DECLARATION OF DR. JAMES L. MULLINS
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`REGARDING U.S. PATENT NO. 7,995,047
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`REGARDING U.S. PATENT NO. 7,995,047
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`Table of Contents
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`Page
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`I.
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`II.
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`INTRODUCTION ........................................................................................... 3
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`QUALIFICATIONS ........................................................................................ 4
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`III. BACKGROUND ON PUBLIC ACCESSIBILITY ........................................ 6
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`A.
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`B.
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`C.
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`D.
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`Scope of This Declaration ..................................................................... 6
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`Person of Ordinary Skill in the Art ....................................................... 8
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`Library Catalog Records and Other Resources ...................................10
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`Periodicals ...........................................................................................13
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`IV. OPINION REGARDING AUTHENTICITY AND PUBLIC
`ACCESSIBILITY ..........................................................................................15
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`A. Authenticity .........................................................................................15
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`B.
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`Public Accessibility .............................................................................19
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`1.
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`Evidence of Public Accessibility Through Print Copies in
`Libraries ....................................................................................19
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`2.
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`Other Evidence of Public Accessibility ....................................23
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`C.
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`Conclusion ...........................................................................................24
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`V.
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`RIGHT TO SUPPLEMENT ..........................................................................25
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`VI.
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`JURAT ...........................................................................................................25
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`I, Dr. James L. Mullins, declare as follows:
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`I.
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`INTRODUCTION
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`1. My name is Dr. James L. Mullins. I have been retained by Baker Botts
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`and understand that the opinions I express herein may be filed publicly, including in
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`connection with inter partes review proceedings for U.S. Patent No. 7,995,047.
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`2.
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`I am presently Dean Emeritus of Libraries and Esther Ellis Norton
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`Professor Emeritus at Purdue University. My career as a professional and
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`academic/research librarian spanned more than 44 years including library positions
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`at Indiana University, Villanova University, Massachusetts Institute of Technology,
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`and Purdue University. Appendix A is a true and correct copy of my curriculum
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`vitae describing my background and experience.
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`3.
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`In 2018, I founded the firm Prior Art Documentation Librarian
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`Services, LLC, now located at 205 St. Cuthbert, Williamsburg, VA 23188. Further
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`information about my firm, Prior Art Documentation Librarian Services, LLC
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`(PADLS), is available at www.priorartdoclib.com.
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`4.
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`I have been retained by Baker Botts to research and then offer my
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`opinions on the authenticity and dates of public accessibility of various documents.
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`For this service, I am being paid my usual hourly fee of $275. I have no stake in the
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`outcome of this proceeding or any related litigation or administrative proceedings,
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`and my compensation in no way depends on the substance of my testimony or the
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`outcome of this proceeding.
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`II. QUALIFICATIONS
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`5.
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`I received a Bachelor of Arts degree in History, Religion and Political
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`Science in 1972 as well as a Master of Arts degree in Library Science in 1973 from
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`the University of Iowa. I received my Ph.D. in Academic Library Management in
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`1984 from Indiana University. Over the past forty-four years, I have held various
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`positions as a leader in the field of library and information sciences.
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`6.
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`I am presently Dean Emeritus of Libraries and Esther Ellis Norton
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`Professor Emeritus at Purdue University, and have been since January 1, 2018. I
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`have been previously employed as follows:
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`• Dean of Libraries and Professor and Esther Ellis Norton Professor,
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`Purdue University, West Lafayette, IN (2004-2017)
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`• Assistant/Associate Director
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`for Administration, Massachusetts
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`Institute of Technology (MIT) Libraries, Cambridge, MA (2000-2004)
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`• University Librarian and Director, Falvey Memorial Library, Villanova
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`University, Villanova, PA (1996-2000)
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`• Director of Library Services, Indiana University South Bend, South
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`Bend, IN (1978-1996)
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`• Part-time Instructor, School of Library and Information Science,
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`Indiana University, Bloomington, IN (1979-1996)
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`• Associate Law Librarian, and associated titles, Indiana University
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`School of Law, Bloomington, IN (1974-1978)
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`• Catalog Librarian, Assistant Professor, Georgia Southern College (now
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`University), Statesboro, GA (1973-1974)
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`7.
