UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`COREPHOTONICS, LTD.,
`Patent Owner.
`____________
`
`Case No. IPR2020-00905, IPR2020-00906
`U.S. Patent No. 10,225,479
`____________
`
`DECLARATION OF DUNCAN MOORE, Ph.D.
`PURSUANT TO 37 C.F.R. § 1.68
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2015
`Page 1
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`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`COREPHOTONICS, LTD.,
`Patent Owner.
`____________
`
`Case No. IPR2020-00905, IPR2020-00906
`U.S. Patent No. 10,225,479
`____________
`
`DECLARATION OF DUNCAN MOORE, Ph.D.
`PURSUANT TO 37 C.F.R. § 1.68
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2015
`Page 1
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`
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`Case No. IPR2020-00905
`U.S. Patent No. 10,225,479
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`TABLE OF CONTENTS
`
`BACKGROUND .................................................................... 1
`I.
`SUMMARY OF OPINIONS ................................................... 2
`II.
`III. EDUCATIONAL AND EMPLOYMENT BACKGROUND ...... 4
`IV. LEVEL OF ORDINARY SKILL IN THE ART (POSITA) ....... 7
`V. RELEVANT LEGAL STANDARDS FOR OBVIOUSNESS ..... 8
`VI. OVERVIEW OF THE ’479 PATENT .................................... 11
`VII. PRIOR ART REFERENCES ................................................. 16
`A.
`Parulski .......................................................................................... 16
`B.
`Kawamura ..................................................................................... 21
`C.
`Ogata ............................................................................................. 35
`VIII. OBVIOUSNESS ................................................................... 41
`A. A POSITA Would Not Have Scaled Kawamura to Use in Parulski
` ....................................................................................................... 41
`1.
` .................................................................................................. 41
`2.
`Aspheric Design with Plastic Elements ................................... 47
`3.
`Design with an Aperture Stop Near the First Lens Element .... 52
`4.
`a Lens with F-Number of 4 ...................................................... 56
`
`Scaling Lens Designs by a Large Factor Is Not Done in Practice
`
`A POSITA Selecting a Lens for Parulski Would Have Used an
`
`A POSITA Selecting a Lens for Parulski Would Have Used a
`
`A POSITA Selecting a Lens for Parulski Would Not Have Used
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`i
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`Case No. IPR2020-00905
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`A POSITA Would Not Have Scaled Ogata to Use in Parulski ..... 58
`B.
`IX. DECLARATION .................................................................. 60
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`
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`ii
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`Case No. IPR2020-00905
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`I.
`
`1.
`
`BACKGROUND
`
`I have been retained as a technical expert by Patent Owner Corepho-
`
`tonics Ltd. (“Patent Owner” or “Corephotonics”) in this proceeding. Corepho-
`
`tonics has asked me to provide my expert opinions concerning certain
`
`technical aspects of imaging lenses and imaging lens design as they relate to
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`the Petitioner Apple Inc.’s petition for inter partes review of U.S. Patent
`
`10,225,479 (“’479 patent”) in Case No. IPR2020-00906 (“-00906 IPR”) and
`
`the accompanying Declaration of José Sasián. In particular, I have been asked
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`to respond to Dr. Sasián’s opinions set forth in his declaration, Ex. 1021, that
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`it would have been obvious to scale the Kawamura and Ogata prior art lens
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`designs to a much smaller size for use with a 1/2.5″ image sensor.
`
`2.
`
`The statements in this declaration summarize my opinions on these
`
`matters based on my over 40 years of experience in the design and develop-
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`ment of imaging lenses for optical systems, my education, knowledge, skills,
`
`and my review and analysis of the materials referenced herein.
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`3.
`
`I am being compensated for my work in this matter at the rate of $425
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`per hour. I am also being reimbursed for reasonable and customary expenses
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`1
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`Case No. IPR2020-00905
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`associated with my work and testimony in this investigation. My compensa-
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`tion is not contingent on the outcome of this matter or the substance of my
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`testimony
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`II. SUMMARY OF OPINIONS
`
`4.
