Declaration for Inter Partes Review of USP 7,573,068
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Inter Partes Review of:
`U.S. Patent No. 7,573,068
`Issued: August 11, 2009
`Application No.: 11/391,941
`
`)
`)
`)
`)
`)
`
`For: Transistor Array Substrate And Display Panel
`
`DECLARATION OF MILTIADIS HATALIS, PH.D. IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,573,068
`
`LG Display Co., Ltd.
`Exhibit 1003
`Page 001
`
`

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`Declaration for Inter Partes Review of USP 7,573,068
`
`CONTENTS
`I.
`INTRODUCTION ........................................................................................... 1
`BACKGROUND AND QUALIFICATIONS ................................................. 1
`II.
`III. DOCUMENTS CONSIDERED IN FORMING MY OPINIONS .................. 8
`IV. UNDERSTANDING OF LEGAL PRINCIPLES ........................................... 9
`BACKGROUND ........................................................................................... 15
`V.
`Overview of the ’068 Patent (Ex. 1001) ............................................. 15
`A.
`B.
`The Challenged Claims ....................................................................... 32
`C.
`Prosecution History ............................................................................. 34
`VI. CLAIM CONSTRUCTION .......................................................................... 34
`VII. GROUND 1: CLAIMS 1, 5, 10, 11 AND 13 ARE ANTICIPATED
`BY SHIN ....................................................................................................... 37
`A.
`Overview – Shin (Ex. 1005) ................................................................ 37
`B.
`Independent Claim 1 Is Anticipated By Shin ...................................... 52
`1.
`[1pre]—“1. A transistor array substrate comprising:” .............. 53
`[1a]—“a substrate” .................................................................... 58
`2.
`3.
`[1b]—“a plurality of driving transistors which are
`arrayed in a matrix on the substrate, each of the driving
`transistors having a gate, a source, and a drain, and a gate
`insulating film inserted between the gate, and the source
`and drain;” ................................................................................. 58
`[1c]—“a plurality of signal lines which are patterned
`together with the gates of said plurality of driving
`transistors and arrayed to run in a predetermined
`direction on the substrate” ........................................................ 69
`
`4.
`
`i
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 002
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`Declaration for Inter Partes Review of USP 7,573,068
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`5.
`
`6.
`
`C.
`
`[1d]—“a plurality of supply lines which are patterned
`together with the sources and drains of said plurality of
`driving transistors and arrayed to cross said plurality of
`signal lines via the gate insulating film, one of the source
`and the drain of each of the driving transistors being
`electrically connected to the supply lines” ............................... 77
`[1e]—“a plurality of feed interconnections which are
`formed on said plurality of supply lines along said
`plurality of supply lines, respectively.” .................................... 97
`Independent Claim 13 Is Anticipated By Shin .................................. 111
`1.
`[13pre]—“A display panel comprising:” ................................ 111
`2.
`Elements [13a]-[13d] are disclosed for the same reasons
`as [1a]-[1d] .............................................................................. 112
`[13e]—“a plurality of feed interconnections which are
`connected to said plurality of supply lines along said
`plurality of supply lines;” ........................................................ 112
`[13f]—“a plurality of pixel electrodes each of which is
`electrically connected to the other of the source and the
`drain of a corresponding one of said plurality of driving
`transistors;” ............................................................................. 114
`[13g]—“a plurality of light-emitting layers which are
`formed on said plurality of pixel electrodes, respectively;
`and” ......................................................................................... 121
`[13h]—“a counter electrode which covers said plurality
`of light-emitting layers.” ......................................................... 123
`Dependent Claims 5, 10, and 11 Are Anticipated By Shin .............. 125
`1.
`Claim 5 .................................................................................... 125
`2.
`Claim 10 .................................................................................. 130
`Claim 11 .................................................................................. 130
`3.
`VIII. GROUND 2: CLAIM 13 IS OBVIOUS IN VIEW OF SHIN .................... 131
`IX. GROUND 3: CLAIMS 1, 5, 9-13 AND 17 ARE UNPATENTABLE
`OVER SHIN AND HECTOR ..................................................................... 135
`A.
`Overview – Hector (Ex. 1006) .......................................................... 136
`
`D.
`
`3.
`
`4.
`
`5.
`
`6.
`
`ii
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 003
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`Declaration for Inter Partes Review of USP 7,573,068
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`B.
