`
`Exhibit D-1
`
`Claim Chart for U.S. Patent No. 9,793,299
`
`Tianma applies the prior art in light of JDI’s improper assertions of infringement and improper application of the claims.
`Tianma does not agree with JDI’s application of the claims, or that the claims satisfy 35 U.S.C. § 112. Tianma’s disclosures
`herein are not, and should in no way be seen as, admissions or adoptions as to any particular claim scope or construction,
`or as any admission that any particular element is met in any particular way. Tianma’s initial patent disclosures are made in
`a variety of alternatives and do not represent Tianma’s agreement or view as to the meaning, definiteness, written
`description support for, or enablement of any claim contained therein.
`
`
`Claim Element
`
`Citation
`
`1(pre). A display
`device comprising
`display area and
`used in a hand-held
`electronic device
`comprising;
`
`The ’299 patent concedes that using liquid crystal displays in a hand-held electronic device was
`conventional and known in the art.
`
`See, e.g.:
`
`’299 Patent at 1:36-39 (“A thin display such as a liquid crystal display has been conventionally
`used for a display used in a hand-held electronic device such as a mobile telephone terminal or a
`PDA (Personal Digital Assistant).”).
`
`Moreover, Maekawa-’171 discloses a display device comprising a display area and used in a
`hand-held electronic device.
`
`See, e.g.:
`
`Maekawa-’171 at 2:66-3:14 (“According to the invention, a semiconductor device having a film
`pattern formed by using the first mask pattern which has low wettability and the second mask
`pattern which has high wettability, a substrate having the film pattern, or a semiconductor
`element, and a manufacturing method thereof are provided. The semiconductor device is, for
`example, an integrated circuit, a display device, a wireless tag, an IC tag, an IC card and the like
`formed of a semiconductor element. The display device includes a liquid crystal display device, a
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–1
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`light emitting display device, a DMD (Digital Micromirror Device), a PDP (Plasma Display Panel),
`an FED (Field Emission Display), an electrophoresis display device (electronic paper) and the
`like representatively. The TFT is, for example, a staggered TFT, an inverted staggered TFT (a
`channel-etch type TFT or a channel protective type TFT), a top gate coplanar TFT, a bottom gate
`coplanar TFT and the like.”).
`
`Maekawa-’171 at 38:16-32 (“By incorporating the display module described in Embodiment 6 or
`7 into a housing, various electronic apparatuses can be manufactured. The electronic
`apparatuses include a television apparatus, a video camera, a digital camera, a goggle type
`display (a head mounted display), a navigation system, an audio reproducing apparatus (a car
`audio system, an audio component set and the like), a notebook personal computer, a game
`machine, a portable information terminal (a mobile computer, a portable phone, a portable game
`machine, an electronic book or the like), an image reproducing apparatus provided with a
`memory medium (specifically an apparatus provided with a display which reproduces a memory
`medium such as a Digital Versatile Disc (DVD) and can display the reproduced image), and the
`like. Here, as examples of these electronic apparatuses, FIGS. 17 and 18 show a television
`apparatus and block diagrams thereof and FIGS. 19A and 19B each shows a digital camera.”).
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at 39:35-42 (“FIGS. 19A and 19B show examples of a digital camera. FIG. 19A is
`a perspective view of the digital camera seen from the front while FIG. 19B is a perspective view
`thereof seen from the back. In FIG. 19A, the digital camera includes a release button 1301, a
`main switch 1302, a finder 1303, a flash 1304, a lens 1305, a camera cone 1306, and a housing
`1307. In FIG. 19B, a finder eyepiece window 1311, a monitor 1312, and an operating button
`1313 are provided.”).
`
`Maekawa-’171 at Figs. 16, 19B.
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–2
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`1(a). a TFT
`substrate,
`
`
`Kinoshita-’944 also discloses a display device comprising a display area and used in a hand-held
`electronic device.