`
`In the preparation of this declaration, I have reviewed:
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`• The ’479 patent (Ex. 1001)
`
`• Prosecution history of the ’479 patent (Ex. 1002)
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`• The declaration of Dr. Fredo Durand (Ex. 1003)
`
`• The curriculum vitae of Dr. Fredo Durand (Ex. 1004)
`
`• U.S. Patent No. 7,859,588 (“Parulski”) (Ex. 1005)
`
`• Japanese Patent Application Publication No. S58-62609 (“Kawa-
`mura”) (Ex. 1012)
`
`• Warren J. Smith, Modern Lens Design (1992) (Ex. 1020)
`
`• The declaration of Dr. José Sasián (Ex. 1021)
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`• ZEMAX Optical Design Program User’s Manual (Ex. 1022)
`
`• U.S. Patent No. 5,546,236 (“Ogata”) (Ex. 1026)
`
`• Specification sheet for Sony ICX629 image sensor (“ICX629”) (Ex.
`1029)
`
`• Specification sheet for Sony ICX624 image sensor (“ICX624”) (Ex.
`1030)
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`2
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`Case No. IPR2020-00905
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`• Robert E. Fischer et al., “Optical System Design” (2008) (Ex. 1035)
`
`• Specification sheet for Sony ICX629 image sensor (“ICX629”)
`
`• Deposition transcript of José Sasián, November 9, 2020 (Ex. 2026)
`
`• José Sasián, Introduction to Lens Design (2019), hardcopy (Ex. 2027)
`
`• Tigran V. Galstian, Smart Mini-Cameras (2014) (Ex. 2028)
`
`• Dmitry Reshidko and Jose Sasián, “Optical analysis of miniature
`lenses with curved imaging surfaces,” Applied Optics, Vol. 54, No.
`28, E216-E223 (October 1, 2015) (Ex. 2029)
`
`• José Sasián, Introduction to Aberrations in Optical Imaging Systems
`(2013), hardcopy (Ex. 2030)
`
`• Yufeng Yan and Jose Sasián, “Miniature Camera Lens Design with a
`Freeform Surface,” Design and Fabrication Congress (2017) (Ex.
`2031)
`
`• Peter Clark, “Mobile platform optical design,” Proc. SPIE 9293, Inter-
`national Optical Design Conference 2017, 92931M (17 December
`2014) (Ex. 2032)
`
`• Jane Bareau and Peter P. Clark, “The Optics of Miniature Digital
`Camera Modules,” SPIE Vol. 6352, International Optical Design Con-
`ference 2006, 63421F. (Ex. 2033)
`
`• Yufeng Yan, “Selected Topics in Novel Optical Design,” Ph.D. Dis-
`sertation (2019) (Ex. 2034)
`
`• Declaration of Dr. José Sasián IPR2020-00489 (Ex. 1003 in that IPR)
`(Ex. 2035)
`
`5.
`
`In forming the opinions set forth herein, I have considered:
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`Case No. IPR2020-00905
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`a. The documents listed above;
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`b. My education, knowledge, skills, and experience in the design and de-
`
`velopment of imaging lenses for optical systems; and
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`c. The level of skill of a person having ordinary skill in the art
`
`(POSITA) at the time of the effective filing dates of the ’479 patent.
`
`6.
`
`It is my professional and expert opinion that a POSITA would not have
`
`been motivated to combine Parulski with Ogata and Kawamura, by scaling
`
`down the Ogata and Kawamura lenses as proposed by Apple and by Dr. Sas-
`
`ián.
`
`III. EDUCATIONAL AND EMPLOYMENT BACKGROUND
`
`7.
`
`As indicated in my Curriculum Vitae, attached as Exhibit 2017, I re-
`
`ceived my Ph. D. in Optics from the University of Rochester in New York in
`
`1974. I also received an M.S. in Optics from the University of Rochester in
`
`1970 and a B.A. in Physics from the University of Maine in 1969.
`
`8.
`
`As further described in my Curriculum Vitae, I am the Rudolf and Hilda
`
`Kingslake Professor of Optical Engineering at the University of Rochester,
`
`and have held that position since 1993. I have been a Professor at The Institute
`
`of Optics at the University of Rochester since 1986, and before that I held the
`
`titles of Assistant Professor and then Associate Professor at The Institute of
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`Optics at the University of Rochester, starting in 1974. I have also served as
`
`Dean of the School of Engineering and Applied Sciences at the University of
`
`Rochester from 1995 to 1997. In all, I have conducted optics research and
`
`taught optics to both undergraduate and graduate students for more than 40
`
`years.
`
`9.
