UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SHARP CORPORATION, SHARP ELECTRONICS CORPORATION, and
`SHARP ELECTRONICS MANUFACTURING COMPANY OF AMERICA, INC.,
`Pelitioners
`
`v.
`
`SURPASS TECH INNOVATION LLC,
`Patent Owner
`
`Case IPR2015-:-:-::c:-::(cid:173)
`Patent No. 7,420,550
`
`DECLARATION OF MICHAEL J. MARENTIC IN SUPPORT OF PETITION FOR INTER
`PARTES REVIEW OF U.S. PATENT NO. 7,420,550
`
`60032 1.1
`
`1
`
`SHARP EXHIBIT 1007
`Page 1 of 76
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SHARP CORPORATION, SHARP ELECTRONICS CORPORATION, and
`SHARP ELECTRONICS MANUFACTURING COMPANY OF AMERICA, INC.,
`Pelitioners
`
`v.
`
`SURPASS TECH INNOVATION LLC,
`Patent Owner
`
`Case IPR2015-:-:-::c:-::(cid:173)
`Patent No. 7,420,550
`
`DECLARATION OF MICHAEL J. MARENTIC IN SUPPORT OF PETITION FOR INTER
`PARTES REVIEW OF U.S. PATENT NO. 7,420,550
`
`60032 1.1
`
`1
`
`SHARP EXHIBIT 1007
`Page 1 of 76
`
`
`
`1.
`
`I, Michael J. Marentic, make this declaration in connection with the Petition for
`
`Inter Partes Review submitted by Sharp Corporation, Sharp Electronics Corporation, and
`
`Sharp Electronics Manufacturing Company of America, Inc. (collectively "Petitioners" or
`
`"Sharp") for review of Claims 1 through 5 of U.S. Patent No. 7,420,550 to Yuh-Ren et al.
`
`("the '550 Patent"), which is assigned to Surpass Tech Innovation LLC ("Patent Owner' or
`
`"Surpass").
`
`2.
`
`Throughout this declaration, I refer to exhibit numbers that correspond to the
`
`exhibits to the Petition for Inter Partes Review for which I provide this declaration.
`
`Scope of My Assignment
`
`3.
`
`I have been requested by counsel for Sharp to study the '550 Patent,
`
`including its claims and prosecution history, as well as the references specifically referred to
`
`in this declaration. I have also been requested by counsel for Sharp to provide my expert
`
`opinion regarding the invalidity of Claims 1-5 of the '550 Patent. I further expect to offer an
`
`additional declaration in response to any declaration submitted by any expert for the Patent
`
`Owner.
`
`Summary of My Opinions
`
`4.
`
`It is my opinion that Claims 1-3 of the '550 Patent are invalid as anticipated
`
`under 35 U.S.C.§ 1 02(b) and Claims 4-5 are obvious to a person of ordinary skill in the art
`
`under 35 U.S.C. §103(a). Moreover, it is my opinion that in addition to being anticipated,
`
`Claims 1-3 are also rendered obvious over prior art.
`
`600321 .1
`
`2
`
`Page 2 of 76
`
`
`
`5.
`
`Specifically, I believe that the following are grounds to find Claims 1-5 of the
`
`'550 Patent invalid:
`
`a. Claims 1-3 are invalid under 35 U.S.C. § 102(b) as anticipated by Japanese
`
`Patent Application Publication No. H08-305322 (Ex. 1002, "the Sharp
`
`Reference").
`
`b. Claims 1-3 and 5 are also invalid under 35 U.S.C. § 103(a) as obvious over
`
`the Sharp Reference.
`
`c. Claims 1-5 are also invalid under 35 U.S.C. § 103(a) as obvious over the
`
`Sharp Reference in view of U.S. Patent No. 6,407,795 to Kamizono, et al. (Ex.
`
`1004, "Kamizono").
`
`d. Claims 1-5 are also invalid under 35 U.S.C. § 103(a) as obvious over U.S.
`
`Patent No. 6,081 ,250 to Shimada et al. (Ex. 1003, "Shimada") in view of
`
`Kamizono.
`
`Summary of My Professional Background and Qualifications
`
`6.
`
`Exhibit 1008 is my curriculum vitae which sets forth my professional
`
`background and qualifications. A list of publications that I have authored or co-authored is
`
`included.
`
`7.
