UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`Petitioner
`
`v.
`
`YECHEZKAL EVAN SPERO,
`Patent Owner
`
`Case IPR2022-00315
`U.S. Patent No. 9,955,551 C1
`
`DECLARATION OF JIANZHONG JIAO, PH.D., IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,955,551
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`VWGoA EX1003
`U.S. Patent No. 9,955,551
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`

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`Case IPR2023-00315
`U.S. Patent No. 9,955,551
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`TABLE OF CONTENTS
`
`
`I.
`INTRODUCTION ......................................................................................... 1
`SUMMARY OF GROUNDS ......................................................................... 2
`II.
`SUMMARY OF OPINIONS ......................................................................... 2
`III.
`IV. QUALIFICATIONS ...................................................................................... 3
`V. MATERIALS CONSIDERED ....................................................................... 7
`VI. LEGAL STANDARDS ................................................................................10
`A. My Understanding of Claim Construction.......................................... 10
`B.
`A Person of Ordinary Skill in the Art ................................................. 12
`C. My Understanding of Obviousness .................................................... 12
`VII. LEVEL OF ORDINARY SKILL IN THE ART ...........................................18
`VIII. OVERVIEW OF THE ’551 PATENT CLAIMS ...........................................19
`A.
`Technology Overview of the Patent Claims ....................................... 19
`B.
`Independent Claims 24, 32, 40, and 48 .............................................. 28
`C.
`Prosecution History Summary ........................................................... 32
`D.
`Level of Ordinary Skill in the Art ...................................................... 32
`E.
`Claim Construction ............................................................................ 33
`“electronic circuitry apparatus for the controlled powering of the
`
`LEDs” .......................................................................................33
`IX. OVERVIEW OF APPLIED REFERENCES.................................................34
`A. Ground 1 – Beam and Satonaka ......................................................... 34
`U.S. Patent No. 6,144,158 to Beam ...........................................34
`
`Japanese Patent Publication No. H7-101291 to Satonaka ..........38
`
`Ground 2 – U.S. Patent No. 6,049,749 to Kobayashi with Beam-
`Satonaka ............................................................................................ 40
`Ground 3 – Karlsson and Nakamura .................................................. 45
` WIPO Patent Publication No. 1998/054030 to Karlsson ...........45
`Japanese Patent Publication No. JPH07-65603 to Nakamura ....49
`
`D. Ground 4 - Gotou with Karlsson-Nakamura ....................................... 53
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`B.
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`C.
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`B.
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`Case IPR2023-00315
`U.S. Patent No. 9,955,551
`X. GROUND 1: BEAM AND SATONAKA RENDER OBVIOUS
`CLAIMS 24, 25, 30–33, 38–41, 46–49, AND 54–55 ....................................55
`A. A POSA would have been motivated to combine Beam and
`Satonaka with a reasonable expectation of success. ........................... 56
`Independent Claim Structural Elements ............................................. 61
`[24.P]/[32.P]/[40.P]/[48.P] “An
`illuminating device having
`
`automatic control of light provided to an illuminated area
`comprising” ..............................................................................61
`[24.1]/[32.1]/[40.1]/[48.1]
`“a
`structure
`for
`incorporating
`illuminating device elements, wherein the structure comprises a
`motor vehicle” ..........................................................................63
`[24.2]/[32.2]/[40.2]/[48.2] “a plurality of individually controllable
`LEDs incorporated in the structure via at least one headlamp
`mounted to the structure, each headlamp including at least one of
`the LEDs, the LEDs in communication with a power source” ...64
`[24.3]/[32.3]/[40.3]/[48.3] “electronic circuitry apparatus for the
`controlled powering of the LEDs and other of the illuminating
`device elements” .......................................................................66
`[24.4]/[32.4]/[40.4]/[48.4] “one or more processors” ................68
`[24.5]/[32.5]/[40.5]/[48/5] “one or more sensors, including one or
`more cameras, placed on the structure for detecting coordinate-
`specific information about the illuminated area, at least one of said
`cameras in communication with power, and in communication
`with at least one of the one or more processors” .......................69
`(a) Beam discloses this element. .........................................69
`(b)
`Satonaka also discloses this element. ............................71
`(c)
`It would have been obvious to modify Beam in view of
`Satonaka with a reasonable expectation of success. ......72
`[24.6]/[32.6]/[40.6]/[48.6] “a controller, including at least one of
`the one or more processors, integrated with the structure via
`mounting, in communication with the LED controlling power
`electronic circuitry apparatus, said controller arranged to process
`the
`information communicated from