`
`I also have extensive professional experience in the fields of optics and
`
`engineering. I worked for Western Electric Engineering Research Center from
`
`1969–1971 where I was responsible for the design and fabrication of special-
`
`ized lens systems. Beginning in 1971, I performed consulting and design ser-
`
`vices for gradient-index lens systems and conventional lens systems. In 1980,
`
`I founded and became President of the Gradient Lens Corporation. From
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`1997–2000, I was an Associate Director of Technology at the White House
`
`Office of Science and Technology Policy. From 2002–2004, I was President
`
`and Chief Executive Officer of Infotonics Technology Center. My Curriculum
`
`Vitae details various other professional positions I have held in the fields of
`
`optics and engineering over the last 40 years.
`
`10.
`
`I have held several advisory positions, including Special Advisor to the
`
`Director, White House Office of Science and Technology Policy, Executive
`
`Office of the President in 2001 and Senior Science Advisor to the Optical
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`Society of America from 2001 to 2003. I am a Fellow of the Optical Society
`
`of America, the International Society for Optical Engineering (SPIE), Amer-
`
`ican Association for the Advancement of Science, IEEE and the American
`
`Institute for Medical and Biological Engineering for my work in optics. I was
`
`also the Chairman of the Hubble Space Telescope Independent Optical Re-
`
`view Panel for NASA from 1990 to 1991. This committee determined the
`
`correct prescription to repair the Hubble Telescope. I was also the Chairman
`
`of the Product Integrity Team verifying the optics for the future replacement
`
`for the Hubble, the James Webb Telescope – which, unlike the Hubble, will
`
`not be serviceable.
`
`11.
`
`I have been awarded numerous honors over the course of my career
`
`including Election to the National Academy of Engineering (membership
`
`comprising 0.1% of all engineers in the U.S.), Engineer of the Year by Roch-
`
`ester Engineering Society, National Engineering Award from the American
`
`Association of Engineering Societies, Optical Society of America Leadership
`
`Award, the International Society for Optical Engineering (SPIE) Gold Medal,
`
`and the Edwin Land Medal of the Society for Imaging Science and Technol-
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`ogy and the Optical Society of America (OSA).
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`6
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`12.
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`I have authored or co-authored almost 90 publications in the field of
`
`optics, and I was an editor of several books on optics. I have given over 150
`
`presentations on optics. I am an inventor of 18 U.S. patents related to optics.
`
`IV. LEVEL OF ORDINARY SKILL IN THE ART (POSITA)
`
`13.
`
`I understand that in evaluating the validity of the ’479 patent claims,
`
`the content of a patent or printed publication prior art should be interpreted
`
`the way a person of ordinary skill in the art would have interpreted the prior
`
`art as of the effective filing date of the challenged patent.
`
`14.
`
`I understand that factors that may be considered in determining the level
`
`of ordinary skill in the art at the time of the effective filing date of the chal-
`
`lenged patents include: (1) the educational level of the inventor; (2) type of
`
`problems encountered in the art; (3) prior art solutions to those problems; (4)
`
`rapidity with which innovations are made; (5) sophistication of the technol-
`
`ogy; and (6) educational level of active workers in the field.
`
`15.
`
`In my opinion, a person of ordinary skill in the art (POSITA) of the ’479
`
`patent, at the time of the effective filing date, would have possessed an under-
`
`graduate degree in optical engineering, electrical engineering, or physics, with
`
`the equivalent of three years of experience in optical design.
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`16.
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`I understand that the ’479 patent shares a specification with and claims
`
`priority to U.S. App. No. 14/365,711 filed June 16, 2014 and issued as U.S.
`
`Patent No. 9,185,291. (Ex. 1001, ’479 patent at 1:7–29.) I understand that
`
`U.S. App. No. 14/365,711 was a § 371 application from international patent
`
`application PCT/IB2014/062180 filed June 12, 2014 and is related to and
`
`claims priority from U.S. Provision Patent Application No. 61/834,486 filed
`
`June 13, 2013. (Ex. 1001, ’479 patent at 1:7–29.) I therefore understand that
`
`the effective filing date of the ’479 patent is June 13, 2013. However, my
`
`opinions in this declaration would not change if the effective filing date of the
`
`challenged claims were June 2014 instead. I note that Dr. Sasián appears to
`
`have applied the date of June 13, 2013 in his analysis of the level of ordinary
`
`skill as well. (Ex. 1021, ¶ 19.)