`
`See, e.g.:
`
`Kinoshita-’944 at 12:45-54 (“An example of the structure of the touch panel 1100 is described in
`greater detail. The touch panel 1100 is mounted over the entire surface of the display panel. The
`touch panel 1100 senses the position of depression (or contact) on the touch panel surface by
`the user's finger or a pen. This type of touch panel 1100 is an input means that is most widely
`used in mobile information terminals wherein keyboard input is dispensed with. By mounting the
`touch panel 1100 on a device such as a notebook personal computer, both keyboard input and
`touch panel input can be utilized and the functional capability is enhanced.”).
`
`Kinoshita-’944 at Fig. 9.
`
`The ’299 patent concedes that TFT substrates were conventional and known in the art.
`
`See, e.g.:
`
`’299 Patent at 12:54-67 (“A liquid crystal display panel used in a conventional mobile telephone
`terminal includes, for example as shown in FIGS. 4 and 5, a TFT substrate 1, a counter substrate
`2, a lower polarizing plate 4, an upper polarizing plate 5, and a sealing member 7. When the
`liquid crystal display panel is seen by the observer, the upper polarizing plate 5, counter
`Invalidity Contentions — Exhibit D-1
`Page D-1–3
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`substrate 2, liquid crystal material 3, TFT substrate 1 and lower polarizing plate 4 are disposed in
`this order from the observer. If the liquid crystal display concerned is a transmission type display,
`a back light 8 is disposed further behind the lower polarizing plate 4 when seen from the
`observer side. The liquid crystal display panel and the back light 8 are held by a concave display
`mold 9 so that a back surface side of the back light 8 is a bottom surface.”).
`
`Moreover, Maekawa-’171 discloses a TFT substrate.
`
`See, e.g.:
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at Fig. 16.
`
`
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–4
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`1(b). a counter
`substrate,
`
`Kinoshita-’944 also discloses a TFT substrate.
`
`See, e.g.:
`
`Kinoshita-’944 at 3:61-4:8 (“The liquid crystal panel 100 has an effective display region 102 with
`a diagonal size of 12.1 inches. The effective display region 102 includes a plurality of display
`pixel sections PX arranged in a matrix. The liquid crystal panel 100 includes an array substrate
`200, a counter substrate 400, and a liquid crystal layer 410 that is held between the array
`substrate 200 and counter substrate 400, with alignment films 219 and 405 interposed,
`respectively. This liquid crystal panel 100 suitably adopts a display mode in which display is not
`greatly affected by a variation in cell gap, for example, a twisted nematic (TN) display mode or an
`IPS (In Plane Switching) display mode. This embodiment adopts a TN display mode in which
`liquid crystal molecules provided between substrates are aligned with 90° twist.”).
`
`Kinoshita-’944 at Fig. 2.
`
`The ’299 patent concedes that counter substrates were conventional and known in the art.
`
`See, e.g.:
`
`’299 Patent at 12:54-67 (“A liquid crystal display panel used in a conventional mobile telephone
`terminal includes, for example as shown in FIGS. 4 and 5, a TFT substrate 1, a counter substrate
`2, a lower polarizing plate 4, an upper polarizing plate 5, and a sealing member 7. When the
`liquid crystal display panel is seen by the observer, the upper polarizing plate 5, counter
`substrate 2, liquid crystal material 3, TFT substrate 1 and lower polarizing plate 4 are disposed in
`this order from the observer. If the liquid crystal display concerned is a transmission type display,
`a back light 8 is disposed further behind the lower polarizing plate 4 when seen from the
`observer side. The liquid crystal display panel and the back light 8 are held by a concave display
`mold 9 so that a back surface side of the back light 8 is a bottom surface.”).
`
`Moreover, Maekawa-’171 discloses a counter substrate.
`
`See, e.g.:
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–5
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at Fig. 16.
`
`Kinoshita-’944 also discloses a counter substrate.
