`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG DISPLAY CO., LTD.,
`Petitioner,
`
`
`v.
`
`
`JOLED INC.,
`Patent Owner.
`
`
`Case No. IPR2021-00677
`Patent No. 10,198,992
`
`
`
`DECLARATION OF MILTIADIS HATALIS, PH.D. IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 10,198,992
`
`SAMSUNG EX. 1028
`
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`
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`
`TABLE OF CONTENTS
`
`I.
`INTRODUCTION .............................................................................................. 1
`QUALIFICATIONS ........................................................................................... 2
`II.
`SCOPE OF OPINION ......................................................................................... 8
`III.
`IV. MATERIALS REVIEWED AND CONSIDERED ........................................... 9
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ............................................. 10
`VI. LEGAL PRINCIPLES OF VALIDITY ........................................................... 11
`VII. BACKGROUND .............................................................................................. 14
` Overview of EL Display Technology .................................................... 14
`Priority Date of the ’992 Patent .............................................................. 27
`Overview of the ’992 Patent (Ex. 1001) ................................................ 28
`The Challenged Claims .......................................................................... 36
`Prosecution History ................................................................................ 41
`Claim Construction ................................................................................. 44
`VIII. OVERVIEW OF THE PRIOR ART REFERENCES ..................................... 47
` Kuribayashi (Ex. 1003) .......................................................................... 47
`Sekiya (Ex. 1004) ................................................................................... 53
`Takahara (Ex. 1005) ............................................................................... 56
`C.
`SPECIFIC GROUNDS OF CHALLENGE ..................................................... 60
` Ground I: Claims 1, 2, 4, 7, 10, 11, and 15 are obvious over
`Kuribayashi in view of Sekiya ............................................................... 61
`1.
`Claim 1 ......................................................................................... 61
`2.
`Claim 2 ....................................................................................... 113
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`IX.
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`- i -
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`B.
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`3.
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`4.
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`5.
`6.
`7.
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`Claim 4: “The EL display apparatus according to claim 1,
`wherein the second gate driver circuit is configured to turn the
`third switch transistor from the ON state for reverse biasing the
`anode terminal of the EL device to the OFF state, and, after a
`second lapse of time, the first gate driver circuit is configured to
`turn the first switch transistor from the OFF state to the ON
`state.” .......................................................................................... 123
`Claim 7: An electronic device, comprising: the EL display
`apparatus according to claim 1. ................................................. 132
`Claim 10 ..................................................................................... 133
`Claim 11 ..................................................................................... 138
`Claim 15: “An electronic device, comprising: the EL display
`apparatus according to claim 10.” ............................................. 139
`Ground II: Claims 3, 5, 6, 8, 9, and 12–14 are obvious over
`Kuribayashi in view of Sekiya and further in view of Takahara ......... 140
`1.
`Claim 3: “The EL display apparatus according to claim 1, further
`comprising: a precharge circuit or a discharge circuit which
`forcibly charges or discharges the one of the plurality of source
`signal lines.” ............................................................................... 140
`Claim 5: “The EL display apparatus according to claim 1,
`wherein the first gate driver circuit is configured to select a
`plurality of the first gate signal lines simultaneously.” ............. 147
`Claim 6 ....................................................................................... 153
`Claim 8 ....................................................................................... 157
`Claim 9: “The method according to claim 8, further comprising:
`controlling the first switch transistor to be in an OFF state via the
`first gate driver circuit, when the second gate driver circuit
`controls the third switch transistor to be in the ON state for
`reverse biasing the anode terminal of the EL device.” .............. 162
`Claim 12: “The EL display apparatus according to claim 10,
`further comprising: a precharge circuit or a discharge circuit
`
`2.
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`3.
`4.
`5.
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`6.
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`- ii -
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`X.
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`which forcibly charges or discharges the one of the plurality of
`source signal lines.” ................................................................... 163
`Claim 13: “The EL display apparatus according to claim 10,
`wherein the first gate driver circuit is configured to select a
`plurality of the first gate signal lines simultaneously.” ............. 163
`8.