`the cameras and
`to
`automatically control the light provided to the illuminated area”
`..................................................................................................74
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`[24.7]/[32.7]/[40.7]/[48.7] “memory storing instructions that,
`when executed by one or more processors of the controller, enable
`the controller to:” ......................................................................75
`Independent Claim 24 Instructions ..................................................... 76
`[24.8] “determine coordinates corresponding to another vehicle,
`
`based on the coordinate-specific information” ..........................76
`[24.9] “select a cluster of the LEDs that emit light toward at
`portion of the other vehicle based on the LEDs having emission
`aimings associated with the first coordinates” ...........................79
`[24.10] “change emission of the selected cluster of LEDs relative
`to emission of other LEDs not included in the cluster to create
`headlamp illumination that preserves a first level of illumination
`illuminating past the other vehicle while preventing glare to a
`driver of the other vehicle.” ......................................................80
`Claim 25 “The illuminating device of claim 24, wherein: the
`changed emission includes a change to at least one of intensity or
`color or a change of at least one LED of the cluster to a non-
`emitting state; and the cluster includes a plurality of the LEDs
`and the cluster of non-contiguous LEDs.” .......................................... 81
`Claims 30/38/46/54 “The illuminating device of claim 24, further
`including one or more optical control elements to control light
`emitted from one or more of the LEDs.” ............................................ 84
`Claims 31/39/47/55 “The illuminating device of claim 30,
`wherein the optical control elements include at least one of one
`or more reflectors, refractors or lenses.” ............................................ 85
`Independent Claim 32 Instructions ..................................................... 86
`[32.8a] “create a beam of diminished illumination illuminating at
`
`least a portion of the at least one target with non-glaring
`illumination, created in a broader field of illumination having
`different intensity than the beam, by one or more changes to
`characteristics of first light of a cluster of the LEDs providing the
`first light directed at the at least a portion and creating the beam”
`..................................................................................................86
`[32.8b] “the beam diminished in intensity relative to the broader
`field of illumination illuminating at least above and on both sides
`of the beam; and” ......................................................................87
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`C.
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`D.
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`E.
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`[32.9] “follow, based at least in part on data from one or more of
`the cameras, the at least one target with the diminished
`illumination as the at least one target changes location relative to
`the motor vehicle.” ....................................................................88
`Claim 33 “The illuminating device of claim 32 wherein: the
`memory further stores instructions that, when executed by one or
`more processors of the controller, enable the controller to select
`the cluster of LEDs based at least in part on known aimings of
`the first light associated with the first cluster having a correlation
`to the at least the portion, the known aimings based at least in
`part on at least one of known directionality of light emitted by
`the first cluster or known directionality of light emitted by the
`first cluster exiting the headlamp; the data includes image data;
`the one or more changes to characteristics of the first light
`include a change to at least one of intensity or color or a change
`of at least one LED of the cluster to a non-emitting state; and the
`cluster includes a plurality of the LEDs and the cluster includes
`non-contiguous LEDS. ....................................................................... 88
`Independent Claim 40 Instructions ..................................................... 93
`[40.8a] “determine a list cluster of the LEDs illuminating at least
`
`a first portion of a first other vehicle based at least in part on data
`from one or more of the sensors indicating a first position
`associated with the first other vehicle” ......................................93
`[40.8b] “diminish glaring illumination of the first other vehicle by
`a first change to one or more characteristics of first light of at least
`the first cluster” ........................................................................95
`[40.8c] “determine a second, different cluster of the LEDs
`illuminating at least a second portion of a second other vehicle
`based at least in part on the data indicating a second position
`associated with the second other vehicle” .................................96
`[40.8d] “diminish glaring illumination of the second other vehicle
`by a second change to one or more characteristics of second light
`of at least the second, different cluster”.....................................97
`[40.8e] “wherein the first and second changes decrease intensity
`of first emission from the first cluster and second emission from
`the second cluster relative to a third emission, from the at least one