`
`Independent Claims 1 And 13 Are Unpatentable Over Shin And
`Hector ................................................................................................ 140
`1.
`[1e]—“a plurality of feed interconnections which are
`formed on said plurality of supply lines along said
`plurality of supply lines, respectively.” / [13e] “a
`plurality of feed interconnections which are connected to
`said plurality of supply lines along said plurality of
`supply lines;” ........................................................................... 140
`C. Motivations To Combine Shin And Hector ...................................... 150
`D. Dependent Claims 5, 9-12, And 17 Are Unpatentable Over Shin
`And Hector ........................................................................................ 164
`1.
`Claim 5 .................................................................................... 164
`2.
`Claim 9 .................................................................................... 165
`3.
`Claim 10 .................................................................................. 166
`4.
`Claim 11 .................................................................................. 167
`5.
`Claims 12 and 17..................................................................... 168
`a.
`[12a]—“a plurality of light-emitting elements each
`of which has a pixel electrode, an EL layer, and a
`counter electrode and is electrically connected to a
`corresponding one of the driving transistors,” ............. 168
`[12b]/[17]—“wherein the feed interconnections are
`formed by patterning a material film which is
`different from a material film serving as a
`prospective pixel electrode and a material film
`serving as a prospective counter electrode and
`which is thicker than the gates of the driving
`transistors and the sources and drains of the
`driving transistors” ....................................................... 169
`CONCLUSION ............................................................................................ 177
`
`b.
`
`X.
`
`
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`iii
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 004
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`Declaration for Inter Partes Review of USP 7,573,068
`
`I.
`
`INTRODUCTION
`1.
`I have been retained as an independent expert witness on behalf of LG
`
`Display Co., Ltd. (“LG Display” or “Petitioner”) in the above-captioned inter partes
`
`review (“IPR”) relating to U.S. Patent No. 7,573,068 (“’068 patent”) (Ex. 1001).
`
`2.
`
`I understand that LG Display is petitioning for IPR of claims 1, 5, 9-13,
`
`and 17 of the ’068 patent and requests that the United States Patent and Trademark
`
`Office (“PTO”) cancel those claims.
`
`3.
`
`In preparing this Declaration, I have reviewed the ’068 patent, and
`
`considered the documents identified in Section III in light of the general knowledge
`
`in the relevant art. In forming my opinions, I relied upon my education, knowledge,
`
`and experience, and considered the level of ordinary skill in the art as discussed
`
`below.
`
`4.
`
`I am being compensated for my work in this matter at my standard
`
`consulting rate, which is $400 per hour, plus actual expenses. My compensation is
`
`not dependent in any way upon the outcome of this matter.
`
`II. BACKGROUND AND QUALIFICATIONS
`5. My complete qualifications and professional experience are described
`
`in my academic curriculum vitae, a copy of which is provided as Exhibit 1004. The
`
`following is a brief summary of my relevant qualifications and professional
`
`experience.
`
`1
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 005
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`Declaration for Inter Partes Review of USP 7,573,068
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`6.
`
`I am currently a Professor in the Department of Electrical and Computer
`
`Engineering at Lehigh University. I hold a B.S. degree in physics from Aristotle
`
`University, Greece, an M.S. degree in electrical engineering from SUNY Buffalo,
`
`and a Ph.D. (1987) in electrical engineering from Carnegie Mellon University. In
`
`1987, I joined Lehigh University as an assistant professor in the Department of
`
`Electrical & Computer Engineering. I served as an associate professor at Lehigh
`
`University from 1991 to 1995, and have been a full professor at Lehigh University
`
`since 1995. From 1988 to 1993, I served as associate director of the
`
`Microelectronics Research Laboratory at Lehigh University. Since 1992, I have
`
`served as director of the Display Research Laboratory at Lehigh University. From
`
`2010 to 2013, I served as interim director of the Sherman Fairchild Center for Solid
`
`State Studies at Lehigh University. From 2003 to 2008, I concurrently served as
`
`professor in the Department of Computer Science at Aristotle University, Greece.
`
`7.
`
`From 1987 to 2015, I also worked as an independent consultant for a
`
`number of major technology companies in the flat panel display and semiconductor
`
`field, including IBM, Kodak, Sharp and Motorola Solutions. In 1992, I was a
`
`visiting scientist at XEROX Palo Alto Research Laboratory.