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`I am a member of the American Library Association (“ALA”), where I
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`served as the chair of the Research Committee of the Association of College and
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`Research Libraries (“ACRL”). My service to ALA included service on the editorial
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`board of the most prominent library journal, College and Research Libraries. I also
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`served on the Standards Committee, College Section of the Association of College
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`and Research Libraries, where I was instrumental in developing a re-issue of the
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`Standards for College Libraries in 2000.
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`8.
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`I am an author of numerous publications in the field of library science,
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`and have given presentations in library sciences at national and international
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`conferences. During more than 44 years as an academic librarian and library science
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`scholar, I have gained extensive experience with catalog records and online library
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`management systems
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`(“LMS”) built using Machine-Readable Cataloging
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`(“MARC”) standards. As an academic library administrator, I have had
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`responsibility to ensure that students were educated to identify, locate, assess, and
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`integrate information garnered from research library resources. I have also
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`facilitated the research of faculty colleagues either directly or through the provision
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`of and access to the requisite print and/or digital materials and services at the
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`universities where I worked.
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`9.
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`Based on my decades of experience, identified above, and detailed in
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`my curriculum vitae, I consider myself to be an expert in the field of library science
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`and academic library administration. I have previously offered my opinions on the
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`public availability and authenticity of documents in over 40 cases. I have been
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`deposed in one case.
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`III. BACKGROUND ON PUBLIC ACCESSIBILITY
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`A.
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`Scope of This Declaration
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`10.
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`I am not a lawyer, and I am not rendering an opinion on the legal
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`question of whether a particular document is, or is not, a “printed publication” under
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`the law. I am, however, rendering my expert opinion on the authenticity of the
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`documents referenced herein, and when and how these documents were
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`disseminated or otherwise made publicly accessible to the extent that persons
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`interested and ordinarily skilled in the subject matter or art, exercising reasonable
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`diligence, could have located the documents.
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`11.
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`I am informed by counsel that an item is considered authentic if there
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`is sufficient evidence to support a finding that the item is what it is claimed to be. I
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`am also informed that authenticity can be established based on the contents of the
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`document itself, such as the appearance, content, substance, internal patterns, or
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`other distinctive characteristics of the item.
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`12.
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`I am informed by counsel that a given reference qualifies as “publicly
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`accessible” if it was disseminated or otherwise made available such that a person
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`interested in and ordinarily skilled in the relevant subject matter could locate it
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`through the exercise of ordinary diligence.
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`13. While I understand that the determination of public accessibility under
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`the foregoing standard rests on a case-by-case analysis of the facts particular to an
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`individual publication, I also understand that a printed publication is rendered
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`“publicly accessible” if it is cataloged and indexed by a library such that a person
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`interested in the relevant subject matter could locate it (i.e., I understand that
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`cataloging and indexing by a library is sufficient, though there are other ways that a
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`printed publication may qualify as “publicly accessible”). One manner of sufficient
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`indexing is indexing according to subject matter. I understand that it is not necessary
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`to prove someone actually looked at the printed publication in order to show it was
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`publicly accessible by virtue of a library’s cataloging and indexing thereof. I
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`understand that cataloging and indexing by a single library of a single instance of a
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`particular printed publication is sufficient. I understand that, even if access to a
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`library is restricted (although that is not the case for the documents I researched in
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`this declaration), a printed publication that has been cataloged and indexed therein
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`is publicly accessible so long as a presumption is raised that the portion of the public
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`concerned with the relevant subject matter would know of the printed publication. I
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`also understand that the cataloging and indexing of information that would guide a
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`person interested in the relevant subject matter to the printed publication, such as the
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`cataloging and indexing of an abstract for the printed publication, is sufficient to
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`render the printed publication publicly accessible. I understand the citation of a
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`publication by others in the field is one factor to consider in determining public
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`accessibility.
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`14.