`
`V. RELEVANT LEGAL STANDARDS FOR OBVIOUSNESS
`
`17.
`
`I have been informed of the legal standards for establishing patent in-
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`validity in inter partes review proceedings before the Patent Trial and Appeal
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`Board.
`
`18.
`
`I understand that the petitioner must prove invalidity of a patent claim
`
`by a preponderance of the evidence, that is, the evidence must be sufficient to
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`show that a fact or legal conclusion is more likely than not.
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`19.
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`I understand that a claim may be anticipated if (1) the claimed invention
`
`was patented, described in a printed publication, or in public use, on sale, or
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`otherwise available to the public before the effective filing date of the claimed
`
`invention; or (2) the claimed invention was described in a patent or published
`
`application, in which the patent or application names another inventor and was
`
`effectively filed before the effective filing date of the claimed invention.
`
`20.
`
`I understand that, once the claims of a patent have been properly con-
`
`strued, the next step in determining anticipation of a patent claim requires a
`
`comparison of the properly construed claim language to the prior art on a lim-
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`itation-by-limitation basis.
`
`21.
`
`I understand that even if a patent claim is not anticipated, it may still be
`
`invalid if the differences between the claimed subject matter and the prior art
`
`are such that the subject matter as a whole would have been obvious at the
`
`time the invention was made to a person of ordinary skill in the pertinent art.
`
`22.
`
`I also understand that a patent may be rendered obvious based on an
`
`alleged prior art reference or a combination of such references plus what a
`
`person of ordinary skill in the art would understand based on his or her
`
`knowledge and the references. It is also my understanding that in assessing
`
`the obviousness of claimed subject matter one should evaluate obviousness
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`over the prior art from the perspective of one of ordinary skill in the art at the
`
`time the invention was made (and not from the perspective of either a layman
`
`or a genius in that art).
`
`23.
`
`I understand that a patent claim composed of several elements is not
`
`proved obvious merely by demonstrating that each of its elements was known
`
`in the prior art. There must be a reason for combining the elements in the
`
`manner claimed. That is, there must be a showing that a person of ordinary
`
`skill in the art at the time of the invention would have thought of either com-
`
`bining two or more references or modifying a reference to achieve the claimed
`
`invention.
`
`24.
`
`I understand that an obviousness determination includes the considera-
`
`tion of the following factors: (1) the scope and content of the prior art, (2) the
`
`differences between the prior art and the claims at issue, (3) the level of ordi-
`
`nary skill in the art, and (4) objective evidence of nonobviousness.
`
`25.
`
`I understand that the burden is on the petitioner to explain how specific
`
`references could be combined, which combinations of elements in specific
`
`references would yield a predictable result, and how any specific combination
`
`would operate or read on the claims. I further understand that the petitioner
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`cannot rely on conclusory statements but must instead provide a reasoned ex-
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`planation supported by evidence. I also understand that obviousness does not
`
`exist where the prior art discourages or teaches away from the claimed inven-
`
`tion. I also understand that even if a reference does not teach away, its state-
`
`ments regarding preferences are relevant to ta finding whether a person skilled
`
`in the art would be motivated to combine that reference with another refer-
`
`ence.
`
`26.
`
`I understand that it is impermissible to use hindsight to arrive at the
`
`claimed invention. My understanding is that the inventor’s own path never
`
`leads to a conclusion of obviousness. I also understand that, when assessing
`
`whether there was a motivation to combine references to teach a claim ele-
`
`ment, defining the problem in terms of its solution reveals improper hindsight.
`
`27.
`
`I understand that, in this proceeding, prior art to the ’479 patent includes
`
`patents and printed publications in the relevant art that predate the effective
`
`filing date of the ‘479 patent’s challenged claims, which I understand to be
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`June 13, 2013. (Ex. 1001, ’479 patent at 1:7–20.)
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`VI. OVERVIEW OF THE ’479 PATENT
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`28. The ’479 patent is concerned with “thin digital cameras with optical
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`zoom operating in both video and still mode.” (Ex. 1001, ’479 patent at 3:27–
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`28.) As the patent explains, “zoom” is the ability to provide different magni-
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`fications of a given scene, allowing the user to choose between showing more
`
`of the scene in the image or showing a smaller portion of the scene in greater
`
`detail. (Ex. 1001, ’479 patent at 1:44–49.)
