`
`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.,
`Petitioners
`
`v.
`
`SURPASS TECH INNOVATION LLC,
`Patent Owner
`___________
`
`Case IPR2015-______
`Patent No. 7,420,550 B2
`Issue Date: September 2, 2008
`Title: LIQUID CRYSTAL DISPLAY DRIVING DEVICE OF MATRIX STRUCTURE TYPE
`AND ITS DRIVING METHOD
`___________
`
`
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,420,550
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`

`

`TABLE OF CONTENTS
`
`
`
`
`I. 
`II. 
`
`B. 
`
`INTRODUCTION ......................................................................................................... 1 
`MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(a)(1) .......................................... 7 
`A. 
`Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) ........................................ 7 
`B. 
`Related Matters Under 37 C.F.R. § 42.8(b)(2) ................................................. 7 
`C. 
`Lead and Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3) .............................. 8 
`D. 
`Service Information Under 37 C.F.R. § 42.8(b)(4) ........................................... 9 
`PAYMENT OF FEES UNDER 37 C.F.R. § 42.103 ..................................................... 9 
`GROUNDS FOR STANDING UNDER 37 C.F.R. § 42.104(a) .................................... 9 
`IDENTIFICATION OF CHALLENGED CLAIMS UNDER 37 C.F.R. § 42.104(b)
`AND RELIEF REQUESTED ...................................................................................... 10 
`A. 
`Claims for Which Inter Partes Review Is Requested Under 37 C.F.R.
`§ 42.104(b)(1) ................................................................................................ 10 
`The Specific Art and Statutory Grounds on Which the Challenge Is Based
`Under 37 C.F.R. § 42.104(b)(2) ..................................................................... 10 
`SUMMARY OF THE ‘550 PATENT ........................................................................... 11 
`A. 
`Specification of the ‘550 Patent ..................................................................... 11 
`1. 
`LCD Panels and Driving Devices Were Known in the Prior Art .......... 11 
`2. 
`The Alleged Invention of the ‘550 Patent ............................................ 13 
`Claims 1-5 of the ‘550 Patent ......................................................................... 16 
`B. 
`Prosecution History of the ‘550 Patent ........................................................... 17 
`C. 
`VII.  CLAIM CONSTRUCTION UNDER 37 C.F.R. § 42.104(b)(3) ................................... 19 
`A. 
`“The first and the second date lines of the first group of date lines” .............. 20 
`B. 
`“Gate lines . . . insulated with each other” and “data lines . . . insulated
`with each other” .............................................................................................. 20 
`i
`
`III. 
`IV. 
`V. 
`
`VI. 
`
`
`
`
`

`

`
`
`C. 
`
`2. 
`
`B. 
`C. 
`
`D. 
`
`E. 
`
`“Gate Drivers” and “Source Drivers” .............................................................. 21 
`1. 
`“Gate Drivers” and “Source Drivers” May Refer to Multiple Driving
`Circuits ................................................................................................ 21 
`“Gate Drivers” and “Source Drivers” Also Refers to A Single Circuit
`With Multiple Outputs .......................................................................... 22 
`VIII.  APPLICATION OF CITED PRIOR ART TO EVERY CLAIM FOR WHICH INTER
`PARTES REVIEW IS REQUESTED UNDER 37 C.F.R. § 42.104(b)(4)-(5) ............. 23 
`A. 
`Ground 1: Claims 1-3 are invalid under 35 U.S.C. § 102(b) as anticipated
`by the Sharp Reference ................................................................................. 24 
`General Considerations Regarding Obviousness Grounds 2-4 ..................... 33 
`Ground 2: Claims 1-3 and 5 are invalid under 35 U.S.C. § 103(a) as
`obvious over the Sharp Reference ................................................................ 34 
`Ground 3: Claims 1-5 are invalid under 35 U.S.C. § 103(a) as obvious
`over the Sharp Reference in view of Kamizono ............................................. 38 
`1. 
`The Disclosure of Kamizono ............................................................... 38 
`2. 
`Claims 1-5 are obvious over the Sharp Reference
`in view of Kamizono ............................................................................ 40 
`Ground 4: Claims 1-5 are invalid under 35 U.S.C. § 103(a) as obvious
`over Shimada in view of Kamizono ................................................................ 47 
`1. 
`The Disclosure of Shimada ................................................................. 47 
`2. 
`Claims 1-5 are obvious over Shimada in view of Kamizono ............... 50 
`SECONDARY CONSIDERATIONS .......................................................................... 59 
`CONCLUSION .......................................................................................................... 60 
`
`IX. 
`X. 
`
`
`
`
`
`
`
`
`ii
`
`