`
`I have many years of experience in the flat panel display industry. I first
`
`became involved in the flat panel display industry in 1973, when I began working at the
`
`University of Illinois Coordinated Science Laboratories where the AC Plasma Display Panel
`
`600321 .1
`
`3
`
`Page 3 of 76
`
`
`
`("PDP") was invented. During my studies at the University, I was employed as an intern
`
`working in the area of plasma display construction and gas discharge physics
`
`characterization. I received a B.S. degree in Engineering Physics from the University of
`
`Illinois.
`
`8.
`
`Upon entering graduate school, I continued my work on the characterization
`
`of the gas discharge in the pixels. I received an M.S. degree in Electrical Engineering from
`
`the University of Illinois, and wrote my master's thesis on measuring the electron density in
`
`an AC PDP.
`
`9.
`
`One of my engineering positions was with Interstate Electronics Corporation
`
`(IEC) as a design electrical engineer. IEC designed drive electron ics, mechanically
`
`packaged the display modules, and incorporated them into terminals for harsh, military
`
`environments. I designed several distinct versions of drive electronics for POPs, including
`
`one using packaged silicon integrated circuits on flexible circuits, or "chip-on-flex." During
`
`th is time, I was awarded several patents relating to PDP technologies. I also investigated
`
`LCDs and thin film electroluminescent displays for incorporation into military applications.
`
`10.
`
`I later formed Plasma Displays, Inc., a single proprietorship consulting
`
`corporation. I worked for several clients, one being Bell Laboratories and AT&T at their joint
`
`Reading, Pennsylvania facility. This facility was where the original picture phone was
`
`developed, the first commercial light emitting diodes ("LEOs") were manufactured, and
`
`600321.1
`
`4
`
`Page 4 of 76
`
`
`
`AT&T's POPs were developed and manufactured.
`
`I worked on PDP drive electronic design,
`
`driver-to-panel interconnect reliability, driver circuit characterization, and yield improvement.
`
`11.
`
`I was a founder and Vice President of Plasmaco, a company that acquired
`
`IBM's PDP production line in New York. Plasmaco manufactured several types of POPs,
`
`including VGA panels with 640x480 pixels for early notebook computers. Such a panel had
`
`5 driver ICs with 32 outputs per driver for 640 data lines. I also developed larger sized VGA
`
`panels with 1280x1 024 pixels. Because of the increase in size, we used the same type of
`
`driver IC chips but doubled the number of driver ICs (i.e., using 10 driver ICs) in the display.
`
`When changing the panel design to increase the size of the panel and/or the nu mber of
`
`pixels, it was a common practice to keep the same type of driver Ie as the smaller panel,
`
`but it was necessary to increase the number of driver ICs to accommodate the added pixels
`
`in the larger display.
`
`12. While at Plasmaco, I also developed and manufactured driver chip-on-glass
`
`("COG") technology that passed extreme militarized environmental testing specifications.
`
`COG technology put electrode driver integrated circuits onto the glass edges of the PDP.
`
`The benefits of using COG technology were that it reduced the physical size and weight of a
`
`notebook computer display and increased the operational reliability of the display.
`
`13.
`
`At Science Applications International Corporation, I worked on efficient
`
`backlights for LCOs, some for direct viewing in sunlight. Commercially available LCOs were
`
`600321 .1
`
`5
`
`Page 5 of 76
`
`
`
`disassembled and repackaged with these backlights. The finished displays were used in
`
`cockpit avionics, medical, banking, and FAA towers.
`
`14.
`
`At Hitachi, from 1995 to 1999, I managed a technology center that developed
`
`technologies relating to the interface between the motherboard and the LCD driver chips for
`
`flat panel monitors and notebook displays. I reported directly to the LCD design and
`
`manufacturing center in Japan. I had access to future LCD technical details and
`
`specifications, and facilitated technology transfer between Silicon Valley firms and Japan
`
`management. The Video Electronics Standards Association ("VESA") writes and publishes
`
`video standards for the electrical interfacing for displays. I was the chairman of the VESA
`
`flat panel display committee, a member of the board of directors, and later the president of
`
`the board of directors.
`
`15. While at Philips, from 1999 to 2001 , I managed a group of engineers that
`
`designed electronics for flat panel displays. My group designed interface timing ICs and
`
`video processing circuit boards for monitors and televisions utilizing LCOs. My group also
`
`worked with an IC design firm to develop the design of source and gate driver ICs for
`
`enhanced performance LCOs having various sizes. The enhanced performance LCOs were
`
`developed to provide high brightness and used multiple driver ICs, as well as the COG
`
`technology.