`
`29. Traditionally, zoom capability was provided using mechanical optical
`
`zooming, moving lens elements relative to each other to change the focal
`
`length, and thus the magnification of the lens. (Ex. 1001, ’479 patent at 1:49–
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`51.) Mechanical optical zoom lenses are generally more expensive and larger
`
`than fixed focal length lenses. (Ex. 1001, ’479 patent at 1:51–53.) Another
`
`approach to zoom is digital zooming, where a digital processor provides a
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`magnification effect by cropping the image from a fixed focal length lens and
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`interpolating between the pixels to create “a magnified but lower-resolution
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`image.” (Ex. 1001, ’479 patent at 1:58.)
`
`30.
`
` An alternative to both mechanical and traditional digital zoom is de-
`
`scribed in the ’479 patent. In the ’479 patent, an improved digital zoom is
`
`provided using a “dual-aperture” configuration. (Ex. 1001, ’479 patent at
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`3:34–36.) As shown in Figure 1B of the ’479 patent, two compact cameras,
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`one with a wide lens and one with a tele lens are located next to each other:
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`(Ex. 1001, ’479 patent, Figure 1B.) Each of these cameras can be made com-
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`pact and light weight. For example, the largest dimension of each of the two
`
`cameras in the above figure is 8.5 mm, and the height is only 6.8 mm. (Ex.
`
`1001, ’479 patent at 6:63–66.)
`
`31. Building cameras this small that provide acceptable performance pre-
`
`sents challenges, particularly for the telephoto lens, which requires a large
`
`effective focal length (EFL) to provide the required enlarged image. The EFL
`
`determines how well the camera performs at capturing images of small or dis-
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`tant objects, as opposed to closer objects. A lens with a greater EFL is able to
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`capture images of such objects at greater distances and create a magnified
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`image. By increasing the EFL, the field of view (FOV) is narrowed for a fixed
`
`size image sensor. This allows the camera to image things that are further
`
`away, with objects appearing larger because the focal length has changed. If
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`a sensor size stays constant, then the field of view gets smaller. This means,
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`for example, that if the user sees trees farther away, the camera with a longer
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`focal length lens will provide an enlarged image that makes these features
`
`larger. An increase of the focal length reduces the FOV. In a system with two
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`cameras with different fixed focal lengths, each camera has a different FOV
`
`of a given object in the scene. The image with a lower FOV will appear to be
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`“zoomed in.”
`
`32.
`
`Increasing the EFL of a lens tends to require that the lens be made phys-
`
`ically longer. The total track length (TTL) determines how long or thick a
`
`camera will be. The smaller the TTL, the thinner and more compact the cam-
`
`era. In at least some contexts in the lens design field, a lens with a TTL less
`
`than EFL is referred as a “telephoto” lens.
`
`33. The ’479 patent describes two designs for lens assemblies with
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`TTL/EFL ratio less than 1:
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`(Ex. 1001, ’479 patent, Figs. 8 and 9.)
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`34. The -00906 IPR challenges claims 19–22 of the ’479 patent. Claim 19
`
`requires that the tele lens fulfill the condition EFL/TTL > 1. (Ex. 1001, ’479
`
`patent at 15:8–11.) Claims 20–21 adds certain features of the Figure 9 lens
`
`design: “a first lens element with positive power, a second lens element with
`
`negative power, a fourth lens element with negative power and a fifth lens
`
`element, wherein the largest distance between consecutive lens elements
`
`along the optical axis is a distance between the fourth lens element and the
`
`fifth lens element.” (Ex. 1001, ’479 patent at 15:37–42.)
`
`VII. PRIOR ART REFERENCES
`
`A.
`
`Parulski
`
`35. The Parulski patent was published as U.S. Patent No. 7,859,588 and
`
`issued on December 28, 2010. (Ex. 1005.) It was filed on March 9, 2007. (Ex.
`
`1005, Parulski, at 1.) Parulski describes “a digital camera that uses multiple
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`lenses and image sensors to provide an improved imaging capability.” (Ex.
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`1005, Parulski at 1:8–10.) An example of such a camera is shown in Parulski’s
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`Figure 2 (Ex. 1005, Parulski at 8:32–33):
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`36. Another example in Parulski is a camera contained in a mobile phone.