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`I understand that evidence showing the specific date when a printed
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`publication became publicly accessible is not necessary. Rather, routine business
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`practices, such as general library cataloging and indexing practices, can be used to
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`establish an approximate date on which a printed publication became publicly
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`accessible.
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`B.
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`15.
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`Person of Ordinary Skill in the Art
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`In forming the opinions expressed in this declaration, I have reviewed
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`the documents and appendices referenced herein. These materials are records
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`created in the ordinary course of business by publishers, libraries, indexing services,
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`and others. From my decades of experience, I am familiar with the process for
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`creating many of these records, and I know that these records are created by people
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`with knowledge of the information contained within the record. Further, these
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`records are created with the expectation that researchers and other members of the
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`public will use them. All materials cited in this declaration and in the related exhibits
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`are of a type that experts in my field would reasonably rely upon and refer to in
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`forming their opinions.
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`16.
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`I have been informed by counsel that the subject matter of this
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`proceeding relates to electronic circuitry for driving displays such as an organic EL
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`(electro-luminescence) panels, LED panels, and the like.
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`17.
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`I have been informed by counsel that a “person of ordinary skill in the
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`art at the time of the inventions” (POSITA) is a hypothetical person who is presumed
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`to be familiar with the relevant field and its literature at the time of the inventions.
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`This hypothetical person is also a person of ordinary creativity, capable of
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`understanding the scientific principles applicable to the pertinent field.
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`18.
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`I have been informed by counsel that persons of ordinary skill in this
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`subject matter or art would have included someone with at least an undergraduate
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`degree in electrical engineering (or equivalent subject) together with two or three
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`years of experience in designing circuits for driving light-emitting devices including
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`organic light-emitting diodes, or a Ph.D. with experience in the same.
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`19.
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`I understand from counsel U.S. Patent No. 7,995,047 was filed in the
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`United States on December 12, 2007 and that it purports to claim priority to an
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`application filed in Japan on December 13, 2006. The Shimoda reference I discuss
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`herein has a copyright date of 2003. Accordingly, I have been asked to assess public
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`accessibility from the 2003-2006 timeframe. By the 2003-2006 timeframe, a person
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`of ordinary skill in the art would have had access to a vast array of print resources,
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`including at least the documents referenced below, as well as to an ever-expanding
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`set of online resources.
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`C. Library Catalog Records and Other Resources
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`20. Some background on MARC
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`(Machine-Readable Cataloging)
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`formatted records, OCLC, and WorldCat is helpful to understand the library catalog
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`records discussed in this declaration. I am fully familiar with the library cataloging
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`standard known as the MARC standard, which is an industry-wide standard method
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`of storing and organizing library catalog information1. MARC practices have been
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`consistent since the MARC format was developed by the Library of Congress in the
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`1960s, and by the early 1970s became the U.S. national standard for disseminating
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`bibliographic data. By the mid-1970s, MARC format became the international
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`standard, and persists through the present. A MARC-compatible library is one that
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`has a catalog consisting of individual MARC records for each of its items. The
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`underlying MARC format (computer program) underpins the online public access
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`1 The full text of the standard is available from the Library of Congress at
`http://www.loc.gov/marc/bibliographic/.
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`catalog (OPAC) that is available to library users to locate a particular holding of a
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`library. Today, MARC is the primary communications protocol for the transfer and
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`storage of bibliographic metadata in libraries2. The MARC practices discussed
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`below were in place during the late 1990s time frame relevant to the documents
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`referenced herein.
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`21. Online Computer Library Center (“OCLC”) is a not-for-profit
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`worldwide consortium of libraries. Similar to MARC standards, OCLC’s practices
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`have been consistent since the 1970s through the present. Accordingly, the OCLC
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`practices discussed below were in place during the time frame discussed in my
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`opinions section. OCLC was created “to establish, maintain and operate a
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`computerized library network and to promote the evolution of library use, of libraries
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`themselves, and of librarianship, and to provide processes and products for the
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`benefit of library users and libraries, including such objectives as increasing
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`availability of library resources to individual library patrons and reducing the rate of
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`rise of library per-unit costs, all for the fundamental public purpose of furthering
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`2 Almost every major library in the world uses a catalog that is MARC-compatible.