`headlamp, illuminating an area between the first and second
`portion.” ....................................................................................97
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`Claim 41 “The illuminating device of claim 40, wherein: the data
`includes image data; at least one of first or second change to
`characteristics of light associated with at least one of the first or
`second cluster of LEDs includes at least one of a chance to color,
`to intensity, or a change of at least one LEDs of the respective
`cluster to a non-emitting state; at least one of the first cluster or
`the second cluster includes a plurality of the LEDs and at least
`one of the first cluster or the second cluster includes non-
`contiguous LEDs; the determination of the first cluster includes
`selection of the first cluster based at least in part on known
`aimings of light associated with the first cluster having a
`correlation to the first position, the known aimings based at least
`in part on at least one of known directionality of light emitted by
`the first cluster or known directionality of light emitted by the
`first cluster exiting the headlamp; and the determination of the
`second cluster includes selection of the second cluster based at
`least in part on known aimings light associated with the second
`cluster having a correlation to the second position, the known
`aimings based at least in part on at least one of known
`directionality of light emitted by the second cluster or known
`directionality of light emitted by the second cluster exiting the
`headlamp. .......................................................................................... 98
`Independent Claim 48 Instructions ....................................................103
`[48.8a] “illuminate a portion of at least one object, indicated by
`
`data from at least one of the one or more sensors, by selecting a
`first cluster of the LEDs to emit first light directed towards a first
`area including the at least the portion of at least one object, the
`first area determined based at least in part on the data, the first
`cluster selected based at least in part on known aimings of light
`associated with the first cluster determined to correspond to the
`first area, and the first light determined based at least in part on
`classifying the object based at least in part on the data; and” .. 103
`[48.8b] “control light emitted from the first cluster directed
`towards the first area to be different in at least one emission
`characteristic, based on the first light determination, from second
`light emitted from a second, different cluster of the LEDs, directed
`towards one or more illuminated second areas at a common
`elevation with the first area and laterally adjacent to the area.”
`................................................................................................ 105
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`Claim 49 “The illuminating device of claim 48, wherein: the data
`includes image data; the memory further stores instructions that,
`when executed by one or more processors of the controller,
`enable the controller to illuminate the at least the portion with
`light below at least a predefined glare level; the at least one
`object includes at least one of a pedestrian, a sign, or another
`vehicle; at least one of the first cluster or the second cluster
`includes a plurality of the LEDs and at least one of the first
`cluster or the second cluster includes non-contiguous LEDs; the
`control of the light emitted from the first cluster includes a
`change of at least one LED of the cluster to a non-emitting state;
`the at least one emission characteristic is different following
`modification by an optical control element; and the known
`aimings of light associated with the first cluster is at east on part
`on known directionality of light emitted by LEDs of the first
`cluster exiting from the at least one headlamp.” ................................107
`XI. GROUND 2: BEAM, SATONAKA, AND KOBAYASHI RENDER
`OBVIOUS CLAIMS 26–29, 34–37, 42–45, AND 50–53............................ 113
`A. A POSA would have been motivated to combine Beam,
`Satonaka, and Kobayashi with a reasonable expectation of
`success. .............................................................................................113
`Claims 26/34/42/50 “The illuminating device of claim 24,
`wherein the memory further stores instructions that when
`executed by one or more processors of the controller, enable the
`controller to: identify an upcoming road curvature along a road
`on which the motor vehicle is traveling; and accommodate the
`upcoming road curvature by adaptation of a light pattern of at
`least one of the at least one headlamps.” ...........................................124
`Claims 27/35/43/51 “The illuminating device of claim 26,
`wherein: the changed emission includes a change to at least one
`of intensity or color or a change of at least one LED of the
`cluster to a non-emitting state; the cluster includes a plurality of
`the LEDS and the cluster includes non-contiguous LEDs; and the
`memory further stores instructions that, when executed one or
`more processors of the controller, enable the controller to
`accommodate the road curvature by changing illumination in at
`least a direction of the road curvature by adaptation of the light
`pattern in at least one of color, intensity or spatial distribution by
`LEDs.” ..............................................................................................125
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`B.