`
`See, e.g.:
`
`
`
`Kinoshita-’944 at 3:61-4:8 (“The liquid crystal panel 100 has an effective display region 102 with
`a diagonal size of 12.1 inches. The effective display region 102 includes a plurality of display
`pixel sections PX arranged in a matrix. The liquid crystal panel 100 includes an array substrate
`200, a counter substrate 400, and a liquid crystal layer 410 that is held between the array
`substrate 200 and counter substrate 400, with alignment films 219 and 405 interposed,
`respectively. This liquid crystal panel 100 suitably adopts a display mode in which display is not
`greatly affected by a variation in cell gap, for example, a twisted nematic (TN) display mode or an
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–6
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`1(c). a multi-thin film
`layer,
`
`IPS (In Plane Switching) display mode. This embodiment adopts a TN display mode in which
`liquid crystal molecules provided between substrates are aligned with 90° twist.”).
`
`Kinoshita-’944 at Fig. 2.
`
`The ’299 patent concedes that multi-thin film layers were conventional and known in the art.
`
`See, e.g.:
`
`’299 Patent at 10:63-11:2 (“Any of various combinations applied to conventional liquid crystal
`display panels may be adopted for the combination of the configuration of the multi-thin film layer
`102 of the TFT substrate and the multi-thin film layer 202 of the counter substrate 2. Therefore,
`detailed descriptions on concrete structural examples of the multi-thin film layers 102 and 202 will
`be here omitted.”).
`
`Moreover, Maekawa-’171 discloses a multi-thin film layer.
`
`See, e.g.:
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at Fig. 16.
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–7
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`
`
`Kinoshita-’944 also discloses a multi-thin film layer.
`
`See, e.g.:
`
`Kinoshita-’944 at 4:8-18 (“In order to achieve further reduction in thickness, the array substrate
`200 includes a light-transmissive insulation substrate 201 that is formed of glass with a thickness
`of 0.15 mm or less, preferably 0.1 mm or less (with a thickness of 0.1 mm in the first
`embodiment). The insulation substrate 201 includes, on one of its major surfaces (i.e. front
`surface), a plurality of signal lines X and a plurality of scan lines Y arranged in a matrix, switch
`elements 211 disposed near intersections of the signal lines X and scan lines Y, and pixel
`electrodes 213 connected to the switch elements 211.”).
`
`Kinoshita-’944 at 4:40-53 (“The switch element 211 with the above structure is covered with an
`interlayer insulation film 217 that is formed of an oxide film such as SiO2, or a nitride film such as
`SiNx. The interlayer insulation film 217 is covered with a color filter layer CF that is formed of a
`Invalidity Contentions — Exhibit D-1
`Page D-1–8
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`1(d). a liquid crystal
`layer,
`
`color resist layer, which is processed to have a predetermined pattern by a photo-lithography
`process. In the first embodiment, the interlayer insulation film 217 is formed of, e.g. silicon nitride.
`The color filter layer CF is formed of a negative type color resist layer, which is colored with, e.g.
`red, green or blue. Color filter layers with the respective colors are disposed on the associated
`display pixel sections PX of the corresponding colors.”).
`
`Kinoshita-’944 at Fig. 2.
`
`The ’299 patent concedes that liquid crystal layers were conventional and known in the art.
`
`See, e.g.:
`
`’299 Patent at 12:54-67 (“A liquid crystal display panel used in a conventional mobile telephone
`terminal includes, for example as shown in FIGS. 4 and 5, a TFT substrate 1, a counter substrate
`2, a lower polarizing plate 4, an upper polarizing plate 5, and a sealing member 7. When the
`liquid crystal display panel is seen by the observer, the upper polarizing plate 5, counter
`substrate 2, liquid crystal material 3, TFT substrate 1 and lower polarizing plate 4 are disposed in
`this order from the observer. If the liquid crystal display concerned is a transmission type display,
`a back light 8 is disposed further behind the lower polarizing plate 4 when seen from the
`observer side. The liquid crystal display panel and the back light 8 are held by a concave display
`mold 9 so that a back surface side of the back light 8 is a bottom surface.”).
`
`Moreover, Maekawa-’171 discloses a liquid crystal layer.
`
`See, e.g.:
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at Fig. 16.
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–9
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`
`
`Kinoshita-’944 also discloses a liquid crystal layer.