`See, e.g., Library of Congress, MARC Frequently Asked Questions (FAQ),
`https://www.loc.gov/marc/faq.html (last visited Mar. 2, 2020) (“MARC is the
`acronym for MAchine-Readable Cataloging. It defines a data format that emerged
`from a Library of Congress-led initiative that began nearly forty years ago. It
`provides the mechanism by which computers exchange, use, and interpret
`bibliographic information, and its data elements make up the foundation of most
`library catalogs used today.”). MARC is the ANSI/NISO Z39.2-1994 (reaffirmed
`2009) standard for Information Interchange Format.
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`ease of access to and use of the ever-expanding body of worldwide scientific, literary
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`and educational knowledge and information.”3 Among other services, OCLC and
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`its members are
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`responsible
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`for maintaining
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`the WorldCat database
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`(http://www.worldcat.org/), used by libraries throughout the world.
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`22. WorldCat is the world’s largest public online catalog, maintained by
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`the OCLC, a not-for-profit international library consortium, and built with the
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`records created by the thousands of libraries that are members of OCLC. OCLC
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`provides bibliographic and abstract information to the public based on MARC-
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`compliant records through its OCLC WorldCat database. WorldCat requires no
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`knowledge of MARC tags and code and does not require a login or password.
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`WorldCat is easily accessible through the World Wide Web to all who wish to search
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`it; there are no restrictions to be a member of a particular community, etc. The date
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`a given catalog record was created (corresponding to the MARC Field 008) appears
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`in some detailed WorldCat records as the Date of Entry but not necessarily all.
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`WorldCat does not provide a view of the underlying MARC format for a specific
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`WorldCat record. In order to see the underlying MARC format the researcher must
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`locate the book in a holding library listed among those shown in WorldCat, and
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`3 OCLC Online Computer Library Center, Inc., Amended Articles of Incorporation
`of OCLC Online Computer Library Center, Inc., Third Article (OCLC, Dublin,
`Ohio) Revised November 30, 2016,
`https://www.oclc.org/content/dam/oclc/membership/articles-of-incorporation.pdf.
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`search the online public catalog (“OPAC”) of a holding library. Whereas WorldCat
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`records are widely available, the availability of library specific MARC formatted
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`records varies from library to library. When a specific library wishes to make the
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`underlying MARC format available there will be a link from the library’s OPAC
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`display, often identified as a MARC record or librarian/staff view.
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`D.
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`Periodicals
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`23. A library typically creates a catalog record for a periodical publication
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`(also referred to as a “serial”) when the library receives its first issue. When the
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`institution receives subsequent issues/volumes of the periodical, the issues/volumes
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`are checked in (often using a date stamp), added to the institution’s holding records,
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`and made available very soon thereafter – normally within a few days of receipt or
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`(at most) within a few weeks of receipt. The initial periodicals record will sometimes
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`not reflect all subsequent changes in publication details (including minor variations
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`in title, frequency, etc.).
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`24. As of 2003-2006, the timeframe I have been asked to investigate, a
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`researcher would have been able to discover materials relevant to his or her topic in
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`a variety of ways. One common means of discovery was to search for relevant
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`information in an index of periodical and other publications, including through
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`OCLC. Having found relevant material, the researcher would then normally obtain
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`it online, look for it in libraries, or purchase it from the publisher, a bookstore, a
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`document delivery service, or other provider. Sometimes, the date of a document’s
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`public accessibility will involve both indexing and library date information. Date
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`information for indexing entries is, however, often unavailable. This is especially
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`true for online indices.
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`25.
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`Indexing services have used a wide variety of controlled vocabularies
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`to provide subject access and other means of discovering the content of documents.
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`The formats in which these access terms are presented vary from service to service.
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`26. Online indexing services have commonly provided bibliographic
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`information, abstracts, and full-text copies of the indexed publications, along with a
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`list of the documents cited in the indexed publication. These services also often
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`provide lists of publications that cite a given document. A citation of a document is
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`additional evidence that the document was publicly available and in use by
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`researchers no later than the publication date of the citing document.