`
`8.
`
`As discussed below, my technical expertise is in flat panel display
`
`technologies, including thin film transistor (“TFT”) and active-matrix organic light-
`
`emitting diode (“AMOLED”) technologies.
`
`2
`
`LG Display Co., Ltd.
`Exhibit 1003
`Page 006
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`

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`Declaration for Inter Partes Review of USP 7,573,068
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`9.
`
`I am the author or co-author of 180 technical publications including
`
`three issued patents, and two book chapters, including one on AMOLED pixel
`
`electronic circuits and one on polysilicon TFT technology. As of this writing, I have
`
`a total of 4,148 citations and my h-index is 28 according to Google Scholar.
`
`10.
`
`In 1992, I founded, and became Director of, the “Display Research
`
`Laboratory,” which was the first academic laboratory in the United States dedicated
`
`to research and development of electronic thin film materials and devices, including
`
`thin film transistors, for flat panel displays, flexible electronics and novel large area
`
`microelectronic system applications. As Director of Lehigh’s Display Research
`
`Laboratory, I have raised over $13 million through research contracts and grants to
`
`support the laboratory's research activities. These contracts and grants were funded
`
`by the Defense Advanced Research Program Agency (DARPA), the Army Research
`
`Laboratory (ARL), the National Science Foundation (NSF), the National
`
`Aeronautics and Space Administration (NASA), the State of Pennsylvania, and a
`
`variety of industrial companies including Corning, IBM, Kodak, Sharp, Northrop
`
`Grumman, and others.
`
`11. From 1987 to present I have conducted research in microelectronics,
`
`including semiconductors, electronic materials, devices and circuits for integrated
`
`circuits and integrated microsystems. My research mainly focuses on electronic thin
`
`film materials and devices, microelectronic fabrication processes, novel electronic
`
`3
`
`LG Display Co., Ltd.
`Exhibit 1003
`Page 007
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`Declaration for Inter Partes Review of USP 7,573,068
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`circuits, and integrated microsystems.
`
` My research group pioneered the
`
`development of electronic materials, devices, and circuits on flexible substrates,
`
`active matrix organic light emitting diode displays, and addressable arrays for
`
`integrated sensor applications such as fingerprint sensors for biometrics and
`
`multichannel gas sensors.
`
`12. As a faculty member, I supervised the research of twenty Ph.D.
`
`dissertations in the technical field of semiconductors/microelectronics. Upon
`
`graduating, all twenty of my Ph.D. graduate students moved either to industrial
`
`positions in the electronic or flat panel display industry, including positions at Apple,
`
`IBM, Intel, Sharp, TSMC, and Motorola, or into academic positions in the United
`
`States or abroad. I have also supervised the research of several post-doctoral
`
`researchers and research associates at Lehigh. Moreover, I have supervised a large
`
`number of graduate student Master’s theses and numerous undergraduate research
`
`projects. I have been an invited lecturer at numerous universities, industrial
`
`laboratories, and conferences in the United States and overseas.
`
`13. The list of peer-reviewed journals in which my papers were published
`
`include Thin Solid Films, Journal of the Electrochemical Society, Solid State
`
`Electronics, Journal of Applied Physics, Journal of the Society for Information
`
`Display, Journal of Materials Science, and multiple IEEE journals including the
`
`IEEE Journal of Display Technology, IEEE Transactions on Electronic Devices,
`
`4
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 008
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`Declaration for Inter Partes Review of USP 7,573,068
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`IEEE Solid State Circuits, and IEEE Electron Device Letters. The technical
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`conferences where my papers were presented have been organized by scientific
`
`societies including: Society of Information Display (SID), Materials Research
`
`Society (MRS), Electrochemical Society (ECS), and Institute of Electrical and
`
`Electronics Engineers (IEEE).
`
`14.
`
`I am also a named inventor on U.S. Patent No. 8,390,536, directed at
`
`controlling current to pixels in an active matrix display by adjusting voltage on the
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`data lines and two international patents associated with the above invention, one
`
`issued in Korea and one in Japan.
`
`15.