`
`600321.1
`
`6
`
`Page 6 of 76
`
`
`
`16.
`
`Philips invested in a tiled LCD display company, and I participated in the
`
`technology development using Philips panels. My group designed circuits and assisted with
`
`their inoorporation into commercial products within Philips' worldwide subsidiaries.
`
`17.
`
`Philips purchased the LCD factory of the Korean company LG, and later
`
`formed a joint ventu re called LG-Philips LCD. I was a member of the group of technical
`
`advisors that performed the due diligence for Philips for the purchase.
`
`18.
`
`At Alien Technology, I was a member of the integrated design team that
`
`produced custom drivers made for cholesteric LCD displays, organic LEOs, and polymer
`
`dispersed LCOs. My responsibilities were IC product definition for the drivers and system
`
`architecture. Driver ICs were fabricated at silicon foundries and formed into small die for
`
`mass assembly utilizing Alien's fluidic assembly onto flexible, very low cost displays. Since
`
`Alien's products were very small sized, low cost LCOs, they typically involved only a single
`
`source driver and a single gate driver, whereas the larger sized LCD panels that I worked
`
`on while at Hitachi and Philips had multiple source and gate drivers.
`
`19.
`
`I am the named inventor or co-inventor on three U.S. patents in the PDP field.
`
`Materials Considered
`
`20.
`
`In forming my opinions, I reviewed the following documents referenced by
`
`their exhibit number in the Petition for Inter Partes Review of the '550 Patent:
`
`600321.1
`
`7
`
`Page 7 of 76
`
`
`
`EXHIBIT NO.
`
`DESCRIPTION
`
`1001
`
`U.S. Patent No. 7,420.550 to Shen et al. ("'550 Patent")
`
`1002
`
`Japanese Patent Application Publication No. H08-305322 and
`Certified English Translation Thereof ("Sharp Reference")
`
`1003
`
`U.S. Patent No. 6,081 ,250 to Shimada et al. ("Shimada")
`
`1004
`
`U.S. Patent No. 6,407,795 to Kamizono et al. ("Kamizono")
`
`1005
`
`Prosecution History of U.S. Appl. No. 10/929,473
`
`1006
`
`U.S. Patent No. 5,805,128 to Kim et al. ("Kim")
`
`1009
`
`U.S. Patent Application Publication No. US 2003/0048249 A 1 to
`Sekido et al. ("Sekido")
`
`21.
`
`I also base this declaration on my knowledge from my 30 years of experience
`
`working on liquid crystal display (LCD) and related technologies.
`
`22.
`
`I reserve the right to amend or supplement this declaration based upon any
`
`reports by any expert(s) for the Patent Owner, or any new documents and/or other
`
`information that becomes available.
`
`Compensation
`
`23.
`
`I am being compensated at my consulting rate of $250 per hour for my time
`
`spent in connection with this case. I am being separately reimbursed for any out-of-pocket
`
`600321.1
`
`8
`
`Page 8 of 76
`
`
`
`expenses. No part of my compensation is dependent upon the outcome of this proceeding
`
`or the nature of the opinions that I express.
`
`Legal Standards
`
`24.
`
`To render my invalidity analysis, I have been informed about the legal
`
`standards for patent invalidity in inter partes review proceedings before the Patent Trial and
`
`Appeal Board.
`
`25.
`
`Specifically, I understand that the petitioner must prove patent invalidity by a
`
`"preponderance of the evidence," that there is no "presumption of validity" in inter partes
`
`review proceedings, and that claims are to be given their "broadest reasonable" construction
`
`in light of the specification as would be read by a person of ordinary skill in the art.
`
`26.
`
`I also understand that a patent claim may be invalidated as anticipated if a
`
`single prior art reference discloses, either expressly or inherently, each and every element
`
`of the patent claim.
`
`27.
`
`I also understand that a patent claim may be invalidated by one or more
`
`references, either alone or in combination, as being "obvious" to a person of ordinary skill in
`
`the art at the time the invention was made.
`
`28.
`
`I understand that one way of demonstrating obviousness in the situation
`
`where a prior art reference discloses a single element but the claim requires multiple
`
`elements is to demonstrate that there are no new and unexpected results from increasing
`
`the number of such elements.
`
`600321.1
`
`9
`
`Page 9 of 76
`
`
`
`29.