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`27. Wiley Online Library – contains a full range of unrivaled journals,
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`books, major reference works, and databases. Multidisciplinary collection of online
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`resources covering life, health, and physical sciences; social science; and the
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`humanities—850 scientific and scholarly societies around the world, and access to
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`over 7.5 million articles from over 1,600 journals, over 21,000 online books, and
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`hundreds of multi-volume reference works, databases, and other resources online.
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`https://onlinelibrary.wiley.com/researchers
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`28. Wisconsin TechSearch (WTS) – WTS is a set of services offered by
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`the University of Wisconsin Libraries. WTS offers an array of article delivery and
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`research services to any individual or organization who requests the specialized
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`skills of WTS staff in locating and retrieving information, regardless of whether the
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`individual is affiliated with the University of Wisconsin.4
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`IV. OPINION REGARDING AUTHENTICITY AND
`ACCESSIBILITY
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`PUBLIC
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`29.
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`I have been asked to opine on “An Integrated Poly-Si TFT Current Data
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`Driver with a Data-line Pre-Charge Function” authored by M. Shimoda, et al.
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`published in Journal of the Society for Information Display in its volume 11, issue
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`number 3, 2003, pages 461-466 (“Shimoda”)
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`30. For consistency and clarification, Shimoda, when used in this
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`declaration, refers not only to the Shimoda article but also the journal volume and
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`issue in which it was published: Journal of the Society for Information Display in its
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`volume 11, issue number 3, 2003.
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`A. Authenticity
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`31.
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`I have been asked to review the version of Shimoda found in Exhibit
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`1004 and to analyze its authenticity.
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`4 https://wts.wisc.edu/
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`32.
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`I have evaluated the authenticity of the Shimoda reference in several
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`ways:
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`• by assessing a download I made from Wiley Online Library, the
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`publisher of Shimoda (Ex. 1004);
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`• by assessing scans of a print copy of Shimoda provided to me at my
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`request on December 28, 2021 by the Wisconsin TechSearch (WTS) of
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`the copy of Shimoda owned by the Linda Hall Library (Ex. 1020); and
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`• by assessing scans of a print copy of Shimoda, Attachment A-3,
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`provided to me at my request on December 28, 2021 by Wisconsin
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`TechSearch (WTS) of the copy of Shimoda owned by the United States
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`Library of Congress (Ex. 1021).
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`33. As stated above, I accessed and downloaded Exhibit 1004 from the
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`Wiley Online Library database by my emeritus faculty status through Purdue
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`University Libraries at this URL:5
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`34. Exhibit 1020 was provided to me at my request on December 28, 2021,
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`by Wisconsin TechSearch of the print copy of Shimoda owned by the Linda Hall
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`Library. Exhibit 1020 includes scans of Shimoda: issue cover, Journal of the Society
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`for Information Display in its volume 11, issue number 3, 2003 with a stamp that
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`5 https://sid-onlinelibrary-wiley-
`com.ezproxy.lib.purdue.edu/doi/abs/10.1889/1.1821286?sid=vendor%3Adatabase
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`reads “LINDA HALL DEC 09 2004 LIBRARY” as reproduced below; journal
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`information page; table of contents with a stamp that reads “LINDA HALL DEC
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`09 2004 LIBRARY” as reproduced below; and the Shimoda article on pages 461-
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`466.
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`
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`The figure on the left is the date stamp from the issue cover, and the figure on the
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`right is the date stamp from the table of contents of Exhibit 1020. All identifying
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`characteristics, such as stamps and notations on Exhibit 1020, are consistent with
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`library practice and procedure that I have observed during my career as a
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`professional librarian, specifically when reviewing scans from the collections of the
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`Linda Hall Library. I have no cause for concern about the authenticity or accuracy
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`of these identifying attributes. Exhibit 1020 was found within the custody of a
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`library, the Linda Hall Library, one of the most likely locations for an authentic
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`document to be publicly accessible.