`Claim 14 ..................................................................................... 163
`CONCLUSION ............................................................................................... 165
`
`7.
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`- iii -
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`I.
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`INTRODUCTION
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
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`1.
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`I, Miltiadis Hatalis, Ph.D., have been retained by counsel for Samsung
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`Display Co. (“Samsung Display” or “Petitioner”) as an expert witness in support of
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`Samsung Display’s petition for Inter Partes Review (“IPR”) and cancellation of claims
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`1–15 of U.S. Patent No. 10,198,992 (Ex. 1001, the “’992 patent”), which I am
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`informed has been assigned to JOLED, Inc. (“JOLED” or “Patent Owner”).
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`2. My opinions are based on my years of education, research and
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`experience, as well as my investigation and study of relevant materials. The materials
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`that I studied for this declaration include all exhibits of the petition.
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`3.
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`I may rely upon these materials, my knowledge and experience, and/or
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`additional materials to rebut arguments raised by the patent owner. Further, I may also
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`consider additional documents and information in forming any necessary opinions,
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`including documents that may not yet have been provided to me.
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`4. My analysis of the materials produced in this investigation is ongoing and
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`I will continue to review any new material as it is provided. This declaration represents
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`only those opinions I have formed to date. I reserve the right to revise, supplement,
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`and/or amend my opinions stated herein based on new information and on my
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`continuing analysis of the materials already provided.
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`Case No. IPR2021-00677
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`Declaration of Miltiadis Hatalis, Ph.D.
`I am being compensated on a per hour basis for my time spent working
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`5.
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`on issues in this case. I have no financial interest in, or affiliation with, the Petitioner,
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`real parties-in-interest, or the patent owner. My compensation is not dependent upon
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`the outcome of, or my testimony in, the present inter partes review or any litigation
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`proceedings.
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`II. QUALIFICATIONS
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`6. My complete qualifications and professional experience are described in
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`my academic curriculum vitae, a copy of which is provided as Exhibit 1027. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
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`7.
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`I am a Professor in the Department of Electrical and Computer
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`Engineering at Lehigh University. I hold a B.S. degree in physics from Aristotle
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`University, Greece, an M.S. degree in electrical engineering from SUNY Buffalo, and
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`a Ph.D. (1987) in electrical engineering from Carnegie Mellon University. In 1987, I
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`joined Lehigh University as an assistant professor in the Department of Electrical &
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`Computer Engineering. I served as an associate professor at Lehigh University from
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`1991 to 1995, and have been a full professor at Lehigh University since 1995. From
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`1988 to 1993, I served as associate director of the Microelectronics Research
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`Laboratory at Lehigh University. Since 1992, I have served as director of the Display
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`Declaration of Miltiadis Hatalis, Ph.D.
`Research Laboratory at Lehigh University. From 2010 to 2013, I served as interim
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`director of the Sherman Fairchild Center for Solid State Studies at Lehigh University.
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`From 2003 to 2008, I concurrently served as professor in the Department of Computer
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`Sciences at Aristotle University, Greece.
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`8.
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`From 1987 to 2015, I also worked as an independent consultant for a
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`number of major technology companies in the flat panel display and semiconductor
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`field, including IBM, Kodak, Sharp and Motorola Solutions. In 1992, I was a visiting
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`scientist at XEROX Palo Alto Research Laboratory.
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`9. As discussed below, my technical expertise is in flat panel display
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`technologies, including thin film transistor (“TFT”) and active-matrix organic light-
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`emitting diode (“AMOLED”) technologies.
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`10.
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`I am the author or co-author of 180 technical publications including three
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`issued patents, and two book chapters, including one on AMOLED pixel electronic
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`circuits and one on polysilicon TFT technology. As of this writing, I have a total of
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`4288 citations and my h-index is 29 according to Google Scholar.