`
`I further understand thai an additional way of demonstrating obviousness is to
`
`demonstrate that one or more items of prior art either alone or in combination, contain all of
`
`the elements of a claim.
`
`30.
`
`It is my understanding that in considering the issue of obviousness, I should
`
`consider what a person of ordinary skill in the pertinent art would have known at the time of
`
`the invention, as well as what such a person would have reasonably expected to have been
`
`able to do in view of that knowledge.
`
`31.
`
`I understand that in analyzing the issue of obviousness, I should consider and
`
`determine: (1) the scope and content of the prior art; (2) the differences between the prior
`
`art and the claims at issue; and (3) the level of ordinary skill in the pertinent art.
`
`32.
`
`I further understand that any of the following may provide a "reason" for
`
`combining elements known in the prior art: (a) a need or problem known in the field at the
`
`time of invention and addressed by the patent; (b) an obvious use of familiar elements
`
`beyond their primary purposes; (c) a design need or market pressure to solve a problem; (d)
`
`a simple substitution of one known element for another that would provide predictable
`
`results; (e) the use of known techniques to improve similar methods or products in the same
`
`way; or (D some teaching, suggestion, or motivation in the prior art that would have led one
`
`of ordinary skill to modify the prior art reference or to combine prior art reference teachings
`
`to arrive at the claimed invention .
`
`600321 .1
`
`10
`
`Page 10 of 76
`
`
`
`33.
`
`I also understand that claims may be invalid if they are directed to obvious
`
`design choices. Specifically, I understand that a patent claim that simply arranges old
`
`elements with each performing the same function it had been known to perform is not
`
`patentable. The combination of familiar elements according to known methods is likely to
`
`be obvious when it does no more than yield predictable results.
`
`34.
`
`I also understand that certain "secondary considerations" of non-obviousness
`
`may be considered, to the extent that they exist. It is my understanding that such
`
`secondary considerations include, among others: (a) commercial success; (b) long felt but
`
`unsolved needs; and (c) the failure of others.
`
`I understand that there must be some
`
`connection to the secondary considerations and the claimed invention. I reserve my right to
`
`address any evidence or opinions the patent owner may submit on this issue.
`
`THE '550 PATENT
`
`35.
`
`I understand that the application leading to the '550 Patent was U.S. Patent
`
`Application No. 10/929,473, which was filed on August 31,2004. For the purposes of my
`
`analysis, I assume that the time of the purported invention was August 31 , 2004.
`
`36.
`
`The '550 Patent relates to an active matrix liquid crystal display (LCD) device
`
`and driving circuit for the LCD device. In particular, the '550 Patent describes a specific way
`
`of connecting the gate and data lines to the thin film transistors (TFTs) driving pixels in an
`
`LCD panel.
`
`600321.1
`
`11
`
`Page 11 of 76
`
`
`
`LCD Panels and Driving Devices Were Known in the Prior Art
`
`37.
`
`As acknowledged in the '550 Patent, active matrix LCD panels and the use of
`
`data and gate lines, or source and gate drivers for TFTs in LCD panels were all known in
`
`prior art. (Ex. 1001, '550 Patent, Col. 1 :23-61 , Figs. 1A-18).
`
`38.
`
`As shown below by multiple shaded blocks in annotated Figure 1A of the '550
`
`Patent, the "Prior Art" driving circuit for LCD panels included multiple source drivers 11 and
`
`multiple gate drivers 12. (Id. at Fig. 1A). The source drivers 11 (purple boxes) provide
`
`image signals (i.e., video signals) to an LCD panel 10 through a plurality of data lines 111
`
`(purple lines), while the gate drivers 12 (orange boxes) provide scanning signals (i.e.,
`
`control signals) to the LCD panel 10 through a plurality of gate lines 121 (orange lines).
`
`Source Drivers
`Source driver
`I
`
`""l-H--
`
`-H---+f---I Line.
`
`0111
`lines
`Fig.IA (Prior Art )
`
`Glle LIne
`
`Oala
`LIne
`
`/
`ata
`LIne
`
`Fig. IB (Prior Art)
`
`39.
`
`As shown above in Figure 1A, prior art LCD panels included data lines 111
`
`and gate lines 121 arranged in a matrix array.
`
`600321 1
`
`12
`
`Page 12 of 76
`
`
`
`40.