`

`TABLE OF AUTHORITIES
`
`
`
` Page(s)
`
`Cases
`Demaco Corp. v. F. Von Langsdorff Licensing, Ltd.,
`851 F.2d 1387 (Fed. Cir. 1988) ....................................................................................... 59
`In re Harza,
`274 F.2d 669 (C.C.P.A. 1960) .................................................................................. 34, 35
`Hewlett-Packard Co. v. Bausch & Lomb Inc.,
`909 F.2d 1464 (Fed. Cir. 1990) ................................................................................. 29, 53
`Hyundai Mobis Co., Ltd. v. Autoliv ASP, Inc.,
`IPR2014-01005, (PTAB Jan. 14, 2015) .......................................................................... 34
`KSR Int’l Co. v. Teleflex,
`550 U.S. 398 (2007) ................................................................................................. passim
`Leapfrog Enters., Inc. v. Fisher-Price, Inc.,
`485 F.3d 1157 (Fed. Cir. 2007) ....................................................................................... 59
`Optivus Tech., Inc. v. Ion Beam Applications S.A.,
`No. CV 03-2052 SJO, 2005 U.S. Dist. LEXIS 44535 (C.D. Cal. Mar. 14,
`2005) ............................................................................................................................... 34
`Ormco Corp. v. Align Tech., Inc.,
`463 F.3d 1299 (Fed. Cir. 2006) ....................................................................................... 59
`In re Shreiber,
`128 F.3d 1473 (Fed. Cir. 1997) ................................................................................. 29, 53
`Statutes
`35 U.S.C. § 102(b) .................................................................................................... 10, 23, 24
`35 U.S.C. § 103(a) ............................................................................ 11, 23, 24, 34, 36, 38, 47
`35 U.S.C. §§ 311-319 ............................................................................................................. 1
`35 U.S.C. § 315(b) .................................................................................................................. 9
`
`
`
`
`iii
`
`

`

`
`
`35 U.S.C. § 315(e)(1) ............................................................................................................. 9
`Other Authorities
`37 C.F.R. § 42 ........................................................................................................................ 1
`37 C.F.R. § 42.6(c) ............................................................................................................... 10
`37 C.F.R. § 42.8(a)(1) ............................................................................................................. 7
`37 C.F.R. § 42.8(b)(1) ............................................................................................................. 7
`37 C.F.R. § 42.8(b)(2) ............................................................................................................. 7
`37 C.F.R. §§ 42.8(b)(3) ........................................................................................................... 8
`37 C.F.R. § 42.8(b)(4) ............................................................................................................. 9
`37 C.F.R. § 42.10(a) ............................................................................................................... 8
`37 C.F.R. § 42.10(b) ............................................................................................................... 9
`37 C.F.R. § 42.15(a) ............................................................................................................... 9
`37 C.F.R. § 42.63 ................................................................................................................. 10
`37 C.F.R. § 42.100(b) ........................................................................................................... 19
`37 C.F.R. § 42.103 ................................................................................................................. 9
`37 C.F.R. § 42.104(a) ............................................................................................................. 9
`37 C.F.R. § 42.104(b) ........................................................................................................... 10
`37 C.F.R. § 42.104(b)(3) ....................................................................................................... 19
`37 C.F.R. § 42.104(b)(4)-(5) ................................................................................................. 23
`37 C.F.R. § 42.104(b) ........................................................................................................... 10
`37 C.F.R. § 42.108 ............................................................................................................... 10
`MPEP § 2114 .................................................................................................................. 29, 53
`MPEP § 2144.04(VI)(B) ........................................................................................................ 35
`
`
`
`
`iv
`
`

`

`EXHIBIT LIST
`
`
`
`EXHIBIT NO.
`
`DESCRIPTION
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`U.S. Patent No. 7,420,550 to Shen et al. (“‘550 Patent”)
`
`Japanese Patent Application Publication No. H08-305322 and
`Certified English Translation Thereof (“Sharp Reference”)
`
`U.S. Patent No. 6,081,250 to Shimada et al. (“Shimada”)
`
`U.S. Patent No. 6,407,795 to Kamizono et al. (“Kamizono”)
`
`Prosecution History of U.S. Appl. No. 10/929,473
`
`U.S. Patent No. 5,805,128 to Kim et al. (“Kim”)
`
`Declaration of Michael J. Marentic
`
`Curriculum Vitae of Michael J. Marentic
`
`U.S. Patent Application Publication No. US 2003/0048249 A1 to
`Sekido et al. (“Sekido”)
`
`
`
`
`
`
`
`
`
`
`

