UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`JOLED INC.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS AMERICA,
`INC., SAMSUNG DISPLAY CO., LTD.,
`and SAMSUNG ELECTRONICS CO.,
`LTD.
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Case No.: 6:20-cv-00559-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF JOLED INC.’S PROPOSED CLAIM CONSTRUCTIONS
`
`Pursuant to the Court’s Scheduling Order (D.I. 24), Plaintiff JOLED Inc. (“JOLED”)
`
`provides the following proposed claim constructions for the terms identified by the parties for
`
`construction. JOLED proposes these constructions based on information currently available to it
`
`and reserves the right to revise its proposed claim constructions as additional information
`
`becomes available. For example, in response to JOLED’s inquires, Defendants have refused to
`
`explain why they believe any of the terms that they have identified require construction or where
`
`they believe a dispute in the terms’ meanings exists. JOLED anticipates Defendants will clarify
`
`their positions as the claim construction process continues. Additionally, Defendants’ technical
`
`document production has been insufficient to show the operation of the accused products and,
`
`thus, Defendants have failed to satisfy the technical document production requirement in the
`
`Court’s Order Governing Proceedings – Patent Case Version 3.2 (the “OGP”). JOLED thus
`
`reserves the right to revise its proposed claim constructions based on clarifications about
`
`Defendants’ claim construction positions or claim construction disputes evident from production
`
`of additional technical documents in compliance with Defendants’ obligations under the OGP.
`
`1
`
`SAMSUNG EX. 1020 - 1/8
`
`

`

`PLAINTIFF’S PROPOSED CLAIM TERMS FOR CONSTRUCTION
`
`Term
`Number
`
`1.
`
`Term
`
`“initially resetting the pixel
`circuit” /
`“initially resets a gate terminal
`of the driving transistor” /
`“resetting . . . a second pixel”
`
`Proposed
`Construction
`
`See Defendants’ Proposed Terms 6 and 7 below.
`
`DEFENDANTS’ PROPOSED CLAIM TERMS FOR CONSTRUCTION
`
`Proposed
`Construction
`
`plain meaning, no construction necessary
`
`Term
`Number
`
`1.
`
`Term
`
`“a gate driver circuit which
`includes a first gate driver
`circuit, a second gate driver
`circuit…” /
`“a gate driver circuit which
`includes a first gate driver
`circuit and a second gate driver
`circuit…” /
`“the gate driver circuit includes
`a first gate driver circuit and a
`second gate driver circuit” /
`“a gate driver circuit including a
`first gate driver circuit…and a
`second gate driver circuit…”
`
`(’130, cls. 1, 13;
`’597, cls. 1, 16;
`’108, cls. 1, 16;
`’336, cls. 10, 18;
`’992, cls. 1, 8, 10)
`
`2
`
`SAMSUNG EX. 1020 - 2/8
`
`

`

`Term
`Number
`
`2.
`
`Term
`
`“wherein the first switch
`transistor and the second switch
`transistor are independently
`on/off controlled by the first gate
`driver circuit and the second
`gate driver circuit” /
`“the first gate driver circuit and
`second gate driver circuit
`control the first gate signal line
`and the second gate signal line
`independently” /
`“the first switching transistor
`and the second switching
`transistor are independently
`on/off controlled by the first gate
`driver circuit and the second
`gate driver circuit” /
`“independently on/off
`controlling the first switching
`transistor and the second
`switching transistor by the first
`gate driver circuit and the
`second gate driver circuit” /
`“wherein, by the first gate driver
`circuit and the second gate
`driver circuit, the first switch
`transistor is independently
`on/off controlled from the
`second switch transistor and the
`third switch transistor”
`
`(’130, cls. 1, 13;
`’597, cl. 4;
`’108, cl. 4;
`’336, cls. 11, 18)
`
`
`
`
`
`
`Proposed
`Construction
`
`plain meaning, no construction necessary
`
`3
`
`
`
`SAMSUNG EX. 1020 - 3/8
`
`

`

`Term
`Number
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`
`
`
`
`Term
`
`“the first gate driver circuit is
`configured to select the plurality
`of first gate signal lines as a
`block simultaneously” /
`“selecting, by the first gate
`driver circuit, the plurality of
`first gate signal lines as a block
`simultaneously” /
`“selecting the plurality of first
`gate signal lines via the first gate
`driver circuit as a block
`simultaneously”
`
`(’108, cls. 6, 20;
`’992, cls. 6, 8, 14)
`
`“the source driver circuit
`[is/being] provided as a
`semiconductor chip and
`[is/being] attached to the EL
`display apparatus”
`
`(’130, cls. 1, 13)
`
`“the second gate driver circuit is
`arranged at a second side of the
`display screen”
`
`(’130, cl. 4)
`
`“initially resetting the pixel
`circuit” /
`“initially resets the pixel
`circuit” /
`“resetting…[a/the] second pixel”
`
`(’597, cls. 1, 16, 17;
`’108, cls. 1, 16, 17)
`
`“initially resets [a/the] gate
`terminal of the driving
`transistor” /
`“a gate terminal of the driving
`transistor is initially reset” /
`“[a/the] gate terminal of the
`driving transistor is reset”
`
`(’597, cls. 1, 6, 16, 17;
`’108, cls. 7, 9, 17-19)
`
`
`Proposed
`Construction
`
`plain meaning, no construction necessary
`
`plain meaning, no construction necessary
`
`plain meaning, no construction necessary
`
`“setting the pixel circuit to a predetermined state to
`render the pixel ready for programming”
`“sets the pixel circuit to a predetermined state to
`render the pixel ready for programming”
`“setting . . . [a/the] second pixel circuit to a
`predetermined state to render the second pixel ready
`for programming”
`
`“sets [a/the] gate terminal of the driving transistor to a
`predetermined state to render the pixel ready for
`programming”
`“a gate terminal of the driving transistor is set to a
`predetermined state to render the pixel ready for
`programming”
`“[a/the] gate terminal of the driving transistor is set to
`a predetermined state to render the pixel ready for
`programming”
`
`4
`
`
`
`SAMSUNG EX. 1020 - 4/8
`
`

