`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`COREPHOTONICS, LTD.,
`Patent Owner
`
`_____________________
`
`
`Inter partes review of
`U.S. Patent No. 10,225,479
`_____________________
`
`
`DECLARATION OF JOSÉ SASIÁN, PH.D.,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW
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`
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`Apple v. Corephotonics
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 4 
`I. 
`Qualifications ................................................................................................... 5 
`II. 
`III.  Level of Ordinary Skill in the Art ................................................................. 10 
`IV.  Konno Discloses a Lens Assmebly that would have been adjusted for
`manufacturing ................................................................................................ 12 
`A. 
`Summary of Konno ............................................................................. 12 
`B. 
`A POSITA would have corrected Konno’s Ex2-LN2 lens for
`manufacturing. ..................................................................................... 14 
`V.  A POSITA would have found it obvious to scale Ogata for a 1/2.5” image
`sensor ............................................................................................................. 18 
`1. 
`Summary of Ogata ................................................................... 18 
`2. 
`Scaling Ogata would have been obvious ................................. 20 
`VI.  A POSITA would have found it obvious to scale Kawamura for a 1/2.5”
`image sensor .................................................................................................. 22 
`1. 
`Summary of Kawamura ........................................................... 22 
`2. 
`Scaling Kawamura would have been obvious ......................... 25 
`VII.  Conclusion ..................................................................................................... 27 
`VIII.  Appendix ........................................................................................................ 28 
`A.  Konno’s Example 2 – LN2 (Ex2-LN2) using Zemax (v.02/14/2011) 28 
`1. 
`Fig. 1A – Ray Trace Diagram .................................................. 28 
`2. 
`Fig. 1B - Analysis .................................................................... 29 
`3. 
`Fig. 1C – Prescription Data ..................................................... 30 
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`B. 
`
`C. 
`
`A. 
`
`Konno’s Ex2-LN2 with Overlap Corrected using Zemax
`(v.02/14/2011) ..................................................................................... 31 
`1. 
`Fig. 2A – Ray Trace Diagram .................................................. 31 
`2. 
`Fig. 2B - Analysis .................................................................... 32 
`3. 
`Fig. 2C – Prescription Data ..................................................... 33 
`Fig. 3 - Ogata scaled to fill a 1/2.5” image sensor using Zemax
`(v.02/14/2011) ..................................................................................... 34 
`1. 
`Fig. 3A – Ray Trace Diagram .................................................. 34 
`2. 
`Fig. 3B - Analysis .................................................................... 35 
`3. 
`Fig. 3C – Prescription Data ..................................................... 36 
`Fig. 4 - Kawamura scaled to fill a 1/2.5” image sensor using Zemax
`(v.02/14/2011) ..................................................................................... 37 
`1. 
`Fig. 4A – Ray Trace Diagram .................................................. 37 
`2. 
`Fig. 4B - Analysis .................................................................... 38 
`3. 
`Fig. 4C – Prescription Data ..................................................... 39 
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`INTRODUCTION
`1.
`
`I, José Sasián, have been retained by counsel for Apple Inc. (“Apple”
`
`or “Petitioner”) as a technical expert in connection with the proceeding identified
`
`above. I submit this declaration in support of Apple’s Petition for Inter Partes
`
`Review of U.S. Patent No. 10,225,479 (“the ’479 Patent”).
`
`2.
`
`Compensation for my work in this matter is based on an hourly rate.
`
`In addition, reasonable and customary expenses associated with my work and
`
`testimony in this matter are reimbursed. This compensation is not contingent on the
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`outcome of this matter, nor is it contingent on the specifics of my testimony. I have
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`no personal or financial stake, nor any interest in the outcome of the present
`
`proceeding.
`
`3.
`
`In the preparation of this declaration, I have reviewed:
`
`(1) APPL-1001: The ’479 Patent;
`
`(2) APPL-1005: U.S. Patent No. 7,859,588 to Parulski et al. (“Parulski”);
`
`(3) APPL-1012: JPS5862609A to Kawamura (“Kawamura”);
`
`(4) APPL-1015: JP Pub. No. 2013-106289 to Konno et al. (“Konno”),
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`Certified English translation and Original;
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`(5) APPL-1018: U.S. Patent No. 7,206,136 to Labaziewicz et al.