`
`See, e.g.:
`
`Kinoshita-’944 at 3:61-4:8 (“The liquid crystal panel 100 has an effective display region 102 with
`a diagonal size of 12.1 inches. The effective display region 102 includes a plurality of display
`pixel sections PX arranged in a matrix. The liquid crystal panel 100 includes an array substrate
`200, a counter substrate 400, and a liquid crystal layer 410 that is held between the array
`substrate 200 and counter substrate 400, with alignment films 219 and 405 interposed,
`respectively. This liquid crystal panel 100 suitably adopts a display mode in which display is not
`greatly affected by a variation in cell gap, for example, a twisted nematic (TN) display mode or an
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–10
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`IPS (In Plane Switching) display mode. This embodiment adopts a TN display mode in which
`liquid crystal molecules provided between substrates are aligned with 90° twist.”).
`
`Kinoshita-’944 at Fig. 2.
`
`1(e). a seal member, The ’299 patent concedes that seal members were conventional and known in the art.
`
`See, e.g.:
`
`’299 Patent at 12:54-67 (“A liquid crystal display panel used in a conventional mobile telephone
`terminal includes, for example as shown in FIGS. 4 and 5, a TFT substrate 1, a counter substrate
`2, a lower polarizing plate 4, an upper polarizing plate 5, and a sealing member 7. When the
`liquid crystal display panel is seen by the observer, the upper polarizing plate 5, counter
`substrate 2, liquid crystal material 3, TFT substrate 1 and lower polarizing plate 4 are disposed in
`this order from the observer. If the liquid crystal display concerned is a transmission type display,
`a back light 8 is disposed further behind the lower polarizing plate 4 when seen from the
`observer side. The liquid crystal display panel and the back light 8 are held by a concave display
`mold 9 so that a back surface side of the back light 8 is a bottom surface.”).
`
`Moreover, Maekawa-’171 discloses a seal member.
`
`See, e.g.:
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at Fig. 16.
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–11
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`
`
`Kinoshita-’944 also discloses a seal member.
`
`See, e.g.:
`
`Kinoshita-’944 at 5:4-18 (“A columnar spacer 104 for providing a predetermined gap between the
`array substrate 200 and counter substrate 400 is disposed within the effective display region 102.
`The columnar spacer 104 is fixed to one of the substrates. For example, the columnar spacer
`104 is formed of a black resin disposed on the array substrate 200, and is fixed to the array
`substrate 200. A light-shield layer 250 is formed in a frame-like shape on the outside of the
`effective display region 102. The light-shield layer 250 is formed of a resin having light-shielding
`properties. For example, the light-shield layer 250 is formed of the same black resin as the
`columnar spacer 104. The array substrate 200 and counter substrate 400 are attached to each
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–12
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`1(f). a polarizing
`plate,
`
`other by a seal material 106, with a predetermined gap of, e.g. 4 μm, being maintained by the
`columnar spacer 104.”).
`
`Kinoshita-’944 at Fig. 2.
`
`The ’299 Patent concedes that polarizing plates were conventional and known in the art.
`
`See, e.g.,
`
`’299 Patent at 11:12-17 (“For the lower polarizing plate 4 and the upper polarizing plate 5, for
`example, film-like polarizing plates used in conventional liquid crystal display panels may be
`used. Detailed descriptions on concrete structural examples of the material, etc. will be here
`omitted.”).
`
`’299 Patent at 12:54-67 (“A liquid crystal display panel used in a conventional mobile telephone
`terminal includes, for example as shown in FIGS. 4 and 5, a TFT substrate 1, a counter substrate
`2, a lower polarizing plate 4, an upper polarizing plate 5, and a sealing member 7. When the
`liquid crystal display panel is seen by the observer, the upper polarizing plate 5, counter
`substrate 2, liquid crystal material 3, TFT substrate 1 and lower polarizing plate 4 are disposed in
`this order from the observer. If the liquid crystal display concerned is a transmission type display,
`a back light 8 is disposed further behind the lower polarizing plate 4 when seen from the
`observer side. The liquid crystal display panel and the back light 8 are held by a concave display
`mold 9 so that a back surface side of the back light 8 is a bottom surface.”).