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`C.
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`Claims 28/36/44/52 “The illuminating device claim 26, wherein
`identification of the upcoming road curvature is based at least in
`part on map data and wherein the adaptation of the light pattern
`is based at least in part on the map data.” ..........................................126
`Claim 29/37/45/53 “The illuminating device of claim 26,
`wherein the identification of the upcoming road curvature is
`based at least in part on sensor data provided by one or more of
`the sensors of the vehicle and wherein the adaptation of the light
`pattern is based in part on map data.” ................................................127
`XII. GROUND 3: KARLSSON AND NAKAMURA RENDER OBVIOUS
`CLAIMS 24, 25, 30–33, 38–41, 46–49, AND 54–55 .................................. 128
`A. A POSA would have been motivated to combine Karlsson and
`Nakamura with a reasonable expectation of success. ........................131
`Independent Claim Structural Elements ............................................136
`[24.P]/[32.P]/[40.P]/[48.P] “An
`illuminating device having
`
`automatic control of light provided to an illuminated area
`comprising” ............................................................................ 136
`[24.1]/[32.1]/[40.1]/[48.1]
`“a
`structure
`for
`incorporating
`illuminating device elements, wherein the structure comprises a
`motor vehicle” ........................................................................ 137
`[24.2]/[32.2]/[40.2]/[48.2] “a plurality of individually controllable
`LEDs incorporated in the structure via at least one headlamp
`mounted to the structure, each headlamp including at least one of
`the LEDs, the LEDs in communication with a power source” . 137
`[24.3]/[32.3]/[40.3]/[48.3] “electronic circuitry apparatus for the
`controlled powering of the LEDs and other of the illuminating
`device elements” ..................................................................... 138
`[24.4]/[32.4]/[40.4]/[48.4] “one or more processors” .............. 139
`[24.5]/[32.5]/[40.5]/[48.5] “one or more sensors, including one or
`more cameras, placed on the structure for detecting coordinate-
`specific information about the illuminated area, at least one of said
`cameras in communication with power, and in communication
`with at least one of the one or more processors” ..................... 140
`(a) Karlsson discloses this element. .................................. 140
`(b) Nakamura discloses this element. ............................... 141
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`It would have been obvious to modify Karlsson in view of
`Nakamura with a reasonable expectation of success. .. 142
`[24.6]/[32.6]/[40.6]/[48.6] “a controller, including at least one of
`the one or more processors, integrated with the structure via
`mounting, in communication with the controlling power electronic
`circuitry apparatus, said controller arranged to process the
`information communicated from the cameras and to automatically
`control the light provided to the illuminated area” .................. 143
`[24.7]/[32.7]/[40.7]/[48.7] “memory storing instructions that,
`when executed by one or more processors of the controller, enable
`the controller to:” .................................................................... 144
`Claim 24 instructions ........................................................................145
`[24.8] “determine coordinates corresponding to another vehicle,
`
`based on the coordinate-specific information” ........................ 145
`[24.9] “select a cluster of the LEDs that emit light toward at
`portion of the other vehicle based on the LEDs having emission
`aimings associated with the first coordinates” ......................... 147
`[24.10] “change emission of the selected cluster of LEDs relative
`to emission of other LEDs not included in the cluster to create
`headlamp illumination that preserves a first level of illumination
`illuminating past the other vehicle while preventing glare to a
`driver of the other vehicle.” .................................................... 148
`Claim 25 “The illuminating device of claim 24, wherein: the
`changed emission includes a change to at least one of intensity or
`color or a change of at least one LED of the cluster to a non-
`emitting state; and the cluster includes a plurality of the LEDs
`and the cluster of non-contiguous LEDs.” .........................................149
`Claims 30/38/46/54 “The illuminating device of claim 24, further
`including one or more optical control elements to control light
`emitted from one or more of the LEDs.” ...........................................151
`Claims 31/39/47/55 “The illuminating device of claim 30,
`wherein the optical control elements include at least one of one
`or more reflectors, refractors or lenses.” ...........................................152
`Claim 32 instructions ........................................................................153
`[32.8a] “create a beam of diminished illumination illuminating at
`
`least a portion of the at least one target with non-glaring
`
`
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`
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`C.