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`(“Labaziewicz”);
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`(6) APPL-1020: Warren J. Smith, MODERN LENS DESIGN (1992)
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`(“Smith”);
`
`(7) APPL-1022: ZEMAX Development Corporation, ZEMAX Optical
`
`Design Program User’s Manual, February 14, 2011 (“ZEMAX User’s
`
`Manual”);
`
`(8) APPL-1026: U.S. Patent No. 5,546,236 to Ogata et al. (“Ogata”);
`
`(9) APPL-1029: Specification sheet for Sony ICX629 image sensor
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`(“ICX629”);
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`(10) APPL-1030: Specification sheet for Sony ICX624 image sensor
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`(“ICX624”);
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`(11) APPL-1035: Robert E. Fischer et al., OPTICAL SYSTEM DESIGN
`
`(2008), (“Fischer”).
`
`4.
`
`In forming the opinions expressed below, I have considered:
`
`(1) The documents listed above;
`
`(2) References on the face of the ’479 Patent;
`
`(3) Any additional documents discussed below; and
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`(4) My own knowledge and experience based upon my work in the fields
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`of imaging systems as described below.
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`II. QUALIFICATIONS
`5. My complete qualifications and professional experience are described
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`Declaration of José Sasián, Ph.D.
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`in my Curriculum Vitae, a copy of which can be found in APPL-1004. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
`
`6.
`
`As shown in my curriculum vitae (APPL-1004), I have extensive
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`academic and industry experience with optical engineering. Specifically, I have
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`over thirty years of academic and industry experience in the field of optical
`
`sciences and optical engineering in general, including optical instrumentation,
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`optical design, and optical fabrication and testing.
`
`7.
`
`I am currently a full-time, tenured Professor of Optical Sciences at the
`
`College of Optical Sciences at the University of Arizona in Tucson, Arizona, a
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`position I have held since 2002. As a professor, I teach and perform research in the
`
`field of optical design. For example, I teach my students how to design lenses and
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`mirrors and how to think about light so that they can design useful optical systems.
`
`8.
`
`As part of my academic and research responsibilities I am frequently
`
`involved with the design, fabrication, and testing of optical devices. Prior to
`
`receiving tenure, I was an Associate Professor of Optical Sciences at the University
`
`of Arizona from 1995 to 2001. Prior to joining the University of Arizona faculty, I
`
`was a member of the technical staff of AT&T Bell Laboratories from 1990 to
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`1995. From 1984 to 1987, I was a Research Assistant, and from 1988 to 1990, I
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`was a Research Associate, in the Optical Sciences Center at the University of
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`Arizona. From 1976 to 1984, I was an optician at the Institute of Astronomy at the
`
`University of Mexico.
`
`9.
`
`I received a Bachelor of Science degree in Physics from the
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`University of Mexico in 1982, a Master of Science degree in Optical Sciences from
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`the University of Arizona in 1987, and a Ph.D. degree in Optical Sciences from the
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`University of Arizona in 1988. My research areas include optical design,
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`fabrication, and testing of optical instruments, astronomical optics, diffractive
`
`optics, opto-mechanical design, light in gemstones, lithography optics, and light
`
`propagation.
`
`10. At the University of Arizona, I have taught the courses Lens Design
`
`OPTI 517 (1997-present), Introduction to Aberrations OPTI 518 (2005-present),
`
`Advanced Lens Design OPTI 696A (2008, 2012, 2017), Illumination Optics
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`Seminar (1997-2000), Introduction to Opto-mechanics OPTI 690 (1998, 2001,
`
`2003, 2004, 2005) and Optical Shop Practices OPTI 597A (1996-present). I teach
`
`students how to design lens systems, how to grind, polish, and test aspheric
`
`surfaces, how to mount lenses properly so that their physical integrity is preserved,
`
`and how to align lens systems.
`
`11.