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`11.
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`In 1992, I founded, and became Director of, the Display Research
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`Laboratory, which was the first academic laboratory in the United States dedicated to
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`research and development of electronic thin film materials and devices, including thin
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`film transistors, for flat panel displays, flexible electronics and novel large area
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`microelectronic system applications. The Display Research Laboratory has received
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`Declaration of Miltiadis Hatalis, Ph.D.
`research contracts and grants to support the laboratory’s research activities from the
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`Defense Advanced Research Program Agency (DARPA), the Army Research
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`Laboratory (ARL), the National Science Foundation (NSF), the National Aeronautics
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`and Space Administration (NASA), the State of Pennsylvania, and a variety of
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`industrial companies including Corning, IBM, Kodak, Sharp, Northrop Grumman, and
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`others.
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`12. From 1987 to present, I have conducted research in microelectronics,
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`including semiconductors, electronic materials, devices and circuits for integrated
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`circuits and integrated microsystems. My research mainly focuses on electronic thin
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`film materials and devices, microelectronic fabrication processes, novel electronic
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`circuits, and integrated microsystems. My research group pioneered the development
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`of electronic materials, devices, and circuits on flexible substrates, active matrix
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`organic light emitting diode displays, and addressable arrays for integrated sensor
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`applications such as fingerprint sensors for biometrics and multichannel gas sensors.
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`13. As a faculty member, I supervised the research of twenty Ph.D.
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`dissertations in the technical field of semiconductors/microelectronics. Upon
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`graduating, all twenty of my Ph.D. graduate students moved either to industrial
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`positions in the electronic or flat panel display industry, including positions at Apple,
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`IBM, Intel, Sharp, TSMC, and Motorola, or into academic positions in the United
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`States or abroad. I have also supervised the research of several post-doctoral
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`researchers and research associates at Lehigh. Moreover, I have supervised a large
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`number of graduate student Master’s theses and numerous undergraduate research
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`projects. I have been an invited lecturer at numerous universities, industrial
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`laboratories, and conferences in the United States and overseas.
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`14. The list of peer-reviewed journals in which my papers were published
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`include Thin Solid Films, Journal of the Electrochemical Society, Solid State
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`Electronics, Journal of Applied Physics, Journal of the Society for Information
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`Display, Journal of Materials Science, and multiple IEEE journals including the IEEE
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`journal of Display Technology, IEEE Transactions on Electronic Devices, IEEE Solid
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`State Circuits, and IEEE Electron Device Letters. The technical conferences where my
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`papers were presented have been organized by scientific societies including: Society
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`of Information Display (SID), Materials Research Society (MRS), Electrochemical
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`Society (ECS), and Institute of Electrical and Electronics Engineers (IEEE).
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`15.
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`I am also a named inventor on U.S. Patent No. 8,390,536, directed at
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`controlling current to pixels in an active matrix display by adjusting voltage on the data
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`lines, and two international patents associated with the above invention, one issued in
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`Korea and one in Japan.
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`16.
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`I have taught at a number of different undergraduate and graduate level
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`courses in the Electrical and Computer Engineering department at Lehigh University.
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`These courses have generally centered on physics, technology, and the design and
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`Declaration of Miltiadis Hatalis, Ph.D.
`fabrication of solid-state devices and integrated circuits. I have also introduced several
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`new courses which include “Introduction to VLSI Design,” “Semiconductor Material
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`and Device Characterization,” and “Introduction to Photovoltaic Energy Systems.” I
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`also regularly teach the “Principles of Electrical Engineering,” “Introduction to
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`Computer Engineering,” “Electronic Circuits,” and “Introduction to VLSI Circuits”
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`courses.