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`Figure 15 of Parulski shows the mobile phone, and Figure 16 shows a camera
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`module for such a mobile phone (Ex. 1005, Parulski at 9:5–10):
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`37. As Dr. Durand and Dr. Sasián note, Parulski refers to the Kodak
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`Easyshare V610 dual lens camera. Ex. 1003, ¶ 48; Ex. 1021, ¶ 38; Ex. 1005
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`at 5:29. The V610 looks generally similar to the camera in Parulski Figure 2.
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`Ex. 1033, Kodak Easyshare V610 manual at 3–4. The V610 utilized a 1/2.5″
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`CCD image sensor with 6.0 megapixels.
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`38. According to Dr. Durand and Dr. Sasián, a POSITA would understand
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`that Parulski would have considered using 1/2.5″ image sensors. Ex. 1003, ¶
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`48; Ex. 1021, ¶ 38. In my opinion, 1/2.5″ image sensors would have been an
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`option for a camera such as the kind shown in Parulski Figure 2. However, for
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`Parulski’s mobile phone camera of Figures 15 and 16, a POSITA would likely
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`have understood that a smaller sensor would have been used.
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`39. As shown in the following table, published in 2014, a camera module
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`using a 1/2.5″ 6 megapixel image sensor would be considered a “miniature
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`camera module,” as would the smaller camera modules likely to be used in
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`Parulski’s mobile phone embodiment:
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`(Ex. 2028, Galstain at 4.)
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`B. Kawamura
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`40. Kawamura was published in 1983 as Japanese Patent Application Pub-
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`lication S58-62609. (Ex. 1012, Kawamura at 1.) It was filed in 1981. (Ex.
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`1012, Kawamura at 1.) The applicant was Asahi Optical Co., a Japanese cam-
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`era manufacturer that sold cameras under the Pentax brand. (Ex. 1012, Kawa-
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`mura at 1.)
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`41. Kawamura describes “a lens of a focal length of about 200 mm for a
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`screen size of 6x7” and provides four examples of such 200 mm focal length
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`lenses. (Ex. 1012, Kawamura at 1, 3–5.) It also refers to the possibility of “a
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`focal length of about 150 mm for a screen size of 4.5x6,” but it does not pro-
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`vide any examples of such a lens. (Ex. 1012, Kawamura at 1.)
`
`42. The Pentax 6x7 was a medium format SLR camera utilizing 120 or 220
`
`roll film.1 The term “medium format” refers to film sizes smaller than the
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`“large format” film used in early studio cameras, but larger than the 35 mm
`
`and smaller films that were once ubiquitous. The 120 film format is over a
`
`century old, having been introduced for use in the Eastman Kodak “Brownie”
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`camera in 1901.2 The nominal width of images on 120 (and 220) film is 56
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`1 https://en.wikipedia.org/wiki/Pentax_6%C3%977
`2 https://en.wikipedia.org/wiki/Brownie_(camera)
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`mm, substantially larger than the 24 mm width of images on “35 mm” 135
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`format film.3 A 6x7 image has a nominal size on the film of 56 mm x 67 mm,
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`and a 4.5x6 image has a nominal size on the film of 56 mm x 41.5 mm.4
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`Therefore, the numbers in “6x7” and “4.5x6” correspond to the approximate
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`film dimensions in centimeters. (Ex. 2026, Sasián Deposition at 42:20–43:20.)
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`43. The Kawamura lens has “a brightness of about 1:4.” (Ex. 1012, Kawa-
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`mura at 1.) Each of the examples in Kawamura actually have a brightness ratio
`
`of 1:4.1. (Ex. 1012, Kawamura at 3–5.) This brightness ratio is another way
`
`of expressing what is commonly called the “f-number.”5 So, the Kawamura
`
`lenses have a f-number of about f/4.1. For a single lens, the f-number is de-
`
`fined as the effective focal length of the lens divided by the diameter of the
`
`entrance pupil. For a single lens with the aperture stop at the lens, the entrance
`
`pupil diameter is simply the diameter of the lens, which determines how much
`
`
`3 https://en.wikipedia.org/wiki/120_film, https://en.wikipedia.org/wiki/135_
`film
`4 https://en.wikipedia.org/wiki/120_film
`5 https://www.kenrockwell.com/tech/lens-specifications.htm (“f/numbers are
`usually expressed as fractions with a slash, like f/5.6, when writing them
`and reading EXIF data. Lenses themselves are often marked with a colon,
`like 1:2.8. It means the same thing.”)