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`35. Exhibit 1021 was provided to me at my request on December 28, 2021,
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`by Wisconsin TechSearch (WTS) of the print copy of Shimoda owned by the Library
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`of Congress. Exhibit 1021 includes scans of Shimoda: front and back cover and
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`spine of the bound volume of the Journal of the Society for Information Display,
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`[11] 2003 with a printed call number that reads “TK5103.5 .N34 Set 1”; issue cover,
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`Journal of the Society for Information Display in its volume 11, issue number 3,
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`2003; journal information page; table of contents with a stamp that reads “LIBRARY
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`OF CONGRESS JUN 15 2005” as reproduced below; and the Shimoda article on
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`pages 461-466.
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`
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`All identifying characteristics, such as stamps and notations on Exhibit 1021 are
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`consistent with library practice and procedure that I have observed during my career
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`as a professional librarian, specifically when reviewing scans from the collections
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`of the Library of Congress. I have no cause for concern about the authenticity or
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`accuracy of these identifying attributes. Exhibit 1021 was found within the custody
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`of a library, the Library of Congress, one of the most likely locations for an authentic
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`document to be publicly accessible.
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`36.
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`I conclude, based on finding print copies of Shimoda in research
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`libraries (Linda Hall Library and the Library of Congress) and online through a
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`reputable, publisher database (Wiley Online Library) that Exhibit 1004, Exhibit
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`1020, and Exhibit 1021 are each authentic, true, and correct copies of Shimoda.
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`Each of Exhibit 1004, Exhibit 1020, and Exhibit 1021 are authentic, true, and correct
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`documents.
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`B.
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`Public Accessibility
`
`1.
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`Evidence of Public Accessibility Through Print Copies in
`Libraries
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`37. Exhibit 1022 is a true and correct copy of the WorldCat entry for
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`Shimoda, Journal of the Society for Information Display as a serial publication.
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`Shimoda was included among the papers published in the Journal of the Society for
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`Information Display in its volume 11, issue number 3, 2003.
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`38.
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` I obtained Exhibit 1022 by completing a search on WorldCat on
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`January 3, 2022, for Journal of the Society for Information Display. The document
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`cataloged in this record is a periodical record for Journal of the Society for
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`Information as verified by title: Journal of the Society for Information Display; and
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`publisher: Society for Information Display CA.
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`39. When I searched this WorldCat record for holdings of Journal of the
`
`Society for Information Display in Missouri, the Linda Hall Library was third on the
`
`list among the 436 libraries worldwide that held the Journal of the Society for
`
`Information Display. See Exhibit 1022. When I searched this WorldCat record for
`
`holdings of Journal of the Society for Information Display in the District of
`
`Page 19 of 25
`
`SAMSUNG, EXH. 1019, P. 19
`
`
`
`Columbia, the Library of Congress was first on the list among the 436 libraries
`
`worldwide that held the Journal of the Society for Information Display. See Exhibit
`
`1023.
`
`40. WorldCat was accessible by a researcher to locate Journal of the
`
`Society for Information Display by title: Journal of the Society for Information
`
`Display; and by subject headings: Information display systems – Periodicals; and/or
`
`Information Display Systems. The searches discussed above could have been
`
`completed anywhere in the world by a researcher who had access to WorldCat and
`
`its predecessor database through an OCLC member library in 2003/2004 through
`
`‘open access’ freely available to all.
`
`41.
`
`In the 2003 to 2006 timeframe, research libraries regularly maintained
`
`records in the course of library operation. One such regularly-maintained record
`
`was OPAC entries.
`
`42. Exhibit 1024 is a download I made from the Linda Hall Library OPAC
`
`(online catalog) on January 3, 2022. The document cataloged in this OPAC
`
`periodical record is for Journal of the Society for Information Display as verified by
`
`title: Journal of the Society for Information Display; publisher and publication date:
`
`Society for Information Display CA. v. 1993 -. The “1993-“ indicates an “open
`
`entry,” that is, a serial that started in 1993 and continues with subsequent issue. The
`
`holdings record at the Linda Hall Library reads:
`
`Page 20 of 25
`
`SAMSUNG, EXH. 1019, P. 20
`
`
`
`
`
`Shimoda could have been located in 2004 by searching on the Linda Hall Library
`
`OPAC (online catalog) for the title: Journal of the Society for Information Display;
`
`and/or by searching the subject heading: Information display systems – Periodicals.