`
`Moreover, Maekawa-’171 discloses a polarizing plate.
`
`See, e.g.:
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at 33:44-50 (“A colored layer 1605 is required in the case of performing a color
`display. In the case of an RGB method, colored layers corresponding to red, green, and blue are
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–13
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`provided for each pixel. Polarizers 1606 and 1607 are provided outside the active matrix
`substrate 1601 and the counter substrate 1602. A protective film 1616 is formed on the surface
`of the polarizer 1606 for alleviating external shocks.”).
`
`Maekawa-’171 at Fig. 16.
`
`
`
`Takahata-’641 also discloses a polarizing plate.
`
`See, e.g.:
`
`Takahata-’641 at ¶ [0033] (“The quarter wave plate 9, in combination with the polarizing plate 10
`of its upper surface, forms an antireflection filter of the circular polarization type. Light from the
`external such as an indoor fluorescent lamp or an outdoor light passes through the polarizing
`plate 10, becoming linearly polarized light, and is transmitted by the quarter wave plate 9,
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–14
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`becoming circularly polarized light, where even if the light is reflected by the transparent
`conductive film, the circularly polarized light, when passing again through the quarter wave plate
`9, changes into linearly polarized light vertical to the transmission axis of the polarizing plate 10,
`so that reflected light is suppressed. In addition, as the quarter wave plate 9, one having flexibility
`to facilitate the input by pen or finger is used.
`
`Takahata-’641 at Fig. 2.
`
`Kinoshita-’944 also discloses a polarizing plate.
`
`See, e.g.:
`
`Kinoshita-’944 at 10:32-40 (“The liquid crystal panel 100 includes a polarizer plate 407 that is
`arranged on an outer surface of the counter substrate 400. The direction of polarization of the
`polarizer plate 407 is set in accordance with characteristics of the liquid crystal layer 410.
`Specifically, the polarizer plate 407 is attached to the other major surface (back surface) of the
`insulation substrate 401 of counter substrate 400 by an adhesive 406. The polarizer plate 407 is
`formed similarly with the first embodiment.”).
`
`1(g) an adhesive
`member, and
`
`Kinoshita-’944 at Fig. 2.
`
`Hashimoto-’091 discloses an adhesive member.
`
`See, e.g.:
`
`Hashimoto-’091 at 30:40-54 (“The saponified cellulose acylate film and the light-polarizing layer
`prepared by the drawing are adhered to each other to prepare a polarizing plate. About the
`direction along which they are adhered to each other, the angle between the direction of the flow
`casting axis of the cellulose acylate film and the draw axis of the polarizing plate is preferably set
`to 45 degrees. The adhesive agent for the adhesion is not particularly limited. Examples thereof
`include PVA-series resins (which may be modified with an acetoacetyl, sulfonic acid, carboxyl,
`oxyalkylene or some other group); and an aqueous solution of a boron compound. The PVA-
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–15
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`series resins are particularly preferable. The thickness of the adhesive agent layer is preferably
`from 0.01 to 10 μm, more preferably from 0.05 to 5 μm after the layer is dried.”).
`
`Takahata-’641 also discloses an adhesive member.
`
`See, e.g.:
`
`Takahata-’641 at ¶ [0035] (“The quarter wave plate 9 and the polarizing plate 10, and/or the
`quarter wave plate 9 and the heat-resistant transparent resin plate 8, may be bonded together
`directly all over (see FIGS. 1 to 3), or may be bonded together indirectly via an optically isotropic
`transparent resin plate. Adhesives to be used for the bonding may be given by acrylate ester
`copolymer or other acrylic resins, urethane resins, silicon resins, rubber resins, aqueous or UV-
`curable adhesives, and the like. Also, the material of the optically isotropic transparent resin plate
`is preferably given by ones of excellent transparency such as polycarbonate, polyarylate,
`polyethersulfone, polysulfone, and norbornene resins. It is noted that the term “optical isotropy” in
`the above embodiments of the present invention refers to those having a retardation value of not
`more than 10 nm, preferably not more than 5 nm.”).