`
`I have taught a number of different undergraduate and graduate level
`
`courses in the Electrical and Computer Engineering department at Lehigh
`
`University. These courses have generally centered on physics, technology, and the
`
`design and fabrication of solid-state devices and integrated circuits. I have also
`
`introduced several new courses which include “Introduction to VLSI Design,”
`
`“Semiconductor Material and Device Characterization,” and “Introduction to
`
`Photovoltaic Energy Systems.” I also regularly teach the “Principles of Electrical
`
`Engineering,” “Introduction to Computer Engineering,” “Electronic Circuits,” and
`
`“Introduction to VLSI Circuits” courses.
`
`16. As part of my research, I utilize much of the same equipment and many
`
`of the same microfabrication processes that are in use by the semiconductor or flat
`
`5
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 009
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`Declaration for Inter Partes Review of USP 7,573,068
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`panel display industry including: Plasma-Enhanced Chemical Vapor Deposition
`
`(PECVD) for the deposition of amorphous silicon, silicon nitride and silicon dioxide
`
`films; sputter and e-beam deposition tools for aluminum, copper, nickel tungsten,
`
`titanium, gold, tantalum, and other metallic thin films; photolithographic tools for
`
`defining photoresist patterns on the substrates; as well as reactive ion etching or wet
`
`etching tools for removing various thin film materials from the substrates. I also
`
`utilize several tools for the characterization of the materials and structures used in
`
`microelectronic devices
`
`including: optical microscopes, Scanning Electron
`
`Microscopy (SEM), Transmission Electron Microscopy (TEM), and Atomic Force
`
`Microscopy (AFM). I further utilize a variety of electrical characterization
`
`techniques and instruments for testing the electrical performance of completed
`
`electronic circuits and systems.
`
`17. As part of my research, I pioneered a technique for crystallizing
`
`amorphous silicon. Similar techniques have been used in the manufacturing of
`
`integrated circuits and flat panel displays. In addition, my research group at Lehigh
`
`pioneered the fabrication of electronic devices and circuits on novel flexible
`
`substrates and the development of integrated microsystems on flexible substrates,
`
`including active matrix organic light emitting diode displays, and addressable arrays
`
`for integrated sensor applications such as fingerprint sensors for biometrics and
`
`multichannel gas sensors. Many industrial and academic laboratories currently
`
`6
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 010
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`Declaration for Inter Partes Review of USP 7,573,068
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`pursue similar research activities; such research flows from the accomplishments of
`
`my research group in this technical field.
`
`18. My industrial experience includes work at the XEROX Palo Alto
`
`Research Laboratory and various consulting projects with companies in the flat-
`
`panel display or semiconductor technical fields. Those projects related to electronic
`
`materials, semiconductor devices and their application to microelectronic systems.
`
`19.
`
`I am a member of several professional organizations including the
`
`Electron Device Society of the IEEE and the SID. I have also been the chair or
`
`co-chair at numerous national and international conferences and symposiums,
`
`including several SID-sponsored Workshops on Active Matrix Liquid Crystal
`
`Displays and a Materials Research Society Symposium on Flat Panel Displays. I
`
`have co-authored two book chapters, one dealing with the “Polysilicon TFT
`
`Technology” and another on the application of “Polysilicon TFTs in AMOLED
`
`Displays.” I have served as a reviewer for technical papers submitted to several
`
`scientific journals and have also served as a reviewer for several years for the
`
`National Science Foundation Small Business Innovative Research (SBIR) program.
`
`20. A detailed list of my publications, education and professional
`
`experience, research grants, Ph.D. dissertations for which I served as advisor,
`
`publications, and litigation cases in which I served as a technical expert, can be found
`
`in my curriculum vitae attached and submitted as Exhibit 1004.
`
`7
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 011
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`Declaration for Inter Partes Review of USP 7,573,068
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`III. DOCUMENTS CONSIDERED IN FORMING MY OPINIONS
`21.
`In addition to the information identified above (e.g., ¶¶ 3, 5-20) and
`
`elsewhere in this Declaration, in forming my opinions, I have considered the
`
`following documents:
`
`Description
`Ex. No.
