`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`TIANMA MICROELECTRONICS CO. LTD.,
`Petitioner,
`v .
`JAPAN DISPLAY INC. AND PANASONIC LIQUID CRYSTAL DISPLAY CO.,
`LTD.,
`Patent Owner
`_______________
`Case IPR No: IPR2021-01028
`Patent No. 9,793,299
`_______________
`
`SUPPLEMENTAL DECLARATION OF THOMAS L. CREDELLE
`UNDER 37 C.F.R. § 1.68
`
`
`
`JDI/PLD - EX. 2016
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`
`
`Supplemental Declaration of Thomas L. Credelle
`
`I.
`
`INTRODUCTION
`
`1.
`
`I, Thomas L. Credelle, submit this supplemental declaration in support
`
`of the preliminary response submitted by Japan Display Inc. and Panasonic Liquid
`
`Crystal Display Co., Ltd. (together, “Patent Owner”) in connection with the petition
`
`for Inter Partes Review of U.S. Patent No. 9,793,299 (“the ’299 patent”) filed by
`
`Tianma Microelectronics Co. Ltd. (“Petitioner”).
`
`II.
`
`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`
`2.
`
`My qualifications and professional experience were expressed in my
`
`first declaration.
`
`III.
`
`LEVEL OF ORDINARY SKILL IN THE ART
`
`3.
`
`The requisite level of ordinary skill in the art was expressed in my first
`
`declaration.
`
`IV.
`
`EXHIBIT 2009
`
`4.
`
`I understand that Tianma has objected in Paper 17 to Exhibit 2009,
`
`which is titled “Part 2: Fundamentals of Touch Technologies other than Projective
`
`Capacitance.”
`
`5.
`
`Exhibit 2009 as originally filed is a true and correct copy of the 2014
`
`Society for Information Display (SID) Week presentation “Part 2: Fundamentals of
`
`Touch Technologies other than Projective Capacitance.” Part 2, which begins on
`
`page 197, states that it was updated in October 2013. SID’s Display Week is a well-
`
`–1–
`
`
`
`JDI/PLD - EX. 2016
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`
`
`Supplemental Declaration of Thomas L. Credelle
`
`known conference for professionals in the display field and the contents of Exhibit
`
`2009 are consistent with the type of information that would be presented at SID
`
`Display Week.
`
`6.
`
`Exhibit 2017 is a true and copy of a screen capture I made on January
`
`13, 2022 of the 2014 archive from the Display Week website showing that Geoff
`
`Walker provided a presentation on touch technology on June 1, 2014. The abstract
`
`of
`
`the
`
`Seminar
`
`Presentation
`
`
`
`is
`
`publicly
`
`available
`
`at
`
`http://www.displayweek.org/2014/Program/Sunday-Short-Courses.
`
`7.
`
`I provided Exhibit 2009 to JDI’s counsel. I downloaded the complete
`
`tutorial, which includes Part 2, from the walkermobile.com website and the
`
`document was saved in my computer files. In my opinion, Exhibit 2009 provides
`
`reliable information regarding touch screen technology and is the type of resource
`
`that experts in the field would rely on.
`
`8.
`
`The
`
`document
`
`is
`
`available
`
`publicly
`
`at
`
`http://www.walkermobile.com/Touch_Technologies_Tutorial_Latest_Version.pdf.
`
`9.
`
`I cited to Exhibit 2009 in my declaration. See Ex. 2010, ¶41. Exhibit
`
`2009 is relevant because it explains the difference between capacitive and resistive
`
`touch panels, which relates to my analysis of the Maekawa and Takahata references
`
`in my declaration and in the Patent Owner’s Preliminary Response. Specifically,
`
`Maekawa and Takahata are not from the same field of endeavor because Maekawa
`
`–2–
`
`
`
`JDI/PLD - EX. 2016
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`
`
`Supplemental Declaration of Thomas L. Credelle
`
`does not mention a touch screen and Takahata discloses a resistive touch screen. Id.
`
`Further, Exhibit 2009 is used to explain the thermal warpage issues associated with
`
`an air gap unique to resistive touch screens, such as the touch screen described in the
`
`Takahata reference. Id. at ¶¶41-42.
`
`V.
`
`EXHIBIT 2010
`
`10.
`
`Exhibit 2010 is my declaration, “Declaration of Thomas L. Credelle
`
`Under 36 C.F.R. § 1.68.”
`
`11.
`
`I understand that Petitioner has objected to paragraph 41 of Exhibit
`
`2010.
`
`12.
`
`The statements made in paragraphs 5-9 in reference to Exhibit 2009
`
`apply to Exhibit 2010 at paragraph 41.
`
`VI. CONCLUSION
`
`13.
`
`This declaration and my opinions herein are made to the best of my
`
`knowledge and understanding, and based on the material available to me, at the time
`
`of signing this declaration. I declare that all statements made herein on my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true, and further, that these statements were made with the knowledge
`
`that willful false statements and the like so made are punishable by fine or
`
`imprisonment, or both, under 18 U.S.C. § 1001.
`
`–3–
`
`
`
`JDI/PLD - EX. 2016
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`
`
`Supplemental Declaration of Thomas L. Credelle
`
`Dated: January 13, 2022
`
`Respectfully submitted,
`
`____________________________
`Thomas L. Credelle
`
`–4–
`
`
`
`JDI/PLD - EX. 2016
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`
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