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`17. As part of my research, I utilize much of the same equipment and many
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`of the same microfabrication processes that are in use by the semiconductor or flat
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`panel display industry including: Plasma-Enhanced Chemical Vapor Deposition
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`(PECVD) for the deposition of amorphous silicon, silicon nitride and silicon dioxide
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`films; sputter and e-beam deposition tools for aluminum, copper, nickel tungsten,
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`titanium, gold, tantalum, and other metallic thin films; photolithographic tools for
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`defining photoresist patterns on the substrates; as well as reactive ion etching or wet
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`etching tools for removing various thin film materials from the substrates. I also utilize
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`several tools for the characterization of the materials and structures used in
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`microelectronic devices
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`including: optical microscopes, Scanning Electron
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`Microscopy (SEM), Transmission Electron Microscopy (TEM), and Atomic Force
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`Microscopy (AFM). I further utilize a variety of electrical characterization techniques
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`and instruments for testing the electrical performance of completed electronic circuits
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`and systems.
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`18. As part of my research, I pioneered a technique for crystallizing
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`amorphous silicon. Similar techniques have been used in the manufacturing of
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`integrated circuits and flat panel displays. In addition, my research group at Lehigh
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`pioneered the fabrication of electronic devices and circuits on novel flexible substrates
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`and the development of integrated microsystems on flexible substrates, including
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`active matrix organic light emitting diode displays, and addressable arrays for
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`integrated sensor applications such as fingerprint sensors for biometrics and
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`multichannel gas sensors. Many industrial and academic laboratories currently pursue
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`similar research activities; such research flows from the accomplishments of my
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`research group in this technical field.
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`19. My industrial experience includes work at the XEROX Palo Alto
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`Research Laboratory and various consulting projects with companies in the flat panel
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`display or semiconductor technical fields. Those projects related to electronic
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`materials, semiconductor devices and their application to microelectronic systems.
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`20.
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`I am a member of several professional organizations including the
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`Electron Device Society of the IEEE and the SID. I have also been the chair or co-
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`chair at numerous national and international conferences and symposiums, including
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`several SID-sponsored Workshops on Active Matrix Liquid Crystal Displays and a
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`Materials Research Society Symposium on Flat Panel Displays. I have co-authored
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`two book chapters, one dealing with the “Polysilicon TFT Technology” and another
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`on the application of “Polysilicon TFTs in AMOLED Displays.” I have served as a
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`reviewer for technical papers submitted to several scientific journals and have also
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`served as a reviewer for several years for the National Science Foundation Small
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`Business Innovative Research (SBIR) program.
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`21. A detailed list of my publications, education and professional experience,
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`research grants, Ph.D. dissertations for which I served as advisor, publications, and
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`litigation cases in which I served as a technical expert, can be found in my curriculum
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`vitae attached and submitted as Exhibit 1027.
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`III. SCOPE OF OPINION
`
`22.
`
`I have been asked to provide my opinions regarding whether claims 1-2,
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`4, 7, 10-11, and 15 of the ’992 patent would have been obvious to one of ordinary skill
`
`in the art at the time of the alleged invention over Kuribayashi (Ex. 1003) in view of
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`Sekiya (Ex. 1004) (Ground I); and whether claims 3, 5-6, 8-9 and 12-14 would have
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`been obvious to one of ordinary skill in the art at the time of the alleged invention over
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`Kuribayashi (Ex. 1003) in view of Sekiya (Ex. 1004) and further in view of Takahara
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`(Ex. 1005) (Ground II).
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`23. This declaration, including the exhibits hereto, sets forth my opinions on
`
`these issues.
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`Declaration of Miltiadis Hatalis, Ph.D.
`IV. MATERIALS REVIEWED AND CONSIDERED
`
`24.