`
`According to the '550 Patent, the data lines 111 and gate lines 121 in the
`
`"Prior Art" shown in Figures 1 A and 1 B are "insulated with each other." (Ex. 1001, '550
`
`Patent, Col. 1 :45-47).
`
`41.
`
`As shown above in Figure 1 B, a pixel 13 in this prior art LCD panel is formed
`
`within each area enclosed by intersecting data lines (e.g., purple line 0,) and gate lines
`
`(e.g., orange line G,).
`
`42.
`
`As the '550 Patent acknowledges, each pixel 13 in prior art LCD panel
`
`included a thin film transistor Q, (TFT, highlighted in yellow), which is switched on and off by
`
`a control signal from the gate driver 12 through a gate line G,.
`
`43.
`
`The source of the TFT Q, receives the image signal sent from the source
`
`driver 11 through the data line 0 ,. An output voltage from the TFT Q, drives liquid crystal
`
`molecules corresponding to the pixel 13 to form an image. (Id. at Col. 1:45-57, Fig. lB).
`
`44.
`
`The time that an LCD needs to react to the driving voltage output by each
`
`TFT is called "response time," and the video quality of an LCD panel is dependent on this
`
`response time. In this regard, the video quality may be poor if the LCD response time is too
`
`long. (Id. at Cols. 1 :62-2:41).
`
`The Alleged Invention of the '550 Patent
`
`45.
`
`According to the '550 Patent, its "chief object" is to provide an LCD driving
`
`circuit having a matrix structure in which the gate and data lines are connected to the TFTs
`
`in a specific way that allegedly increases "the response speed" of the LCD. (Id. at Col.
`
`60032 1.1
`
`13
`
`Page 13 of 76
`
`
`
`3:18-20,35-40). This configuration is shown in, for example, Figure 4B, which is
`
`reproduced below.
`
`'550 Patent Fig. 4B
`
`----,
`C~
`CS
`I
`L~S7J
`
`R2
`
`R3
`
`----::I
`1:C
`~s
`I
`L_~~J
`
`C2
`
`C3
`
`C1
`
`46.
`
`As shown above in annotated Figure 4B, the driving device includes a matrix
`
`array formed from rows (R1-R3) and columns (C1-C3) of TFTs (Q). Each TFT in the matrix
`
`is associated with a pixel (represented by the dashed rectangles). The driving device
`
`further includes a certain number ("N") of gate lines G; (i=1, 2, ... N), and a certain number
`
`("M") of groups (e.g., pairs) of data lines OJ and OJ' G, j'=(1, 1 '), (2, 2'), ... (M, M'l). For
`
`600321 1
`
`14
`
`Page 14 of 76
`
`
`
`example, as shown in Figure 4B above, the driving device has three gate lines, G
`"
`
`G2, and
`
`G3, and two groups of data lines ((0" Dr ) and (02, D,.)).
`
`47.
`
`As shown in Figures 4A, 5A, and 6A, the '550 Patent describes a source
`
`driver with a limit of 60 Hz but provides no further explanation or specification. Absent in
`
`the '550 Patent is the number of drive channels or outputs per source driver and matrix size.
`
`One would calculate the number of required driver ICs by dividing the horizontal pixel count
`
`by the number of drive channels per data driver. The driving device shown in Figure 4A
`
`uses 60 Hz source drivers; it doubles the normal calculated number of source drivers and
`
`mounts them on a single glass panel edge. The driving device shown in Figure 5A also
`
`uses 60 Hz source drivers; it again doubles the normal calculated number of data drivers,
`
`but mounts them on both the top and bottom edges of the panel with an interdigitated
`
`column connection. The driving device shown in Figure 6A uses 120 Hz or faster source
`
`drivers, mounted on one panel edge, and then adds dual switches to each output channel
`
`for driving the paired data electrodes.
`
`48.
`
`The '550 Patent does not discuss the benefits or reasons for including a
`
`single source driver and a single gate driver on the one hand, and having a set of multiple
`
`source and gate drivers on the other hand.
`
`49. Multiple source and gate drivers were commonly used in the prior art,
`
`particularly LCD panels as they increased in screen size. In fact, when I was in the LCD
`
`industry before the filing date of the '550 Patent, it was a common practice to change the
`
`600321.1
`
`15
`
`Page 15 of 76
`
`
`
`panel design to increase the size of the panel and/or the number of pixels by simply adding
`
`more driver ICs. For example, while the small, low cost LCD panel (which had an
`
`equivalent pixel dimension of 7x4) that I worked on at Alien Technology had only a single
`
`source driver and a single gate driver, all the large sized LCD panels (which had pixel
`
`dimension of at least 800x600) that I worked on at Philips had multiple driver ICs.