`

`Term
`Number
`
`8.
`
`9.
`
`10.
`
`Term
`
`“when the third switch
`transistor initially resets the gate
`terminal of the driving
`transistor” /
`“when the third switch
`transistor initially resets the
`pixel circuit”
`
`(’597, cls. 1, 16;
`’108, cls. 1, 16)
`
`“the first switch transistor of the
`Nth row is controlled in an OFF
`state by the first gate driver
`circuit” /
`“the first switch transistor of the
`Nth pixel row is controlled in an
`OFF state by the first gate
`driver circuit”
`
`(’597, cl. 10;
`’108, cl. 11)
`
`“the gate driver circuit is
`configured to change a ratio of
`an area of the plurality of
`band-shaped non-display
`regions on the display screen to
`an area of the plurality of band-
`shaped display regions on the
`display screen depending on at
`least one of a brightness
`adjustment, a type of image
`data, or whether a display image
`is a motion image or a still
`image” /
`“the gate driver circuit is
`configured to change a number
`of divisions by which the display
`screen is divided into the
`plurality of band-shaped non-
`display regions and the plurality
`of band-shaped display regions
`depending on the type of image
`data” /
`“type of image data”
`
`(’336, cls. 1, 6, 19)
`
`
`
`
`
`
`Proposed
`Construction
`
` “when the third switch transistor sets the gate
`terminal of the driving transistor to a predetermined
`state to render the pixel ready for programming”
`“when the third switch transistor sets the pixel circuit
`to a predetermined state to render the pixel ready for
`programming”
`
`plain meaning, no construction necessary
`
`plain meaning, no construction necessary
`
`5
`
`
`
`SAMSUNG EX. 1020 - 5/8
`
`

`

`
`
`
`
`Proposed
`Construction
`
`plain meaning, no construction necessary
`
`plain meaning, no construction necessary
`
`Term
`Number
`
`11.
`
`12.
`
`
`
`Term
`
`“the gate driver circuit is
`configured to move up and down
`the plurality of band-shaped
`non-display regions and the
`plurality of band-shaped display
`regions”
`
`(’336, cl. 14)
`
`“asymmetrically generate the
`plurality of band-shaped
`non-display regions and the
`plurality of band-shaped display
`regions on the display screen”
`
`(’336, cl. 16)
`
`
`6
`
`
`
`SAMSUNG EX. 1020 - 6/8
`
`

`

`
`
`
`
`Dated: February 8, 2021
`
`Respectfully submitted,
`
`
`
`Vincent J. Belusko (pro hac vice)
`California State Bar No. 100282
`Dylan J. Raife (pro hac vice)
`California State Bar No. 288346
`Morrison & Foerster LLP
`707 Wilshire Boulevard, Suite 6000
`Los Angeles, CA 90017-3543
`213-892-5200
`213-892-5454 (Fax)
`vbelusko@mofo.com
`draife@mofo.com
`
`David L. Fehrman (pro hac vice)
`California State Bar No. 87400
`DSA Legal Solutions
`12655 W. Jefferson Blvd., Fl. 4
`Los Angeles, CA 90066-7008
`424-380-2291
`815-880-2890 (Fax)
`dfehrman@dsa-legal.com
`
`Diek O. Van Nort (pro hac vice)
`California State Bar No. 273823
`Morrison & Foerster LLP
`425 Market Street
`San Francisco, CA 94105-2482
`415-268-6971
`415-268-7522 (Fax)
`dvannort@mofo.com
`
`
`7
`
`
`
`SAMSUNG EX. 1020 - 7/8
`
`

`

`
`
`
`
`
`
`
`sf-4422670
`
`
`Richard D. Milvenan
`Texas State Bar No. 14171800
`McGinnis Lochridge LLP
`600 Congress Avenue, Suite 2100
`Austin, TX 78701-2986
`512-495-6000
`512-495-6093 (Fax)
`rmilvenan@mcginnislaw.com
`
`A. Max Olson (pro hac vice)
`California State Bar No. 155510
`Morrison & Foerster LLP
`Shin-Marunouchi Building, 29th Floor
`5-1 Marunouchi 1-chome
`Chiyoda-ku, Tokyo 100-6529
`Japan
`+81-3-3214-6522
`+81-3-3214-6512 (Fax)
`aolson@mofo.com
`
`Counsel For Plaintiff
`
`
`
`
`8
`
`
`
`SAMSUNG EX. 1020 - 8/8
`
`