U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`SAMSUNG DISPLAY CO., LTD., SAMSUNG ELECTRONICS CO., LTD.,
`AND SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`
`v.
`
`SOLAS OLED LTD.
`Patent Owner.
`
`DECLARATION OF MILTIADIS HATALIS, PH.D., IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,868,880
`
`Petitioner Samsiung Ex. 1003 - Page 1 of 164
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`TABLE OF CONTENTS
`
`
`Page
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`
`
`Contents
`I.
`INTRODUCTION .......................................................................................... 1
`II.
`BACKGROUND AND QUALIFICATIONS ................................................ 1
`III. DOCUMENTS CONSIDERED IN FORMING MY OPINIONS ................. 8
`IV. LEGAL PRINCIPLES .................................................................................... 9
`V. OVERVIEW OF ’880 PATENT .................................................................. 14
`VI. CLAIM CONSTRUCTION ......................................................................... 21
`VII. GROUNDS FOR INVALIDITY .................................................................. 22
`A. Grounds 1/1a: Claims 1-9, 11-14, and 25-32 Are Anticipated
`and/or Rendered Obvious by Miyazawa in Light of the
`Knowledge of a POSA ....................................................................... 22
`1.
`U.S. Patent Pub. No. 2005/0083270 (“Miyazawa”) ................ 22
`2.
`Claim 1 ..................................................................................... 28
`3.
`Claim 2 ..................................................................................... 40
`4.
`Claim 3 ..................................................................................... 46
`5.
`Claim 4 ..................................................................................... 51
`6.
`Claim 5 ..................................................................................... 53
`7.
`Claim 6: .................................................................................... 54
`8.
`Claim 7 ..................................................................................... 55
`9.
`Claim 8 ..................................................................................... 56
`10. Claim 9 ..................................................................................... 58
`11. Claim 11 ................................................................................... 59
`12. Claim 12 ................................................................................... 59
`13. Claim 13 ................................................................................... 61
`14. Claim 14 ................................................................................... 63
`15. Claim 25 ................................................................................... 64
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`B.
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`TABLE OF CONTENTS
`(continued)
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`Page
`
`16. Claim 26: .................................................................................. 67
`17. Claim 27 ................................................................................... 67
`18. Claim 28 ................................................................................... 69
`19. Claim 29 ................................................................................... 70
`20. Claim 30 ................................................................................... 71
`21. Claim 31 ................................................................................... 72
`22. Claim 32 ................................................................................... 73
`Ground 2/2a: Claims 1-14, and 25-33 are anticipated or
`rendered obvious by Morosawa in Light of the Knowledge of a
`POSA .................................................................................................. 73
`1. Morosawa ................................................................................. 73
`2.
`Claim 1 ..................................................................................... 81
`3.
`Claim 2 ..................................................................................... 99
`4.
`Claim 3 ................................................................................... 106
`5.
`Claim 4 ................................................................................... 109
`6.
`Claim 5 ................................................................................... 110
`7.
`Claim 6 ................................................................................... 111
`8.
`Claim 7 ................................................................................... 115
`9.
`Claim 8 ................................................................................... 116
`10. Claim 9 ................................................................................... 118
`11. Claim 10 ................................................................................. 119
`12. Claim 11 ................................................................................. 119
`13. Claim 12 ................................................................................. 119
`14. Claim 13 ................................................................................. 121
`15. Claim 14 ................................................................................. 123
`16. Claim 25 ................................................................................. 125
`17. Claim 26: ................................................................................ 128
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`ii
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`Petitioner Samsiung Ex. 1003 - Page 3 of 164
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`TABLE OF CONTENTS
`(continued)
`
`Page
`
`C.
`
`18. Claim 27 ................................................................................. 129
`19. Claim 28 ................................................................................. 129
`20. Claim 29 ................................................................................. 129
`21. Claim 30 ................................................................................. 130
`22. Claim 31 ................................................................................. 130
`23. Claim 32 ................................................................................. 130
`24. Claim 33 ................................................................................. 131
`Ground 3: Claims 18-24 and 34-40 are rendered obvious by the
`combination of Morosawa and Shirasaki in Light of the
`Knowledge of a POSA ..................................................................... 131
`1.
`Shirasaki ................................................................................. 131
`2. Motivation To Combine Morosawa and Shirasaki ................ 132
`3.
`Claims 18 and 34.................................................................... 134
`4.
`Claims 19/35 .......................................................................... 136
`5.
`Claims 20/36 .......................................................................... 137
`6.
`Claims 21/37 .......................................................................... 138
`7.
`Claim 22 ................................................................................. 140
`8.
`Claim 23 ................................................................................. 142
`9.
`Claim 24 ................................................................................. 145
`10. Claim 38 ................................................................................. 147
`11. Claim 39 ................................................................................. 147
`12. Claim 40 ................................................................................. 148
`D. Ground 4: Claims 24 and 40 are rendered obvious by the
`combination of Morosawa, Shirasaki, and Koyama in Light of
`the Knowledge of a POSA ............................................................... 148
`1.
`Koyama and Motivation to Combine ..................................... 149
`2.
`Claims 24, 40 ......................................................................... 150
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`Petitioner Samsiung Ex. 1003 - Page 4 of 164
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`TABLE OF CONTENTS
`(continued)
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`Page
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`
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`E.
`
`Ground 5: Claims 15-17 are rendered obvious by the
`combination of Morosawa and Hector in Light of the
`Knowledge of a POSA ..................................................................... 150
`1.
`Hector ..................................................................................... 150
`2. Motivation to Combine Morosawa and Hector ..................... 152
`3.
`Claim 15 ................................................................................. 154
`4.
`Claim 16 ................................................................................. 155
`5.