`
`I have directed several student reports, theses, and dissertations in the
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`areas of lens and mirror design. I have lectured regarding my work, and have
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`published, along with students and colleagues, over one hundred scientific papers
`
`in the area of optics. These include technical papers, student reports and theses
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`done under my direction, related to miniature lenses. For example:
`
` Yufeng Yan, Jose Sasian, “Miniature camera lens design with a freeform
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`surface,” Proc. SPIE 10590, International Optical Design Conference
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`2017, 1059012 (27 November 2017); doi: 10.1117/12.2292653
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` Dmitry Reshidko, Jose Sasian, “Optical analysis of miniature lenses with
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`curved imaging surfaces,” Appl. Opt. Oct. 54(28):E216-23, 2015.
`
` Sukmock Lee, Byongoh Kim, Jiyeon Lee, and Jose Sasian, “Accurate
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`determination of distortion for smart phone cameras,” Applied Optics,
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`Vol. 53, Issue 29, pp. H1-H6 (2014).
`
` Ying Ting Liu, “Review and Design of a Mobile Phone Camera Lens for
`
`21.4 Mega-Pixels Image Sensor,” M. Sc. Report, University of Arizona,
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`2017.
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` Luxin Nie, “Patent Review of Miniature Camera Lenses,” M. Sc. Report,
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`University of Arizona, 2017.
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` Cheng Kuei-Yeh, “Cell phone zoom lens design and patent research,” M.
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`Sc. Report, University of Arizona, 2010.
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` Rob Bates, “Design for Fabrication: Miniature Camera Lens Case
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`Study,” M. Sc. Report, University of Arizona, 2008.
`
`12. Since 1995, I have been a consultant and have provided to industry
`
`solutions to a variety of projects that include lenses for cell-phones, lenses for
`
`microscopes, and lenses for fast speed photography. I also have consulted in the
`
`area of plastic optics. I hold patents and patent applications related to lens systems.
`
`13.
`
`I have been a topical editor and reviewer for the peer-reviewed
`
`journals Applied Optics and Optical Engineering. I am a fellow of the International
`
`Society for Optics and Photonics (SPIE), a fellow of the Optical Society of
`
`America (OSA), and a lifetime member of the Optical Society of India.
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`14.
`
`I have served as a co-chair for the conferences “Novel Optical
`
`Systems: Design and Optimization” (1997-2006), “Optical systems alignment,
`
`tolerancing, and verification” (2007-2020), and “International Optical Design
`
`Conference,” (2002). I have taught in Japan (2014, 2016, and 2017) the course:
`
`Advanced Lens Design: Art and Science.
`
`15.
`
`I have been a co-editor of approximately 21 published conference
`
`proceedings from SPIE. I am the author of the book, "Introduction to Aberrations
`
`in Optical Imaging Systems," by Cambridge University Press, 2013; and of the
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`book “Introduction to Lens Design.” By Cambridge University Press, 2019. I am
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`named as an inventor on approximately 13 U.S. patents.
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`16. A more detailed summary of my background, experience, and
`
`publications is contained in my CV attached herein.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`17.
`
`I understand that the level of ordinary skill may be reflected by the
`
`prior art of record, and that a Person of Ordinary Skill in The Art (“POSITA”) to
`
`which the claimed subject matter pertains would have the capability of
`
`understanding the scientific and engineering principles applicable to the pertinent
`
`art. I understand that a POSITA has ordinary creativity, and is not an automaton.
`
`18.
`
`I understand that there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
`
`experience of persons working in the field at the time of the invention; (2) the
`
`sophistication of the technology; (3) the types of problems encountered in the field;
`
`and (4) the prior art solutions to those problems.
`
`19.
`
`I am familiar with the lens systems pertinent to the ’479 Patent. I am
`
`also aware of the state of the art at the time the application resulting in the ’479
`
`Patent was filed. I have been informed by counsel to Apple that the earliest
`
`claimed priority date for the ’479 Patent is June 13, 2013, although any given
`
`claim of the ’479 Patent may or may not be entitled to the earliest claimed date.