`1001 U.S. Patent No. 7,573,068 (“’068 patent”)
`
`1002 Prosecution history for U.S. Patent Application No. 11/232,368 (“’068
`FH”)
`
`1005
`
`International Patent Publication No. WO 2004/090853 (“Shin”)
`
`1006
`
`International Patent Publication No. WO 03/079442 (“Hector”)
`
`1007 Thin Film Transistors, Materials and Processes, Volume 2:
`Polycrystalline Silicon Thin Film Transistors (Yue Kuo ed., 2004)
`(excerpts) (“Kuo”)
`
`1008 Solas’s Opening Claim Construction Brief, Solas OLED Ltd. v. LG
`Display Co., Ltd., et al., Case No. 6:19-cv-00236-ADA, Dkt. 68 (W.D.
`Tex. Mar. 13, 2020) (“Solas’s Op. Claim Construction Br.”)
`
`1009 Defendants’ Opening Claim Construction Brief, Solas OLED Ltd. v.
`LG Display Co., Ltd., et al., Case No. 6:19-cv-00236-ADA, Dkt. 67
`(W.D. Tex. Mar. 13, 2020) (“Defendants’ Op. Claim Construction
`Br.”)
`
`1010 Claim Construction Order, Solas OLED Ltd. v. LG Display Co., Ltd., et
`al., Case No. 6:19-cv-00236-ADA, Dkt. 82 (W.D. Tex. June 9, 2020)
`(“Markman Order”)
`
`1011 RESERVED
`
`1012
`
`Joint Revised List of Terms/Constructions, Solas OLED Ltd. v. LG
`Display Co., Ltd., et al., Case No. 6:19-cv-00236-ADA, Dkt. 67-28
`(W.D. Tex. Mar. 13, 2020) (“Parties’ Exchange of Constructions”)
`
`8
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 012
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`Declaration for Inter Partes Review of USP 7,573,068
`
`Ex. No.
`Description
`1013 Defendants LG Display Co., Ltd., LG Electronics, Inc. and Sony
`Corporation’s Invalidity Contentions, Solas OLED Ltd. v. LG Display
`Co., Ltd., et al., Case No. 6:19-cv-00236-ADA (W.D. Tex. Jan. 24,
`2020)
`
`1014 U.S. Patent No. 6,724,149 (“Komiya”)
`
`1015 U.S. Patent No. 6,281,552 (“Kawasaki”)
`
`1016 U.S. Patent No. 7,115,956 (“Nakamura”)
`
`1017 U.S. Patent Application Publication No. 2004/0113873 (“Shirasaki”)
`
`1018 Raymond A. Serway, Principles of Physics (1998) (excerpts)
`(“Serway”)
`
`1019 U.K. Patent Application No. GB 2,389,952 (“Routley”)
`
`1020 U.S. Patent No. 6,809,706 (“Shimoda”)
`
`1021 U.S. Patent Application Publication No. 2002/0101172 (“Bu”)
`
`
`
`IV. UNDERSTANDING OF LEGAL PRINCIPLES
`22.
`I understand that a prior art reference can anticipate a patent claim when
`
`the prior art’s disclosure renders the recited claim elements not novel. I understand
`
`that in order to anticipate a patent claim, a prior art reference must teach each and
`
`every element of the claim, expressly or inherently, with the same arrangement as in
`
`the claims. I understand that a reference anticipates a claim if it discloses the claimed
`
`invention such that a POSITA could take its teachings in combination with his/her
`
`own knowledge of the particular art and be in the possession of the invention.
`
`9
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 013
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`Declaration for Inter Partes Review of USP 7,573,068
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`23.
`
`In analyzing anticipation, I understand that it is important to consider
`
`the scope of the claims, the level of skill in the relevant art, and the scope and content
`
`of the prior art. I understand that extrinsic evidence may be considered for
`
`anticipation so long as it is used to explain, but not expand, the meaning of the
`
`reference.
`
`24.
`
`I understand that a prior art reference can render a patent claim obvious
`
`to one of ordinary skill in the art if the differences between the subject matter set
`
`forth in the patent claim and the prior art are such that the subject matter of the claim
`
`would have been obvious at the time the claimed invention was made.
`
`25.
`
`In analyzing obviousness, I understand that it is important to consider
`
`the scope of the claims, the level of skill in the relevant art, the scope and content of
`
`the prior art, the differences between the prior art and the claims, and any secondary
`
`considerations.
`
`26.