`
`In addition to the information identified in § II above and elsewhere in
`
`this Declaration, in forming my opinions, I have considered the following documents:
`
`Exhibit
`1001
`1002
`1003
`1004
`1005
`
`1006
`
`1007
`1008
`1009
`
`1010
`1011
`1012
`
`1013
`1014
`
`1015
`1016
`1017
`1018
`
`1019
`
`Description
`U.S. Patent No. 10,198,992 (the “’992 patent”)
`File History for U.S. Patent No. 10,198,992
`U.S. Patent No. 6,175,345 (“Kuribayashi”)
`U.S. Patent No. 6,583,775 (“Sekiya”)
`Certified Translation of Japanese Laid-Open Patent Application
`No. 2001-210122A (“Takahara”)
`2021.02.03 JOLED Reply in Case ref.: 2 O 87/20 (District Court
`of Mannheim)
`European Patent No. EP 3,407,340
`2020.10.30 Nullity action against EP 3,407,340
`Improvement of Current-Voltage Characteristics in Organic
`Light Emitting Diodes by Application of Reversed-Bias Voltage
`(“Zou”)
`U.S. Patent No. 6,380,689 (“Okuda”)
`U.S. Patent No. 6,859,193 (“Yumoto”)
`Low-Temperature Polysilicon Thin-Film Transistor Driving with
`Integrated Driver for High-Resolution Light Emitting Polymer
`Display (“Kimura IEEE”)
`U.S. Patent Publication No. 2002/0033718 (“Tam”)
`International Publication No. WO 98/48403 of PCT/US98/08367
`(“Dawson PCT”)
`Japanese Laid-Open Patent Application No. 2001-210122A
`U.S. Patent No. 6,525,704 (“Kondo”)
`U.S. Patent No. 6,580,657 (“Sanford”)
`C. Tang, et. al. “Organic Electroluminescent Diodes” Applied
`Physics Letters, vol. 51, page 913 (1987) (“Tang APL”)
`2/8/21 Samsung’s Proposed Constructions in JOLED Inc., v.
`Samsung Electronics America, Inc. et al., Case No. 6:20-CV-
`00559-ADA (W.D. Tex.)
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`9
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`
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`Exhibit
`1020
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`
`Description
`2/8/21 JOLED’s Proposed Constructions in JOLED Inc., v.
`Samsung Electronics America, Inc. et al., Case No. 6:20-CV-
`00559-ADA (W.D. Tex.)
`Scheduling Order in JOLED Inc., v. Samsung Electronics
`America, Inc. et al., Case No. 6:20-CV-00559-ADA (W.D. Tex.)
`11/16/2020 JOLED Infringement Contentions in JOLED Inc., v.
`Samsung Electronics America, Inc. et al., Case No. 6:20-CV-
`00559-ADA (W.D. Tex.)
`Correspondence re JOLED dropping ’336 Claim 16
`U.S. Patent No. 6,323,631 (“Juang”)
`U.S. Patent No. 6,348,906 (“Dawson 906”)
`U.S. Patent No. 5,550,066 (“Tang 066”)
`Curriculum Vitae of Dr. Miltiadis Hatalis
`
`V. LEVEL OF ORDINARY SKILL IN THE ART
`
`1021
`
`1022
`
`1023
`1024
`1025
`1026
`1027
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`25.
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`In rendering the opinions set forth in this declaration, I was asked to
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`consider the patent claims and the prior art through the eyes of a person of ordinary
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`skill in the art (“POSITA”). I am informed that the “art” is the field of technology to
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`which a patent is related and that a POSITA is a hypothetical person who is presumed
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`to be aware of all pertinent art, to possess conventional wisdom in the art, is a person
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`of ordinary creativity, and has common sense. I am informed that the purpose of using
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`the viewpoint of a POSITA is for objectivity.
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`26.
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`I am informed 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 innovations
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`are made, (d) sophistication of the technology, and (e) the educational level of active
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`workers in the field. I am also informed that in a given case, every factor may not be
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`present, and one or more factors may predominate.