`Claim 17 ................................................................................. 158
`VIII. CONCLUSION ........................................................................................... 158
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`Petitioner Samsiung Ex. 1003 - Page 5 of 164
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`
`I.
`
`INTRODUCTION
`1.
`I have been retained as an independent expert witness on behalf of
`
`Samsung Display Co., Ltd., Samsung Electronics, Co., Ltd., and Samsung
`
`Electronics America, Inc. (collectively, “Samsung”) in the above-captioned inter
`
`partes review (“IPR”) relating to U.S. Patent No. 7,868,880 (“the ’880 Patent”)
`
`(Ex1001).
`
`2.
`
`I understand that Samsung is petitioning for IPR of claims 1-40 of the
`
`’880 patent and requests that the United States Patent and Trademark Office
`
`(“PTO”) cancel those claims.
`
`3.
`
`In preparing this Declaration, I have reviewed the ’880 patent and
`
`considered the documents identified below 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.
`
`
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`The following is a brief summary of my relevant qualifications and professional
`
`experience.
`
`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.
`
`
`
`2
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`As discussed below, my technical expertise is in flat panel display
`
`8.
`
`technologies, including thin film transistor (“TFT”) and active-matrix organic
`
`light-emitting diode (“AMOLED”) technologies.
`
`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 4,273 citations and my h-index is 29 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.
`
`
`
`3
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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 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.
`
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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,
`
`IEEE Solid State Circuits, and IEEE Electron Device Letters. The technical
`
`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
`
`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
`
`
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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 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
`
`
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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 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
`
`7
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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.
`
`III. DOCUMENTS CONSIDERED IN FORMING MY OPINIONS
`In addition to the information identified above (e.g., ¶¶ 3, 5-20) and
`21.
`
`elsewhere in this Declaration, in forming my opinions, I have considered the
`
`following documents:
`
`Exhibit
`Ex-1001
`
`U.S. Patent No. 7,868,880
`
`Description
`
`Ex-1002
`
`Claim Listing
`
`Ex-1005
`
`Prosecution History of U.S. Patent No. 7,868,880
`
`Ex-1006
`
`U.S. Patent Pub. No. 2005/0083270 (“Miyazawa”)
`
`Ex-1007
`
`U.S. Patent Pub. No. 2003/095087 (“Libsch”)
`
`Ex-1008 WIPO Pub. No. WO 2004/040543 (“Morosawa”)
`
`Ex-1009 WIPO Pub. No. WO 2004/086347 (“Shirasaki”)
`
`Ex-1010
`
`U.S. Patent No. 7,564,433 (“Hector”)
`
`Ex-1011
`
`U.S. Patent Pub. No. 2003/0197664 (“Koyama”)
`
`8
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`
`IV. 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 person of ordinary skill in the art
`
`(“POSA”) could take its teachings in combination with his/her own knowledge of
`
`the particular art and be in the possession of the invention.
`
`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
`
`9
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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 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
`
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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.
`
`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 ’880 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
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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 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 POSA 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
`
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`certain technical field (including knowledge of known problems and desired
`
`features in the field).
`
`33.
`
`I have been asked to analyze claims 1-40 of the ’880 patent, and prior
`
`art relating thereto, from the perspective of such a person at the time of the alleged
`
`inventions. I have been informed by counsel to assume that this is in the 2005 time
`
`frame. I will refer to this time as the “relevant time” or similar herein.
`
`34.
`
`I understand that the factors that may be considered in determining the
`
`level of ordinary skill in the art may include (a) the type of problems encountered
`
`in the art, (b) prior art solutions to those problems, (c) the rapidity with which
`
`innovations are made, (d) sophistication of the technology, and (e) the educational
`
`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 ’880 patent at the relevant time (2005) 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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`POSA 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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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`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 POSA 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 POSA). In particular, I was actively engaged in the field of
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`the ’880 patent at the relevant time (2005 timeframe), as discussed above.
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`37. Nevertheless, my opinions below are not restricted to the precise
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`definition of a POSA above. The claims of the ’880 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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`including the references discussed below. Thus, my opinions below would apply
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`under any reasonable definition of a POSA.
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`V. OVERVIEW OF ’880 PATENT
`38. The ’880 Patent is directed to a display panel including a matrix of
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`OLED display pixels arranged at the intersections of scan lines and drive lines. As
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`shown in Figure 10 below, a data driver (blue) supplies gradation data along data
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`lines (DL) to program the brightness of each display pixel (yellow). Ex1001,
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`18:11-35. A scanning driver (orange) selects rows for programming using
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`horizontal scan lines (SL), and a power source driver (green) supplies a drive
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`voltage to each row of pixels at specific times, defining a Display-ON period, in
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`which pixels in the row are on, and a Display-OFF, or non-display period, in which
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`the pixels are off. In addition, bias control signals (purple) from a “state setting
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`unit” enter parallel to the scan lines and are used to eliminate a programmed bias
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`state between data programming periods. Ex1001, 18:35-55; 20:11-17.
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`’880 Patent Figure 101
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`1 Throughout, all color annotations are added.
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`U.S. Patent No. 7,868,880
`Ex1003, Declaration of Miltiadis Hatalis
`39. Figure 11 (below) depicts the driving circuit for each pixel, showing
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`how the drive line (blue), scan line (orange), power source line (green), and bias
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`line (purple) connect to four transistors (Tr11–Tr14) that control the programming,
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`clearing, and driving of the light emitting element OEL of each pixel.
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`
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`’880 Patent Figure 11
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`
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`40. The operation of this circuit is described with reference to the timing
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`diagram of Figure 12 (below). It shows a Display-ON period (yellow) set when
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`the power source driver drives volta