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`20. Based on the technologies disclosed in the ’479 Patent, I believe that a
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`POSITA would include someone who had, as of the claimed priority date of the
`
`’479 Patent, a bachelor’s or the equivalent degree in electrical and/or computer
`
`engineering or a related field and 2-3 years of experience in imaging systems
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`including image processing and lens design. I believe that a POSITA involved in
`
`lens design would have had additional experience in designing and modifying lens
`
`systems including analyzing, tolerancing, adjusting, and optimizing multi-lens
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`systems with lens design software and would have been familiar with the
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`specifications of lens systems including image sensors. Such as person would
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`have also familiarity with photography and mechanical devices. In addition, I
`
`recognize that someone with less formal education but more experience, or more
`
`formal education but less experience could have also met the relevant standard for
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`a POSITA.
`
`21.
`
`I believe that I am a POSITA regarding the lens design aspects of the
`
`’479 Patent and, furthermore, I have supervised students and engineers who were
`
`also POSITAs in lens system design. Accordingly, I believe that I am qualified to
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`opine from the perspective of a POSITA regarding the lens system aspects of
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`the ’479 Patent and issues discussed below.
`
`22. For purposes of this Declaration, unless otherwise noted, my opinions
`
`and statements, such as those regarding the understanding of a POSITA (and
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`Inter Partes Review of U.S. Patent 10,225,479
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`specifically related to the references I listed above), reflect the knowledge that
`
`existed in the art before the earliest claimed priority date of the ’479 Patent.
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`IV. KONNO DISCLOSES A LENS ASSMEBLY THAT WOULD HAVE
`BEEN ADJUSTED FOR MANUFACTURING
`A.
`Summary of Konno
`23. The Konno reference was published in Japanese, my opinion thus
`
`relies on the certified English translation provided in APPL-1015.
`
`24. Similar to the dual-lens system described in the ’479 patent, Konno
`
`discloses a dual-lens assembly for use in digital equipment including cell phones.
`
`See APPL-1015, Abstract, ¶¶ 12, 25 (“digital equipment such as digital cameras,
`
`mobile phones, and personal digital assistants.”).
`
`25. One dual-lens embodiment that Konno presents is Example 2 which
`
`has an LN1 lens being a wide-angle lens and an LN2 lens being a telephoto lens.
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`APPL-1015, ¶¶7,14. The telephoto LN2 lens system meets the telephoto ratio of
`
`EFL/TTL>1.0. See id., Table 1, ¶40. This is also represented as TTL/EFL<1.0. See
`
`APPL-1020, p.169 (“The ratio L/F [i.e., TTL/EFL] is called the telephoto ratio,
`
`and a lens for which this ratio is less than unity is classified as a telephoto lens.”)
`
`26. An example of Konno’s dual-lens system is provided below:
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`Wide Lens (LN1)
`with Image Sensor
`
`Tele Lens (LN2)
`with Image Sensor
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`
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`
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`Id., Fig. 21 (annotated).
`
`27. The wide (LN1) and telephoto (LN2) lens systems in Konno’s
`
`Example 2 each have fixed focal lengths and include an image sensor for capturing
`
`images that the lens projects onto its respective imaging sensor surface. See id. ¶¶
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`49, 52-53. Each lens system LN1 and LN2 also includes respective focus drive
`
`elements to provide focusing across a range. See id. ¶50 (“the first and second
`
`imaging optical systems LN1 and LN2 have different focus movements in the case
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`of whole feeding”). A POSITA would have understood that with this arrangement,
`
`Konno’s dual-lens system is configured to achieve stereoscopic vision that uses
`
`parallax (i.e., spacing between the two sensors) to provide “three-dimensional
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`vision [that] can be displayed at the focal length fm of the second imaging optical
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`system LN2.” Id. ¶52.
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`28. Optical data for the LN1 and LN2 lenses in Example 2 is provided in
`
`Table 1, reproduced below:
`
`Example 2
`
`
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`Id., Table 1.
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`B. A POSITA would have corrected Konno’s Ex2-LN2 lens for
`manufacturing.