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`27. Taking these factors into consideration, it is my opinion that a POSITA
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`as of the time of the ’992 patent would have had at least a bachelor’s degree in electrical
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`engineering (or equivalent), and at least two years’ industry experience, or equivalent
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`research, in active matrix display technology. Alternatively, a POSITA could
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`substitute directly relevant additional education for experience, e.g., an advanced
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`degree relating to the design of electroluminescent devices, drive circuits, or other
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`circuit design or an advanced degree in electrical engineering (or equivalent), with at
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`least one year of relevant industry experience.
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`28. At the relevant time, I would have qualified as at least a POSITA and my
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`opinions herein are informed by my own knowledge based on my personal experiences
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`and observing others of various skill levels (including those above and below the level
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`of a POSITA). In particular, I was actively engaged in the field of the ’992 patent at
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`the relevant time, as discussed above.
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`VI. LEGAL PRINCIPLES OF VALIDITY
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`29. Several legal standards have been explained to me that I should consider
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`as part of my validity analysis.
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`I am informed that Petitioner bears the burden of proving grounds of
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`30.
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`invalidity by a preponderance of the evidence. I am informed that a “preponderance”
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`means “more likely than not.” I am informed that general and conclusory assertions,
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`without underlying factual evidence, may not support a conclusion that something is
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`“more likely than not.”
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`31.
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` I am informed that a prior art reference can render a patent claim obvious
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`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.
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`32.
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`In analyzing obviousness, I am informed that it is important to consider
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`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.
`
`33.
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`I am informed that when the claimed subject matter involves combining
`
`pre-existing elements to yield no more than what one would expect from such an
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`arrangement, the combination is obvious. I am also informed that in assessing whether
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`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 am
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`informed that there need not be a precise teaching in the prior art directed to the specific
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`subject matter of a claim because one can take account of the inferences and creative
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`steps that a person of skill in the art would employ. I am further informed that a person
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`of ordinary skill is a person of ordinary creativity, not an automaton.
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`34.
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`I am informed that obviousness cannot be based on the hindsight
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`combination of components selectively culled from the prior art. I am informed that in
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`an obviousness analysis, neither the motivation nor the avowed purpose of the
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`inventors controls the inquiry. Any need or problem known in the field at the time of
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`the invention and addressed by the patent can provide a reason for combining elements.
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`For example, I am informed that it is important to consider whether there existed at the
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`time of the invention a known problem for which there was an obvious solution
`
`encompassed by the patent’s claims. I am informed that known techniques can have
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`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.
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`35.
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`I am informed that, when there is a reason to solve a problem and there is
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`a finite number of identified, predictable solutions, a person of ordinary skill has good
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`reason to pursue the known options within his or her technical grasp. I am further
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`informed that, if this leads to the anticipated success, it is likely the product not of
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`innovation but of ordinary skill and common sense, which bears on whether the claim
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`would have been obvious.
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`13
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`I am informed that secondary considerations can include, for example,
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`36.
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`evidence of commercial success of the invention, evidence of a long-felt need that was
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`solved by an invention, evidence that others copied an invention, or evidence that an
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`invention achieved surprising or unexpected results. I am further informed that such
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`evidence must have a nexus, or causal relationship to the elements of a claim, in order
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`to be relevant. I am unaware of any such secondary considerations for the ’992 patent.
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`VII. BACKGROUND
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` Overview of EL Display Technology
`37. The “Technical Field” of the ’992 patent is directed to “an EL display
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`apparatus employing an organic or inorganic electroluminescence (EL) device and,
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`more particularly, to an EL display apparatus capable of feeding an EL device with a
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`desired current.” Ex. 1001, 1:23–26. Moreover, the 992 discloses that “[t]he active-
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`matrix configuration [is] used for the organic EL display panel.” Id., 12:28-29.
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`38. A major breakthrough for organic EL devices was first reported in 1987
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`when C. Tang demonstrated “organic electroluminescent diodes” having “unique
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`characteristics of high electroluminescent emission efficiency, fast response, low
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`voltage drive, and simplicity of fabrication.” Ex. 1018, C. Tang, et. al., “Organic
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`Electroluminescent Diodes,” Applied Physics Letters, vol. 51 (1987) (“Tang APL”),
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`914. The simple fabrication included “a double layer of organic thin films” sandwiched
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`between two appropriately selected electrode materials. Id., 913. Moreover, Tang first
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`reported that an “organic diode … behaves like a rectifier” and that “[l]ight emission
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`[is] seen only in forward bias.” Id.