`
`I understand that when the claimed subject matter involves combining
`
`pre-existing elements to yield no more than what one would expect from such an
`
`arrangement, the combination is obvious. I also understand that in assessing whether
`
`a claim is obvious one must consider whether the claimed improvement is more than
`
`the predictable use of prior art elements according to their established functions. I
`
`understand that there need not be a precise teaching in the prior art directed to the
`
`specific subject matter of a claim because one can take account of the inferences and
`
`10
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 014
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`Declaration for Inter Partes Review of USP 7,573,068
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`creative steps that a person of skill in the art would employ. I further understand
`
`that a person of ordinary skill is a person of ordinary creativity, not an automaton.
`
`27.
`
`I understand that obviousness cannot be based on the hindsight
`
`combination of components selectively culled from the prior art. I understand that
`
`in an obviousness analysis, neither the motivation nor the avowed purpose of the
`
`inventors controls the inquiry. Any need or problem known in the field at the time
`
`of the invention and addressed by the patent can provide a reason for combining
`
`elements. For example, I understand that it is important to consider whether there
`
`existed at the time of the invention a known problem for which there was an obvious
`
`solution encompassed by the patent’s claims. I understand that known techniques
`
`can have obvious uses beyond their primary purposes, and that in many cases a
`
`person of ordinary skill can fit the teachings of multiple pieces of prior art together
`
`like pieces of a puzzle.
`
`28.
`
`I understand that, when there is a reason to solve a problem and there
`
`is a finite number of identified, predictable solutions, a person of ordinary skill has
`
`good reason to pursue the known options within his or her technical grasp. I further
`
`understand that, if this leads to the anticipated success, it is likely the product not of
`
`innovation but of ordinary skill and common sense, which bears on whether the
`
`claim would have been obvious.
`
`11
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`LG Display Co., Ltd.
`Exhibit 1003
`Page 015
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`Declaration for Inter Partes Review of USP 7,573,068
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`29.
`
`I understand that secondary considerations can include, for example,
`
`evidence of commercial success of the invention, evidence of a long-felt need that
`
`was solved by an invention, evidence that others copied an invention, or evidence
`
`that an invention achieved a surprising or unexpected result. I further understand
`
`that such evidence must have a nexus, or causal relationship to the elements of a
`
`claim, in order to be relevant. I am unaware of any such secondary considerations
`
`for the ’068 patent.
`
`30.
`
`I understand that patent claims can, in general, recite a numerical range.
`
`However, if the patent claim recites a numerical range that is broader than a prior
`
`art’s disclosure, the prior art is found to disclose and anticipate the claimed range of
`
`the invention. I also understand that if the claimed numerical range overlaps with or
`
`lies within the ranges disclosed by the prior art, then the prior art establishes a
`
`presumption, or “prima facie case,” of obviousness.
`
`31.
`
`I understand that once prima facie obviousness is established in the
`
`prior art, the burden to prove that the claimed range is non-obvious is on the patentee.
`
`For example, a claimed range may be non-obvious if the patentee shows that it is
`
`directed to a “critical range” that produces surprising or unexpected results. On the
`
`other hand, when variables were known in the art to be result-effective, i.e., that it
`
`was known that a property is affected by the variable, then it is not inventive to
`
`discover the optimum or workable ranges by routine experimentation. This is
`
`12
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`Page 016
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`Declaration for Inter Partes Review of USP 7,573,068
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`because the optimization of variables is expected to be within the grasp of one of
`
`ordinary skill in the art, and the normal desire of scientists or artisans to improve
`
`upon what is already generally known provides the motivation to determine the
`
`correct dimensions from within a range are the optimal dimensions. A claimed range
`
`may also be non-obvious if the prior art taught away from that range.
`
`32.
`
`I understand that a person of ordinary skill in the art (“POSITA”) is a
`
`hypothetical person who is presumed to be aware of all pertinent art, possesses
`
`conventional wisdom in the art, is a person of ordinary creativity, and has common
`
`sense. I understand that this hypothetical person is considered to have the normal
`
`skills and knowledge of a person in a certain technical field (including knowledge
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`of known problems and desired features in the field).
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`33.
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`I have been asked to analyze claims 1, 5, 9-13, and 17 of the ’068 patent,
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`and prior art relating thereto, from the perspective of such a person at the time of the
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`alleged inventions. I have been informed by counsel to assume that this is in the
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`2004 time frame. I will refer to this time as the “relevant time” or similar herein.
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`34.