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`D.
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`E.
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`F.
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`Case IPR2023-00315
`U.S. Patent No. 9,955,551
`illumination, created in a broader field of illumination having
`different intensity than the beam, by one or more changes to
`characteristics of first light of a cluster of the LEDs providing the
`first light directed at the at least a portion and creating the beam”
`................................................................................................ 153
`[32.8b] “the beam diminished in intensity relative to the broader
`field of illumination illuminating at least above and on both sides
`of the beam” ........................................................................... 154
`[32.9] “follow, based at least in part on data from one or more of
`the cameras, the at least one target with the diminished
`illumination as the at least one target changes location relative to
`the motor vehicle.” .................................................................. 155
`Claim 33 “The illuminating device of claim 32 wherein: the
`memory further stores instructions that, when executed by one or
`more processors of the controller, enable the controller to select
`the cluster of LEDs based at least in part on known aimings of
`the first light associated with the first cluster having a correlation
`to the at least the portion, the known aimings based at least in
`part on at least one of known directionality of light emitted by
`the first cluster or known directionality of light emitted by the
`first cluster exiting the headlamp; the data includes image data;
`the one or more changes to characteristics of the first light
`include a change to at least one of intensity or color or a change
`of at least one LED of the cluster to a non-emitting state; and the
`cluster includes a plurality of the LEDs and the cluster includes
`non-contiguous LEDS.” ....................................................................156
`Claim 40 instructions ........................................................................159
`[40.8a] “determine a list cluster of the LEDs illuminating at least
`
`a first portion of a first other vehicle based at least in part on data
`from one or more of the sensors indicating a first position
`associated with the first other vehicle” .................................... 159
`[40.8b] “diminish glaring illumination of the first other vehicle by
`a first change to one or more characteristics of first light of at least
`the first cluster” ...................................................................... 161
`[40.8c] “determine a second, different cluster of the LEDs
`illuminating at least a second portion of a second other vehicle
`based at least in part on the data indicating a second position
`associated with the second other vehicle” ............................... 162
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`[40.8d] “diminish glaring illumination of the second other vehicle
`by a second change to one or more characteristics of second light
`of at least the second, different cluster”................................... 163
`[40.8e] “wherein the first and second changes decrease intensity
`of first emission from the first cluster and second emission from
`the second cluster relative to a third emission, from the at least one
`headlamp, illuminating an area between the first and second
`portion.” .................................................................................. 164
`Claim 41 “The illuminating device of claim 40, wherein: the data
`includes image data; at least one of first or second change to
`characteristics of light associated with at least one of the first or
`second cluster of LEDs includes at least one of a chance to color,
`to intensity, or a change of at least one LEDs of the respective
`cluster to a non-emitting state; at least one of the first cluster or
`the second cluster includes a plurality of the LEDs and at least
`one of the first cluster or the second cluster includes non-
`contiguous LEDs; the determination of the first cluster includes
`selection of the first cluster based at least in part on known
`aimings of light associated with the first cluster having a
`correlation to the first position, the known aimings based at least
`in part on at least one of known directionality of light emitted by
`the first cluster or known directionality of light emitted by the
`first cluster exiting the headlamp; and the determination of the
`second cluster includes selection of the second cluster based at
`least in part on known aimings light associated with the second
`cluster having a correlation to the second position, the known
`aimings based at least in part on at least one of known
`directionality of light emitted by the second cluster or known
`directionality of light emitted by the second cluster exiting the
`headlamp.” ........................................................................................165
`Claim 48 instructions ........................................................................169
`[48.8a] “illuminate a portion of at least one object, indicated by
`
`data from at least one of the one or more sensors, by selecting a
`first cluster of the LEDs to emit first light directed towards a first
`area including the at least the portion of at least one object, the
`first area determined based at least in part on the data, the first
`cluster selected based at least in part on known aimings of light
`associated with the first cluster determined to correspond to the
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`first area, and the first light determined based at least in part on
`classifying the object based at least in part on the data; and” .. 169