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`39.
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`In the art, due to its rectification property, an organic EL element “is often
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`called OLED (organic light emitting diode) and … the mark of a diode is used for the
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`light emitting element OLED.” Ex. 1004 (Sekiya), 1:60–65. See also, Ex. 1011
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`Yumoto, 1:59–64 (“The organic EL element has a rectification property, in many
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`cases, so is sometimes referred to as an OLED (organic light emitting diode).” The two
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`electrodes of an organic EL diode or OLED, as with all diodes, are referred to as the
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`“anode” and “cathode,” which are annotated in the below standard circuit symbol for
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`a diode.
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`As with all diodes, whether an OLED diode is in the forward or reverse bias state, it is
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`a function of the voltage difference between the anode and cathode terminals; when
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`this voltage difference is positive, i.e., the anode is at a higher voltage than the cathode,
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`then an OLED device is in forward bias state and when this voltage difference is
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`negative, i.e., the anode is at a lower voltage than the cathode, then an OLED device
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`is in reverse bias state.
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`40. A typical organic EL display, such as would be used in computing
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`devices, televisions, etc., includes an array of OLEDs, each of which must generate the
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`intended level of light emission for a given pixel in a given frame in order to achieve
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`light emission uniformity. At the time of the alleged invention of the ’992 patent, in
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`order to control the current applied to the OLEDs in a display, two general architectures
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`were well known: “active matrix” OLED displays (AMOLED), and “passive matrix”
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`OLED displays (PMOLED).
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`41.
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`In a “passive matrix” display, each pixel is formed by the overlap of two
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`conductive lines (a horizontal and a vertical), whereby current is provided. A passive
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`matrix display emits light one row at a time within a frame period. By repetitively
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`scanning the OLEDs of the various rows, the display gives the impression to the viewer
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`of a steady image. Due to the limited emission time (a small fraction of the frame
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`period) each OLED must emit at a very high brightness; thus passive matrix displays
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`require high drive currents which can damage the OLEDs. For example, a passive
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`matrix display having the VGA format (640x480), a common format at the time of the
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`’992 patent, the current flowing through an OLED would have been 480 times higher
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`than what would have been if current could flow continuously instead of one row at a
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`time. Larger display formats such as SVGA (800x600), XGA (1024x768), etc., would
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`have required even higher currents.
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`Case No. IPR2021-00677
`U.S. Patent No. 10,198,992
`Declaration of Miltiadis Hatalis, Ph.D.
`42. On the other hand, in an “active matrix display,” such as the display
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`described in the ’992 patent, the amount of current applied to each organic EL element
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`is “actively” controlled by a separate “pixel circuit,” formed adjacent to each organic
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`EL element, throughout the frame period and thus significantly smaller drive currents
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`are used. In addition to being one of the pioneering inventors of OLEDs, Tang is also
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`one of the pioneering inventors of an active matrix OLED display. “FIG. 1 shows the
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`schematic of active matrix 4-terminal TFT-EL display device. Each pixel element
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`includes two TFTs, a storage capacitor and an EL element.” Ex. 1026 (“Tang 066”),
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`6:13–15, Fig. 1. Tang discloses that “[t]he first TFT is electrically connected to the
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`gate of the second TFT which in turn is electrically connected to the capacitor so that
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`following an excitation signal the second TFT is able to supply a nearly constant
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`current to the EL pad between signals.” Id., 4:20-24. Tang shows in Fig. 8 (below) a
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`cross section of the completed TFT-EL structure depicting the EL anode in contact
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`with a TFT. Tang further discloses th