`
`50.
`
`Consistent with my experience, U.S. Patent Application Publication No. US
`
`2003/0048249 A1 to Sekido et al. (Ex. 1009, "Sekido"), which was published on March 13,
`
`2003, states that "in order to drive many gate bus lines and the source bus lines on the
`
`display circuit board, a plurality of the gate drivers and source drivers must be
`
`connected to the area around the liquid crystal display panel." (Par. [0006]) (emphasis
`
`added). Sekido further teaches that increasing the size of the LCD screen will increase the
`
`number of driver ICs in the panel. (Par. [0008]). Other prior art references discussed below
`
`also teach the use of multiple source and gate drivers for a large sized or high resolution
`
`LCD panel.
`
`51.
`
`As shown above in Figure 48, the gate line G;(e.g., G" G" and G,) in each
`
`row is connected to the gates of each TFT in that row. However, for each column, the first
`
`and second data lines OJ and Dr that form a group of data lines are not connected to all
`
`TFTs in that column. Instead, the first data line OJ in each column is connected only to the
`
`sources of the TFTs in the odd rows (see the red boxes in R1, R3, etc.) of that column,
`
`600321.1
`
`16
`
`Page 16 of 76
`
`
`
`while the second data line Or in the same column is connected only to the sources of the
`
`TFTs in the even rows (see the green box in R2) that column. (ld. at Col. 8: 1 0-31).
`
`52.
`
`For example, referring to the first group of data lines 0, and Or (see the red
`
`and green lines) in first column (C1) of Figure 4B above, the first data line 0, (see the red
`
`line) is connected to the sources (red dots) of the TFTs in the first and third rows (red boxes
`
`in R1 and R3 of the first column C1), while the second data line Odgreen line) is connected
`
`to the source (green dot) of the TFT in the second row (green box in R2 of the first column
`
`C1). Similarly, for the second pair of data lines (i.e., 0, and 0,.) in the second column, the
`
`first data line (i.e., 0,) is connected to the sources of the TFTs in the first and third rows (i.e.,
`
`R1 and R3 of the second column C2), while the second data line 0,· is connected to the
`
`source of the TFT in the second row (i.e., R2 of the second column C2).
`
`53.
`
`According to the '550 Patent, this alternating connection with the Odd
`
`Row/Even Row ("Odd Row/Even Row" configuration) reduces the response time of the LCO
`
`panel. (ld. at Col. 3:35-40). However, the '550 Patent does not explain how this reduction
`
`occurs.
`
`54.
`
`The gate lines are connected to the gate driver are "insulated with each other;"
`
`and the data lines are connected to the source driver and are "insulated with each other."
`
`(Ex. 1001, '550 Patent, Col. 8:20-22, Col. 8:29-31). The '550 Patent goes on to explain that
`
`a space is provided between the neighboring data lines (e.g., Or and 0,) to prevent them
`
`from short circuiting. (Ex. 1001 , '550 Patent, Col. 8:31-36, Fig. 4C).
`
`600321 .1
`
`17
`
`Page 17 of 76
`
`
`
`55.
`
`As shown below in annotated Figure 6A, the first and second data lines 0,
`
`and Of (e.g., red and green lines 01 and 01') in each group (i.e., pair) of data lines are
`
`connected to the same source driver (purple box), and data is transferred to these data lines
`
`by an electronic switch S (highlighted in yellow). (Id. at Col. 5:4-8, Col. 8:50-52).
`
`'550 Patent Fig. 6A
`
`Source driver (120 Hz or 180 Hz . .. )
`
`Source Driver
`
`• ••
`•••
`~ S •••
`
`~~~~=
`UJlIU, r, Dz
`
`1st 2nd
`Data Data
`Line Line
`
`56.
`
`In addition, all of the source drivers are installed on the same side (e.g., upper
`
`side) of the LCD panel. (See also id. at Fig. 4A, Col. 8:37-38). The '550 Patent
`
`acknowledges that these components were arranged in the exact same way in the "Prior Art"
`
`in Figure 1A. (Id. at Col. 1 :36-45, Fig. 1A).
`
`600321 1
`
`18
`
`Page 18 of 76
`
`
`
`57.