`
`Takahata-’641 ¶ [0045] (“The heat-resistant transparent resin plate 8, in the upper electrode
`plate 1, may be disposed between the quarter wave plate 9 and the polarizing plate 10 (see FIG.
`3), or may be disposed on one side of the quarter wave plate 9 the closer to the upper electrode
`2 (see FIG. 1), or may be disposed on one of the polarizing plate 10 farther from the upper
`electrode 2 (see FIG. 2). Also, in these cases, an optically isotropic transparent resin plate may
`be interposed between the heat-resistant transparent resin plate 8 and the quarter wave plate 9
`or the polarizing plate 10.”).
`
`Takahata-’641 at Fig. 2.
`
`Kinoshita-’944 also discloses an adhesive member.
`
`See, e.g.:
`
`Kinoshita-’944 at 5:32-43 (“The liquid crystal panel 100 includes a pair of polarizer plates 220
`and 407 that are arranged on an outer surface of the array substrate 200 and an outer surface of
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–16
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`the counter substrate 400, respectively. The directions of polarization of the polarizer plates 220
`and 407 are set in accordance with characteristics of the liquid crystal layer 410. Specifically, the
`polarizer plate 220 is attached to the other major surface (back surface) of the insulation
`substrate 201 of array substrate 200 by an adhesive 221. The polarizer plate 407 is attached to
`the other major surface (back surface) of the insulation substrate 401 of counter substrate 400 by
`an adhesive 406.”).
`
`Kinoshita-’944 at 7:65-8:3 (“Then, as shown in FIG. 8B, a polarizer plate 220 with a thickness of
`about 0.3 mm is attached to the outer surface of the glass substrate 201 via an adhesive 221. In
`addition, a polarizer plate 407 with a thickness of about 0.3 mm is attached to the outer surface
`of the glass substrate 401 via an adhesive 406.”).
`
`1(h). a protective
`member;
`
`Kinoshita-’944 at Fig. 9.
`
`Maekawa-’171 discloses a protective member.
`
`See, e.g.:
`
`Maekawa-’171 at 33:39-43 (“In the liquid crystal module shown in FIG. 16, an active matrix
`substrate 1601 and a counter substrate 1602 are fixed with a sealant 1600, with a pixel portion
`1603 and a liquid crystal layer 1604 interposed therebetween which form a display region.”).
`
`Maekawa-’171 at 33:44-50 (“A colored layer 1605 is required in the case of performing a color
`display. In the case of an RGB method, colored layers corresponding to red, green, and blue are
`provided for each pixel. Polarizers 1606 and 1607 are provided outside the active matrix
`substrate 1601 and the counter substrate 1602. A protective film 1616 is formed on the surface
`of the polarizer 1606 for alleviating external shocks.”).
`
`Maekawa-’171 at Fig. 16.
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–17
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`
`
`Takahata-’641 also discloses a protective member.
`
`See, e.g.:
`
`Takahata-’641 at ¶ [0031] (“Basically, the touch panel is so structured that the upper electrode
`plate 1 in which the upper electrode 2 made of a transparent conductive film is provided on its
`lower surface and the lower electrode plate 3 in which the lower electrode 4 made of a
`transparent conductive film is provided on its upper surface are adhesively fixed only at their non-
`display area portions with the two electrodes 1 and 3 opposed to each other via the air layer 6. In
`the case of a low-reflection touch panel of the circular polarization type, the upper electrode plate
`1 is implemented by one in which at least the quarter wave plate 9 and the polarizing plate 10
`whose absorption axis crosses the optical axis of the quarter wave plate 9 at an angle of 45° or
`135° are laminated in an order from the upper electrode 2 side. Also, each of the upper electrode
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–18
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`plate 1 and the lower electrode plate 3 is formed of a single layer or by laminating a plurality of
`layers in allover bonding. First to third embodiments of the present invention are characterized in
`that in each of such low-reflection touch panels, the upper electrode plate 1 has a 0.15 to 0.8 mm
`thick, optically isotropic heat-resistant transparent resin plate 8 having a property of a glass
`transition temperature of not less than 150° C., and that the heat-resistant transparent resin plate
`8 is bonded directly or indirectly with the quarter wave plate 9 all over (see FIGS. 1 to 3). It is
`noted here that in the individual embodiments of the present invention, the term “plate” includes
`thin ones of sheets or films or the like.”).