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`light enters the lens. For multi-element lenses, the calculation is more compli-
`
`cated, but it remains true that the entrance pupil diameter determines how
`
`much light travels through the lens system to the sensor. The f number, in turn,
`
`determines how much light reaches each unit of area on the sensor per unit of
`
`time. Smaller f-number lenses form a brighter image at the sensor. As a result,
`
`the f-number affects how long an exposure must be under given light condi-
`
`tions, i.e., how “fast” the lens is. The f-number also affects the depth of field
`
`of an image and the degree of image aberrations.
`
`44. A larger film size means a larger camera and larger lenses. The Pentax
`
`6x7 camera is shown in the following photo6:
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`6 http://camera-wiki.org/wiki/Pentax_67
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`45. The Pentax 6x7 camera body (without lens) was 184 mm (about 7.25
`
`inches) wide and weighed 1.29 kg (almost 3 pounds).7 A lens added further
`
`weight. As this photo shows, the manufacturer made a hand grip to assist the
`
`user in holding and controlling the heavy camera.
`
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`7 http://camera-wiki.org/wiki/Pentax_67
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`46. The following photo shows the Pentax 6x7 camera, together with an
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`Asahi 200 mm, 1:4 brightness lens of the general type described in Kawa-
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`mura8:
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`47. The following photos from an eBay listing shows the same Asahi
`
`1:4/200 6x7 lens and better illustrate its shape and dimensions9:
`
`
`
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`8 http://camera-wiki.org/wiki/Pentax_67
`9 https://www.ebay.com/p/126837639
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`48. According to this eBay listing, the lens has a weight of 8.88 oz.10 This
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`is not surprising given the multiple large glass elements and the need for a
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`large barrel to hold them. While the Asahi lens shown in these photos may not
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`have exactly the same design as described in the Kawamura patent, it is of the
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`same general class of lenses. This further confirms that a camera using a lens
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`of the type described in Kawamura would weigh multiple pounds.
`
`49. The following photo shows a Pentax 4.5x6 camera.11 Note that the lens
`
`in this photo is a 45 mm focal length lens, much shorter than the 150 mm lens
`
`mentioned by Kawamura. While the 4.5x6 camera is narrower than its 6x7
`
`counterpart, it is still a much larger and heavier camera than more typical
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`35 mm cameras.
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`10 https://www.ebay.com/p/126837639
`11 http://camera-wiki.org/wiki/Pentax_645
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`50. Dr. Sasián’s Zemax analysis allows us to confirm how long the lenses
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`disclosed in Kawamura are. The lens that he scaled using Zemax was Kawa-
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`mura’s Example 1 lens. Ex. 1021, ¶ 45; Ex. 1012 at 3. The focal length of the
`
`unmodified lens is given in Kawamura as 200.079 mm. Ex. 1012 at 3. After
`
`scaling in Zemax, the lens had a focal length of 16.330 mm and a total axial
`
`length of 15.343 mm. Ex. 1021 at 26. This shows that Dr. Sasián scaled the
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`Kawamura lens by a factor of 200.08 mm / 16.330 mm = 12.25. The original
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`lens thus had a total axial length of 12.25 × 15.34309 mm = 188 mm, or
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`roughly 7.4 inches, meaning that any camera with the original Kawamura ex-
`
`ample 1 lens attached would be at least 7.4 inches long.
`
`51. Unsurprisingly for a lens of this size in that era, the lens elements are
`
`made of glass. (Ex. 1012, Kawamura at 2–3.) Also to be expected for a lens
`
`from 1981, the lens elements are all spheric, meaning that the front and rear
`
`surfaces of each lens element forms a portion of a sphere, and the shape of
`
`each surface is defined by a single parameter, r, the radius of curvature. (Ex.
`
`1012, Kawamura at 3–9.) The spherical lens shapes are apparent from the cir-
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`cular arc shapes of the surfaces in the cross section drawings, Figures 1, 3, 5,
`
`and 7:
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`(Ex. 1012, Kawamura, Figure 1.)
`
`52. The Kawamura lens is described as an “Ernostar type” lens. (Ex. 1012,
`
`Kawamura at 1.) The first “Ernostar” lens was developed the Ernemann com-
`
`pany in the 1920s.12 In the 1920s, simulation and optimization of lens designs
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`was a laborious, manu
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