`
`The '550 Patent also states that the gate driver can be "a chip on glass or an
`
`integrated gate driver circuit on glass." (Id. at Col. 8:53-54). However, the '550 Patent does
`
`not define either of these terms, nor does it explain the difference between "a chip on glass"
`
`and "an integrated gate driver circuit on glass."
`
`PROSECUTION HISTORY OF THE '550 PATENT
`
`58.
`
`I understand that as originally filed, the application for the '550 Patent
`
`included claims directed to six different embodiments described in the '550 Patent. I also
`
`understand that, in response to a "Restriction Requirement" (Ex. 1005, p. 122), only the
`
`claims directed to the "First Embodiment" (i.e., "Species I; Figures 4A-4C") (Id. at p. 127)
`
`were elected and the claims directed to the other embodiments were canceled.
`
`59.
`
`I understand that during prosecution, the application claim corresponding to
`
`Claim 1 of the '550 Patent was rejected as anticipated by U.S. Patent No. 5,805,128 to Kim
`
`et al. (Ex. 1006, "Kim"). (See Ex. 1005, p. 141). This application claim was identical to
`
`Claim 1, except that it did not include the last element of Claim 1, namely "the first data lines
`
`and the second data lines of each group of data lines are connected with the same source
`
`driver." (See id. at pp. 31 , 152).
`
`60.
`
`As shown below, annotated Figure 5 of Kim shows an LCD driving device of
`
`matrix structure type including the Odd Row/Even Row configuration, gate lines 3
`
`connected to a gate driver 16, first data lines 10 connected to a data driver 8 on the bottom,
`
`and second data lines 14 connected to a data driver 12 on the top. (Ex. 1006, Kim, Col.
`
`600321.1
`
`19
`
`Page 19 of 76
`
`
`
`3:26-37, Col. 4:28-51, FIG. 5). I note that Figure 5 of Kim shows the Odd Row/Even Row
`
`configuration that is virtually identical to the one shown in Figures 5A and 58 of the '550
`
`Patent.
`
`Kim Fig. 5
`
`Source Driver
`
`- 14
`
`- 14
`
`12
`
`f-- 10
`c-
`
`Iv +
`r
`-
`
`r
`16
`, j - -~
`
`r-
`
`r
`
`r-
`
`r
`
`r-
`
`V +
`V +
`- ILF
`- It!
`V
`-
`r
`hf~ V~ V +
`-
`-
`r
`- ILF
`- ILF
`-
`
`l
`
`6
`
`lOJ
`~ +
`
`F
`
`f
`
`e Gat
`Drive
`r - .
`16
`
`r
`"V~
`-
`
`~
`
`......
`
`I
`
`~
`
`V
`
`Source Dnver
`
`/- 8
`
`61.
`
`In the prosecution history. I did not find any argument by the applicants
`
`disputing the Examiner's position that Kim disclosed all elements of the rejected claim,
`
`including the Odd Row/Even Row configuration and gate driver.§. Rather, the applicants
`
`distinguished the rejected claim over Kim by including an additional claim limitation, namely
`
`that "the first data lines and the second data lines of each group of data lines are connected
`
`with the same source driver." (Ex. 1005, pp. 152, 156). The claim was subsequently
`
`allowed by the Examiner.
`
`600321 1
`
`20
`
`Page 20 of 76
`
`
`
`62.
`
`Even though Figure 5 of Kim does not disclose "the same source driver"
`
`limitation, the technique of connecting first and second data lines of each group of data lines
`
`with the same source driver in an LCD device was well known in the prior art, including the
`
`Sharp Reference and Shimada as discussed below. I understand that none of the Sharp
`
`Reference, Shimada, and Kamizono referred to in this declaration was considered by the
`
`Examiner during prosecution of the '550 Patent.
`
`CLAIM CONSTRUCTION
`
`63.
`
`I understand that in inter partes review proceedings, patent claims are to be
`
`given their "broadest reasonable" construction in light of the specification as would be read
`
`by a person of ordinary skill in the art.
`
`64.
`
`Most of the terms of Claims 1-5 of the '550 Patent are clear to me, except for
`
`the following terms.
`
`"The first and the second date lines of the first group of date lines"
`
`65.