`
`Takahata-’641 at ¶¶ [0036]-[0042] (“The material of the heat-resistant transparent resin plate 8 is
`given by an optically isotropic transparent resin having a glass transition temperature of not less
`than 150° C. molded to a thickness of 0.15 to 0.8 mm, the optically isotropic transparent resin
`selected from among polycarbonate resins, norbornene resins, epoxy resins, siloxane resins,
`polyarylate resins, polyethersulfone resins, polysulfone resins, ultraviolet-curable acrylic resins,
`epoxy acrylic resins, and other heat-resistant acrylic resins.”).
`
`(“Also, the heat-resistant transparent resin plate 8 of each embodiment of the present invention,
`with its thickness set to not more than 0.8 mm, allows the input by pen or finger to be done
`adequately lightly even when incorporated as one constituent layer of the upper electrode plate 1
`by virtue of its high flexibility as compared with glass plates. More preferably, a heat-resistant
`transparent resin plate 8 having a thickness of not more than 0.7 mm is used. Still, the heat-
`resistant transparent resin plate 8 will not fracture, unlike glass plates, thus greatly facilitating the
`handling of the touch panel during the assembly process, and eliminating the possibility of
`damage during input operations with the touch panel. Moreover, rolling process as well becomes
`applicable, which facilitates defoaming process or the like during the bonding process.”).
`
`Takahata-’641 at ¶ [0045] (“The heat-resistant transparent resin plate 8, in the upper electrode
`plate 1, may be disposed between the quarter wave plate 9 and the polarizing plate 10 (see FIG.
`3), or may be disposed on one side of the quarter wave plate 9 the closer to the upper electrode
`2 (see FIG. 1), or may be disposed on one of the polarizing plate 10 farther from the upper
`electrode 2 (see FIG. 2). Also, in these cases, an optically isotropic transparent resin plate may
`be interposed between the heat-resistant transparent resin plate 8 and the quarter wave plate 9
`or the polarizing plate 10.”).
`
`Invalidity Contentions — Exhibit D-1
`Page D-1–19
`
`JDI/PLD - EX. 2002
`TIANMA MICROELECTRONICS
`CO. LTD. v. JDI/PLD
`IPR2021-01028
`
`

`

`
`
`Takahata-’641 at ¶¶ [0059]-[0064] (“That is, in the touch panel having an antireflection filter of the
`circular polarization type, the upper electrode plate has the 0.15 to 0.8 mm thick optically
`isotropic heat-resistant transparent resin plate having the characteristic of the glass transition
`temperature of not less than 150° C., and the heat-resistant transparent resin plate is laminated
`directly or indirectly on the quarter wave plate all over their surfaces. Therefore, thermal
`expansion of the quarter wave plate and the polarizing plate are almost fully suppressed even
`under a high-temperature environment over 70° C. such as in a vehicle with its windows closed
`under summer's direct sunlight, as with glass plates, so that a stable state free from occurrence
`of waviness or strain can be maintained. Also, since the heat-resistant transparent resin plate is
`laminated directly or indirectly on the quarter wave plate all over their surfaces, stress applied to
`the quarter wave plate can be dispersed so that occurrence of retardation changes can be
`almost fully suppressed even under the above high-temperature environment, as with glass
`plates. That is, the antireflection characteristics are less impaired.”).
`
`Takahata-’641 at Figs. 1-3, 8, 9.
`
`Toyomaki-’816 also discloses a protective member.
`
`