, 183:2-7 cited in Petitioner Reply at 9.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
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`32
`
`32
`
`
`
`(3) Dr. Milster admits that none of the claims of the ’277 patent
`recite manufacturing limitations.
`
`• Dr. Mister admitted that manufacturing considerations are not required by any of
`the claims of the ’277 patent:
`
`APPL-1028, 90:13-91:4 cited in Petitioner Reply at 36.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
`
`33
`
`33
`
`
`
`(4) Dr. Milster’s other supposed requirements for manufacturing
`are not even present in the embodiments in the ’277 patent.
`
`APPL-1037 (Declaration in Support of Reply), ¶30 cited in Petitioner Reply at 15.
`
`APPL-1037 at 57
`(showing that Example 1 of the ’277 patent is desensitized).
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
`
`APPL-1037 at 62
`(showing that Example 1 of the ’277 patent suffers from ghost images).
`34
`
`34
`
`
`
`(5) Patent Owner should not be allowed to take inconsistent
`positions on related patents having the exact same disclosure.
`
`• Patent Owner cannot argue that a POSITA would consider manufacturing to preserve
`patentability in this case (the ’277 patent) when it previously argued the exact
`opposite to preserve patentability of a parent patent (the ’568 patent) that relies on the
`exact same disclosure. (see Aylus Networks, Inc. v. Apple Inc., No. 2016-1599 (Fed.
`Cir. 2017).
`
`APPL-1029 (PO Response in IPR2018-00030) at 4
`cited in Petitioner Reply at 11.
`
`APPL-1030 (Moore decl. in IPR2018-00030) ¶ 121
`cited in Petitioner Reply at 12.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
`
`35
`
`35
`
`
`
`(6) Beich’s manufacturing considerations are “quick
`generalizations”, but actual tolerances are much more forgiving.
`
`• The Sur-Reply argues that Beich’s Rules of Thumb Tolerances are required
`for manufacturing Dr. Sasián's examples, but Beich’s rules are only “quick
`generalizations.”
`
`APPL-1007 (Beich) at 7 cited in Petitioner Reply at 13.
`
`DEMONSTRATIVE EXHIBIT — NOT EVIDENCE
`
`36
`
`36
`
`
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