`29. The LN2 lens in Konno’s Example 2 has an error where the fifth lens
`
`from the object side (L5) overlaps the fourth lens (L4) by a small amount:
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`L5
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`L4
`
`Overlap
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`Spacing between the 4th and 5th lenses as specified in Konno
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`
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`See infra Appendix, Fig. 1A (annotated).
`
`30. A POSITA would have understood that one way of correcting this error
`
`is by moving the fifth lens toward the image plane by a small amount, for example,
`
`0.05 mm so that the fifth lenses does not overlap the fourth lens. This is shown in
`
`the diagram below where the fifth lens is moved 0.05 mm to the right, thereby
`
`resolving the overlap:
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`Konno’s Ex2-LN2 embodiment with the fifth lens element
`moved toward the image plane by 0.05 mm to resolve the lens overlap
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`
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`See infra Appendix, Fig. 2A (annotated).
`
`31. Correcting an overlap of two lens elements in a lens design program
`
`by moving one lens by a small amount to fix an overlap is well within the
`
`knowledge and skill level of a POSITA. This type of error is easy to correct using
`
`lens design software and the process described by Fischer. See APPL-1035, p.171-
`
`76. This is also just one routine option that a POSITA would have considered to
`
`correct this kind of error.
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`32. For example, moving the fifth lens in this case by 0.05 mm corrects
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`the overlap in LN2 to provide a working and producible lens design with image
`
`quality that is consistent with LN2’s original specifications, as shown below:
`
`Analysis of corrected version of
`Konno’s Ex2-LN2 embodiment
`
`Analysis of original version of
`Konno’s Ex2-LN2 embodiment
`
`Analysis of corrected version of
`Konno’s Ex2-LN2 embodiment
`
`Analysis of original version of
`Konno’s Ex2-LN2 embodiment
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`
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`
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`See infra Appendix, Figs. 1B, 2B.
`
`33. Based on these plots a POSITA would have understood that the
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`corrected version of LN2 yields performance and image quality consistent with the
`
`original design. Additionally, moving the fifth lens to correct the overlap yields a
`
`lens design that still meets the parameters for the LN2 lens as shown in Konno’s
`
`Table 1. See APPL-1015, ¶76.
`
`34. Thus, a POSITA could have manufactured a usable lens assembly
`
`based on the data that Konno provides for the Ex2-LN2 lens assembly without
`
`excessive experimentation since moving the fifth lens to resolve the overlap is the
`
`only change needed to produce a manufacturable and usable lens assembly. Also,
`
`this is a change that a POSITA would have recognized to simply be the result of
`
`assembling the LN2 lens according to Konno’s parameters as a POSITA would
`
`have naturally positioned the fifth lens to abut the fourth lens when manufactured
`
`since two lenses cannot physically overlap.
`
`V. A POSITA WOULD HAVE FOUND IT OBVIOUS TO SCALE
`OGATA FOR A 1/2.5” IMAGE SENSOR
`
`1.
`Summary of Ogata
`35. Ogata describes “[a] wide-angle photographic lens system comprising
`
`a front lens unit having a positive refractive power, an aperture stop and a rear lens
`
`unit having a positive refractive power or a negative refractive power ….” APPL-
`
`1026, Abstract. Ogata’s photographic lens system “has a short total length (a
`
`length as measured from a first surface to an image side surface of the lens system
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`and … is suited for use with collapsible mount type cameras.” Id. An example of
`
`Ogata’s lens assembly is provided below:
`
`
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`Id., Fig. 1.
`
`36.
`
`In addition to providing a short total length, Ogata asserts that the
`
`benefit of this lens design is that it “a high aperture ratio and excellent optical
`
`performance ….” Id., 3:4-5. A table showing the prescription data for Ogata’s
`
`Embodiment 1 is provided below:
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`Id., 7:35-61.
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`2.
`Scaling Ogata would have been obvious
`37. While Ogata was originally described in reference to a “collapsible
`
`mount type camera” with a 35 mm focal length, a POSITA would have recognized
`
`that, given the prescription data above, the design could be scaled to work in a
`
`smaller format such as to support digital image sensors that were more modern
`
`than when Ogata issued in 1996. See APPL-1020, p.57; APPL-1029; APPL-1030.