`[48.8b] “control light emitted from the first cluster directed
`towards the first area to be different in at least one emission
`characteristic, based on the first light determination, from second
`light emitted from a second, different cluster of the LEDs, directed
`towards one or more illuminated second areas at a common
`elevation with the first area and laterally adjacent to the area” 171
`Claim 49 “The illuminating device of claim 48, wherein: the data
`includes image data; the memory further stores instructions that,
`when executed by one or more processors of the controller,
`enable the controller to illuminate the at least the portion with
`light below at least a predefined glare level; the at least one
`object includes at least one of a pedestrian, a sign, or another
`vehicle; at least one of the first cluster or the second cluster
`includes a plurality of the LEDs and at least one of the first
`cluster or the second cluster includes non-contiguous LEDs; the
`control of the light emitted from the first cluster includes a
`change of at least one LED of the cluster to a non-emitting state;
`the at least one emission characteristic is different following
`modification by an optical control element; and the known
`aimings of light associated with the first cluster is at east on part
`on known directionality of light emitted by LEDs of the first
`cluster exiting from the at least one headlamp. ..................................174
`XIII. GROUND 4: KARLSSON, NAKAMURA, AND GOTOU RENDER
`OBVIOUS CLAIMS 26–29, 34–37, 42–45, AND 50–53............................ 178
`A. A POSA would have been motivated to combine Karlsson,
`Nakamura, and Gotou with a reasonable expectation of success. ......178
`Claims 26/34/42/50 “The illuminating device of claim 24,
`wherein the memory further stores instructions that when
`executed by one or more processors of the controller, enable the
`controller to: identify an upcoming road curvature along a road
`on which the motor vehicle is traveling; and accommodate the
`upcoming road curvature by adaptation of a light pattern of at
`least one of the at least one headlamps.” ...........................................181
`Claims 27/35/43/51 “The illuminating device of claim 26,
`wherein: the changed emission includes a change to at least one
`of intensity or color or a change of at least one LED of the
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`U.S. Patent No. 9,955,551
`cluster to a non-emitting state; the cluster includes a plurality of
`the LEDS and the cluster includes non-contiguous LEDs; and the
`memory further stores instructions that, when executed one or
`more processors of the controller, enable the controller to
`accommodate the road curvature by changing illumination in at
`least a direction of the road curvature by adaptation of the light
`pattern in at least one of color, intensity or spatial distribution by
`LEDs.” ..............................................................................................182
`Claims 28/36/44/52 “The illuminating device claim 26, wherein
`identification of the upcoming road curvature is based at least in
`part on map data and wherein the adaptation of the light pattern
`is based at least in part on the map data.” ..........................................183
`Claim 29/37/45/53 “The illuminating device of claim 26,
`wherein the identification of the upcoming road curvature is
`based at least in part on sensor data provided by one or more of
`the sensors of the vehicle and wherein the adaptation of the light
`pattern is based in part on map data.” ................................................184
`XIV. THE ALLEGED SECONDARY CONSIDERATIONS DO NOT
`DEMONSTRATE NONOBVIOUSNESS .................................................. 185
`CONCLUSION .................................................................................................... 187
`
`
`E.
`
`
`
`- xii -
`
`

`

`Case IPR2023-0XXXX
`U.S. Patent No. 9,955,551
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`I.
`
`INTRODUCTION
`I, Dr. Jianzhong Jiao, declare as follows:
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`1.
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`I have been retained on behalf of Volkswagen Group of America, Inc.
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`(“VWGoA” or “Petitioner”) for the above-captioned inter partes review proceeding
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`to provide my expert opinions and expert knowledge. I understand that this
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`proceeding involves U.S. Patent No. 9,955,551 (“the ’551 patent”) titled “Detector
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`Controlled Illuminating System,” to Yechezkal Evan Spero, and that Torchlight
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`Technologies, LLC has purported to be the exclusive licensee of the ’551 patent. I
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`understand that the Petition submitted by Petitioner challenges claims 24-55 of the
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`’551 patent.
`
`2.
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`The ’551 patent describes, generally, adaptive headlamp systems and
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`methods. I am familiar with the technology described in the ’551 patent as of its
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`earliest possible priority date, July 12, 2002.
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`3.
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`I have been asked to provide my independent technical review, analysis,
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`insights, and opinions regarding the ’551 patent and the references that form the
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`basis for the grounds of unpatentability set forth in the Petition for inter par