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`I understand that the factors that may be considered in determining the
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`level of ordinary skill in the art may include (a) the type of problems encountered in
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`the art, (b) prior art solutions to those problems, (c) the rapidity with which
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`innovations are made, (d) sophistication of the technology, and (e) the educational
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`Declaration for Inter Partes Review of USP 7,573,068
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`level of active workers in the field. I also understand that in a given case, every
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`factor may not be present, and one or more factors may predominate.
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`35. Based on my review of these factors, the prior art described below and
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`my personal experience in the field, it is my opinion that the level of ordinary skill
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`in the art for the ’068 patent at the relevant time (2004) would have had at least a
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`bachelor’s degree in electrical engineering (or equivalent) and at least two years’
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`industry experience, or equivalent research in circuit design. Alternatively, a
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`POSITA could substitute directly relevant additional education for experience, e.g.,
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`an advanced degree relating to the design of electroluminescent devices, drive
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`circuits, or other circuit design or an advance degree in electrical engineering (or
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`equivalent), with at least one year of industry experience.
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`36. At the relevant time, I would have qualified as at least a POSITA and
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`my opinions herein are informed by my own knowledge based on my personal
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`experiences and observing others of various skill levels (including those above and
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`below the level of a POSITA). In particular, I was actively engaged in the field of
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`the ’068 patent at the relevant time (2004 timeframe), as discussed above.
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`37. Nevertheless, my opinions below are not restricted to the precise
`
`definition of a POSITA above. The claims of the ’068 patent are directed to a drive
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`circuit design that was well-known and taught by numerous prior art references
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`Declaration for Inter Partes Review of USP 7,573,068
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`including the references discussed below. Thus, my opinions below would apply
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`under any reasonable definition of a POSITA.
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`
`
`
`
`V. BACKGROUND
`A. Overview of the ’068 Patent (Ex. 1001)
`38. U.S. Patent No. 7,573,068 is entitled “Transistor Array Substrate And
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`Display Panel” and names Satoru Shimoda, Tomoyuki Shirasaki, Jun Ogura, and
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`Minoru Kumagai as inventors. The ’068 patent generally relates to a “transistor
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`array substrate includ[ing] a plurality of driving transistors which are arrayed in a
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`matrix on a substrate.” ’068 patent, Abstract. The ’068 patent relates to an active-
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`matrix driven display with “light emitting elements which cause self-emission when
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`a current is supplied by the transistor array substrate.” ’068 patent, 1:15-24. The
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`light emitting element of each pixel is an organic electroluminescent (“EL”) element,
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`such as an organic light emitting diode (“OLED”). ’068 patent, 1:21-56.
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`39. OLEDs are generally comprised of “one or more layers of organic
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`material [that] are sandwiched between two electrodes,” an anode and a cathode.
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`See Bu (Ex. 1021), [0005]. OLEDs are “current driven devices,” which means that
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`the amount of light the OLED emits varies approximately linearly with the amount
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`of current flowing through the OLED. See id., [0008]. This feature of OLEDs stands
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`in contrast to liquid crystal display (LCD) devices, which are “voltage driven
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`devices.” Id. Because the amount of light emitted by the OLED varies linearly with
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`the amountof current, and because the amountof current in turn varies nonlinearly
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`with the amount of voltage difference between the anode andthe cathode of the
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`OLED,the amountoflight emitted by the OLED therefore varies nonlinearly with
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`the voltage difference between the anode andthe cathode ofthe OLED. See Routley
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`(Ex. 1019), Figs. 4a, 4b, 017 (Figure 4a showsthe “typical light intensity-voltage
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`curve ... for an OLED... is non-linear and exhibits a dead region corresponding to
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`the OLED turn-on voltage .... Figure 4b showsa lightintensity-current curve... for
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`an OLED which... is approximately linear.”); id., 018-020. This relationship is
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`depicted in the figure below, which showsthelight intensity vs. voltage curve(left)
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`and the light intensity vs. current curve (right) of an OLED.
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`EB
`OGae
`=
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`LIGHT
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`INTENSITY
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`
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`400”
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`Figure 4a
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`VOLTAGE
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`/
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`Figure 4b
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`CURRENT
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`Routley (Ex. 1019), Figs. 4a, 4b, 017-020; see also, e.g., Shimoda (Ex. 1020), Fig.
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`7.
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