`
`Independent Claims 1 and 2 each recite that "the first and the second date
`
`lines of the first group of date lines are respectively connected with the sources of all the
`
`thin film transistors of the odd and the even rows of the first column ... . " (Ex. 1001 , '550
`
`Patent, Col. 19:52-56, Col. 20:13-17) (emphasis added). Nowhere else in the '550 Patent is
`
`there any mention or discussion of "date lines." I believe that the term "date lines" in this
`
`claim recitation is meant to be "data lines."
`
`60032 1.1
`
`21
`
`Page 21 of 76
`
`
`
`"Gate lines ... insulated with each other" and "data lines ... insulated with each
`other"
`
`66.
`
`Independent Claims 1 and 2 each recite "a group of N gate lines ...
`
`insulated with each other" and "M groups of data lines ... insulated with each other."
`
`(Ex. 1001. '550 Patent, Col. 19:44-45, 51-52, Col. 20:5-6,12-13) (emphasis added). The
`
`'550 Patent does not explain what "insulated with each other" means. Rather, the
`
`specification uses the same phrase "insulated with each other" when describing the data
`
`lines 111 and gate lines 121 shown in the "Prior Art" in Figures lA and 1 B of the '550 Patent
`
`(id. at Col. 1:45-47), as well as the data lines (D" D,., D" D,·) and the gate lines (G" G" G3)
`
`shown in Figures 4A-4C of the First Embodiment. (Id. at Col. 8:20-22, 29-31).
`
`67.
`
`I believe that "insulated with each other" means "spaced apart from and
`
`parallel to each other." This is consistent with Figures 1 A-I B of the "Prior Art" in the '550
`
`Patent, which show that the data lines 111 are spaced apart from and parallel to each other
`
`(thereby "insulated with each other") and the gate lines 121 are likewise spaced apart from
`
`and parallel to each other (thereby "insulated with each other"). This is also consistent with
`
`all of the figures that describe the First Embodiment of the '550 Patent (e.g., Figs 4A-4C,
`
`5A-5B, 6A-6B), which also show that the data lines (e.g., D" D,., D" D,) are spaced apart
`
`from and parallel to each other (thereby "insulated with each other"), and the gate lines (e.g.,
`
`G" G" G3) are spaced apart from and parallel to each other (thereby "insulated with each
`
`other").
`
`600321 .1
`
`22
`
`Page 22 of 76
`
`
`
`"the gate drivers" and the "source drivers"
`
`68.
`
`Independent Claims 1 and 2 refer 10 "gate lines oonnected to the gate drivers"
`
`and "data lines connected to the source drivers." However, Ihe term "source driver" is not
`
`mentioned in the specification of the '550 Patenl. Ralher, the specification refers to "data
`
`drivers."
`
`69.
`
`Using the broadest reasonable construction, I believe that a person of
`
`ordinary skill in the art would construe these terms as written in the plural form, that is, "the
`
`gate drivers" refer to more than one gate driver and "the source drivers" refer to more than
`
`one source driver.
`
`70. However, the specification, drawings, and prosecution history of the '550
`
`Patent use the terms "source drivers" and "gale drivers" to cover a variety of driving circuits
`
`and configurations known at the time of Ihe invenlion. These are discussed below:
`
`1.
`
`"Gate Drivers" and "Source Drivers" May Refer to Multiple
`Driving Circuits
`
`71.
`
`In the certain figures in the '550 Palent, Ihe "gate drivers" and "source drivers"
`
`are used to refer to multiple driving circuils, as shown in Ihe "Prior Art" (e.g., Fig. 1 A of the
`
`'550 Patent). As shown in Figure 1 A, the "gale driver" and "source driver" each comprise
`
`multiple driver circuits (e.g., integrate circuit (lC) chips in the purple and orange boxes).
`
`600321.1
`
`23
`
`Page 23 of 76
`
`
`
`Source Drivers
`1l
`$ourc:a 4r1w-r
`
`+1---+--4--; Unes
`
`Fig. IA (Prior Art)
`
`72.
`
`At the time that the '550 Patent was filed, it was widely known that such
`
`drivers could be implemented using multiple IC chips. Specifically, as LCD displays
`
`increase in size with the increased number of pixels, the number of gate lines and data lines
`
`likewise increases. However, it becomes difficult, from a packaging and cost perspective, to
`
`fabricate a single chip capable of driving hundreds or even thousands of data and source
`
`lines. Therefore, a person of ordinary skill in the art would use multiple driver IC chips in
`
`larger sized LCD panels to keep costs, time and labor down and to simplify packaging.
`
`2.
`
`"Gate Dr
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