`
`According to Smith:
`
`A lens prescription can be scaled to any desired focal
`length simply by multiplying all of its dimensions by the
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`Inter Partes Review of U.S. Patent 10,225,479
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`same constant. All of the linear aberration measures will
`then be scaled by the same factor. Note however, that
`percent distortion, chromatic difference of magnification
`(CDM), the numerical aperture or f number, aberrations
`expressed as angular aberrations, and any other angular
`characteristics remain completely unchanged by scaling.
`
`APPL-1026, p.57.
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`38. For example, a POSITA would have recognized that Ogata could have
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`been successfully scaled for a 1/2.5” image sensor, as would have been compatible
`
`with image sensors that Parulski would have considered for use in its camera
`
`embodiments. See APPL-1005, 5:21-35 (indicating that the Kodak Easyshare V610
`
`is a similar prior art camera); APPL-1033, p.62 (indicating a 1/2.5” CCD image
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`sensor in the V610 camera), APPL-1030 (specification sheet for a prior art 1/2.5”
`
`CCD sensor); APPL-1029(specification sheet for a prior art 1/2.5” CCD sensor).
`
`39. Ogata scaled in this way would have maintained the same field of
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`view (FOVW) of 63.4 degrees and f-number of 2.9 but would have had a lower
`
`focal length (EFL) of 5.72 mm and total track length (TTL) of 6.892 mm as a
`
`result of the scaling. See infra Appendix, Figs. 3A-3C. A POSITA would have
`
`recognized that this could have been done in lens design software such as Zemax,
`
`as indicated in the model of Ogata Embodiment 1 scaled to support a 1/2.5” mm
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`sensor, shown below:
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`See APPL-1022, pp.254-55 (describing the scaling function in Zemax).
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`VI. A POSITA WOULD HAVE FOUND IT OBVIOUS TO SCALE
`KAWAMURA FOR A 1/2.5” IMAGE SENSOR
`
`1.
`Summary of Kawamura
`40. Kawamura is titled “Telephoto Lens” and describes a “telephoto lens of
`
`a four-group, five-lens configuration.” APPL-1012, p.1. Kawamura’s telephoto lens
`
`system is designed to “provide a lens that keeps a compactness of an overall length
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`to a conventional level of a telephoto ratio of about 0.96 to 0.88” and “has an
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`excellent image-formation performance due to favorably correcting spherical
`
`aberration of both a reference wavelength and color” while “decreasing chromatic
`
`aberration in magnification.” Id.
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`41. Kawamura provides several embodiments (Examples 1-4) that each
`
`include five lens elements. See id., p.1, Figs. 1, 3, 6, 8. In each embodiment, the
`
`telephoto lens system includes a four-group, five-lens configuration including:
`
`in order from an object side, a first lens, which is a positive
`meniscus lens that is convex toward the object side; a
`second lens and a third lens, which are a laminated positive
`meniscus lens of a negative meniscus lens and positive
`meniscus lens having a lamination surface that is convex
`toward the object side; a fourth lens, which is a negative
`lens having a rear surface with a large curvature that is
`concave toward an image-surface side; and a fifth lens,
`which is a positive lens.
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`Id.
`
`42. For Examples 1-4, Kawamura provides figures and a prescription table
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`including numerical values for the design. As an example, FIG. 1 and corresponding
`
`table of example 1 are reproduced below:
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`Id., Fig. 1.
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`
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`Id., p.3 (Table for Example 1).
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`Inter Partes Review of U.S. Patent 10,225,479
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`2.
`Scaling Kawamura would have been obvious
`43. While Kawamura was originally described in reference to a 150-200
`
`mm focal length (see APPL-1012, p.1), a POSITA would have recognized that,
`
`given the prescription data above, the design could have been scaled to work in a
`
`smaller format such as to support digital image sensors that were more modern
`
`than when Kawamura published in 1983. See APPL-1020, p.57; APPL-1029;
`
`APPL-1030. According to Smith:
`
`A lens prescription can be scaled to any desired focal
`length simply by multiplying all of its dimensions by the
`same constant. All of the linear aberration measures will
`then be scaled by the same factor. Note however, that
`percent distortion, chromatic difference of magnification
`(CDM), the numerical aperture or f number, aberrations
`expressed as angular aberrations, and any other angular
`characteristics remain completely unchanged by scaling.