`
`43. Exhibit 1025 is a download I made from the Library of Congress OPAC
`
`(online catalog) on January 3, 2022. The document cataloged in this record is
`
`Journal of the Society for Information Display verified by the fields listing main
`
`title: Journal of the Society for Information Display; publisher and publication date:
`
`Society for Information Display, 1993- . The “1993-“ indicates an “open entry,”
`
`that is, a serial that started in 1993 and continues with subsequent issue. The
`
`holdings record at the Library of Congress reads:
`
`
`
`Page 21 of 25
`
`SAMSUNG, EXH. 1019, P. 21
`
`
`
`Shimoda could have been located in 2005 in the Library of Congress OPAC by
`
`searching for the title: Journal of the Society for Information Display; or by
`
`searching the subject heading: Information display systems – Periodicals; and/or
`
`Information display systems. Evidence that Library of Congress owns this issue of
`
`Journal of the Society for Information Display is found in the field titled “Older
`
`receipts” as shown above.
`
`44. The date stamp on Exhibit 1020 indicates receipt of Shimoda on
`
`December 9, 2004 by the Linda Hall Library. From my experience, a typical amount
`
`of time to process a journal article such as volume 11, issue number 3, 2003 of the
`
`Journal of the Society for Information Display, and transfer to the shelves and make
`
`accessible to a researcher is a week to 10 days. Therefore, Shimoda would have
`
`been publicly accessible no later than December 19, 2004 at the Linda Hall Library.
`
`45. The date stamp on Exhibit 1021 indicates receipt of Shimoda on June
`
`15, 2005 by the Library of Congress. From my experience, a typical amount of time
`
`to process a journal article such as volume 11, issue number 3, 2003 of the Journal
`
`of the Society for Information Display, and for transfer to the shelves and make
`
`accessible to a researcher is a week to 10 days. Therefore, Shimoda would have
`
`been publicly accessible no later than June 25, 2005 at the Library of Congress.
`
`Page 22 of 25
`
`SAMSUNG, EXH. 1019, P. 22
`
`
`
`46. Thus, in my opinion, Shimoda would have been publicly available by
`
`December 19, 2004 at the Linda Hall Library and June 25, 2005 at the Library of
`
`Congress.
`
`2. Other Evidence of Public Accessibility
`
`47.
`
`I understand that there are other manners to prove public accessibility,
`
`such as by showing that Shimoda was actually cited in papers presented at a
`
`conference or articles published in research journals. This supports public
`
`availability as it shows that other researchers had, in fact, accessed Shimoda. To
`
`ascertain whether others had cited Shimoda, I performed a search on Google Scholar.
`
`Below are two such citations to Shimoda.
`
`48. Exhibit 1026 (“Sanford”) is an article by James L. Sanford and Frank
`
`R. Libsch, titled “Vt Compensated Voltage-data a-Si TFT AMOLED Pixel Circuits,”
`
`published in Journal of the Society of Information Display, volume 12, issue 1, 2004,
`
`on pages 65-73. I downloaded Exhibit 1026 on January 3, 2022, by my emeritus
`
`faculty status at Purdue University. In the “References” section, Sanford cites
`
`Shimoda as reference number 24, as shown below:
`
`49. Exhibit 1027 (“Son”) is an article by Son, Y.-S et al., titled “P40: A
`
`Novel Data Driving Method and Circuits for AMOLED Displays,” SID Symposium
`
`
`
`Page 23 of 25
`
`SAMSUNG, EXH. 1019, P. 23
`
`
`
`Digest of Technical Papers, volume 37, 2006, on pages 343-346. I downloaded
`
`Exhibit 1027 on January 3, 2022, by my emeritus faculty status at Purdue University.
`
`In the “References” section, Son cites Shimoda as reference number [6], as shown
`
`below:
`
`50. Thus, in my opinion, further evidence of the public availability of
`
`Shimoda includes other researchers citin
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