`
`APPL-1026, p.57.
`
`
`44. For example, a POSITA would have recognized that Kawamura could
`
`be successfully scaled for a 1/2.5” image sensor, as would have been compatible
`
`with image sensors that Parulski would have considered for use in its camera
`
`embodiments. See APPL-1005, 5:21-35 (indicating that the Kodak Easyshare V610
`
`is a similar prior art camera); APPL-1033, p.62 (indicating a 1/2.5” CCD image
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`Inter Partes Review of U.S. Patent 10,225,479
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`sensor in the V610 camera), APPL-1030 (specification sheet for a prior art 1/2.5”
`
`CCD sensor); APPL-1029(specification sheet for a prior art 1/2.5” CCD sensor).
`
`45. Kawamura scaled in this way would have maintained the same field
`
`of view (FOVW) of 24.3 degrees and f-number of 4.0 but would have had a lower
`
`focal length (EFL) of 16.33 mm and total track length (TTL) of 15.343 mm as a
`
`result of the scaling. A POSITA would have recognized that this could have been
`
`done in lens design software such as Zemax, as indicated in the model of
`
`Kawamura Example 1 scaled to support a 1/2.5” mm sensor, shown below:
`
`See APPL-1022, pp.254-55 (describing the scaling function in Zemax).
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`VII. CONCLUSION
`
`46.
`
`I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on information
`
`and belief are believed to be true. I understand that willful false statements are
`
`punishable by fine or imprisonment or both. See 18 U.S.C. § 1001.
`
`Date: May 5, 2020
`
`Respectfully submitted,
`
`José Sasián, Ph.D.
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`Inter Partes Review of U.S. Patent 10,225,479
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`VIII. APPENDIX
`A. Konno’s Example 2 – LN2 (Ex2-LN2) using Zemax (v.02/14/2011)
`
`1.
`
`Fig. 1A – Ray Trace Diagram
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`2.
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`Fig. 1B - Analysis
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`3.
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`Fig. 1C – Prescription Data
`
`*Aspheric data as provided in Konno (APPL-1015) ¶75.
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`Inter Partes Review of U.S. Patent 10,225,479
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`B. Konno’s Ex2-LN2 with Overlap Corrected using Zemax
`(v.02/14/2011)
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`1.
`
`Fig. 2A – Ray Trace Diagram
`
`
`
`Spacing between the 4th and 5th lenses increased by 0.05 mm to correct overlap.
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`2.
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`Fig. 2B - Analysis
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`Inter Partes Review of U.S. Patent 10,225,479
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`3.
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`Fig. 2C – Prescription Data
`
`*Aspheric data as provided in Konno (APPL-1015) ¶75.
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`Inter Partes Review of U.S. Patent 10,225,479
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`C.
`
`Fig. 3 - Ogata scaled to fill a 1/2.5” image sensor using Zemax
`(v.02/14/2011)
`
`1.
`
`Fig. 3A – Ray Trace Diagram
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`
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`Inter Partes Review of U.S. Patent 10,225,479
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`2.
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`Fig. 3B - Analysis
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`Inter Partes Review of U.S. Patent 10,225,479
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`3.
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`Fig. 3C – Prescription Data
`
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`Declaration of José Sasián, Ph.D.
`Inter Partes Review of U.S. Patent 10,225,479
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`A.
`
`Fig. 4 - Kawamura scaled to fill a 1/2.5” image sensor using
`Zemax (v.02/14/2011)
`
`1.
`
`Fig. 4A – Ray Trace Diagram
`
`
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`Inter Partes Review of U.S. Patent 10,225,479
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`2.
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`Fig. 4B - Analysis
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`Declaration of José Sasián,