`

`
`
`I.
`
`INTRODUCTION
`Pursuant to 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42, Sharp Corporation, Sharp
`
`Electronics Corporation, and Sharp Electronics Manufacturing Company of America, Inc.
`
`(collectively “Petitioners”) respectfully petition for Inter Partes Review (“IPR”) of Claims 1-5
`
`of U.S. Patent No. 7,420,550 (“the ‘550 Patent,” Ex. 1001), which is assigned to Surpass
`
`Tech Innovation LLC (“Patent Owner” or “Surpass”). As demonstrated below, there is a
`
`reasonable likelihood that Petitioners will prevail in establishing that at least one of the
`
`Claims challenged in this Petition is unpatentable based on the prior art discussed
`
`below. Accordingly, institution of an IPR and initiation of trial is respectfully requested.
`
`The ‘550 Patent relates to liquid crystal display (“LCD”) panels, such as those used
`
`in flat screen televisions. As shown in Figure 4B (annotated below), the LCD panel of the
`
`‘550 Patent includes thin film transistors Q (“TFT”) arranged in a matrix array of rows and
`
`columns. Each column of TFTs is connected to a pair of “data lines” (e.g., D1 and D1’ in
`
`column C1) and each row (R1, R2, R3) of TFTs is connected to a gate line (e.g., G1).
`
`Image signals are sent to the TFTs via the data lines, and control signals are sent via the
`
`gate lines. A voltage output from each TFT drives the liquid crystal molecules in the
`
`corresponding pixel to form an image. The ‘550 Patent acknowledges that all of these
`
`elements were in the prior art.
`
`
`
`
`1
`
`

`

`
`
`
`
`The ‘550 Patent purports to improve upon the quality of moving images displayed in
`
`LCD panels by connecting the data lines to the TFTs in a specific manner. As shown above
`
`in annotated Figure 4B, independent Claims 1 and 2 of the ‘550 Patent require that in each
`
`column of TFTs: (1) the first data line (e.g., line D1, traced in red) is connected to the
`
`sources (the red dots) of the TFTs located in the “odd rows” (e.g., the red boxes in R1 and
`
`R3 in C1); and (2) the second data line (e.g., line D1’ , traced in green) in the same column is
`
`connected to the sources (the green dot) of TFTs located in the even rows (e.g., the green
`
`box in R2 in C1). By alternating the connection of data lines in this “Odd Row/Even Row”
`
`(e.g., red/green/red/green . . .) configuration, the response time of the LCD is allegedly
`
`reduced, resulting in an improvement to the quality of the moving image.
`
`However, this purported invention was old. As the Examiner recognized, the prior art
`
`disclosed this same “Odd Row/Even Row” configuration. During prosecution, the Examiner
`
`rejected the applicant’s claims over U.S. Patent No. 5,805,128 to Kim et al. (Ex. 1006,
`
`2
`
`
`

`

`“Kim”). (See Ex. 1005, p. 141). As shown in the annotated figure below, Kim discloses a
`
`virtually identical LCD driving device as that disclosed in the ‘550 Patent, including the Odd
`
`Row/Even Row configuration (shown in red and green).
`
`
`
`
`
`Notably, the applicant did not dispute that Kim disclosed the Odd Row/Even Row
`
`configuration, as well as all of the other basic elements of an LCD driving device (e.g.,
`
`multiple gate and source drivers). Rather, the Examiner focused on the fact that, in Kim, the
`
`first (red) data line 10 is connected to source driver 8, and that the second (green) data line
`
`14 is connected to a different source driver 12. The applicant sought to overcome Kim by
`
`including the additional limitation that “the first data lines and the second data lines of each
`
`group of data lines are connected with the same source driver.” As a result, the Examiner
`
`allowed the claims.
`
`As it turns out, connecting data lines to the same source driver was known too, and
`
`therefore provided no patentable weight to the Claims. Indeed, the ‘550 Patent identifies
`
`3
`
`
`

`

`
`
`this same configuration (i.e., connecting the data lines of each group to a single source
`
`driver) in Figure 1A, which is clearly labelled as “Prior Art.” Numerous prior art
`
`references that were not cited also disclose the allegedly novel “same source driver”
`
`limitation, including Japanese Patent Application Publication No. H08-305322 (Ex. 1002,
`
`“the Sharp Reference”) and U.S. Patent No. 6,081,250 to Shimada et al. (Ex. 1003,
`
`“Shimada”), both of which are owned by Petitioner Sharp Corporation.
`
`
`
`More particularly, Figure 10 (annotated below) of the Sharp Reference discloses an
`
`LCD driving circuit having first data lines (e.g., see the red line 6 in C1) and second data
`
`lines (e.g., see the green line 6 in C1) connected with the same source driver (e.g., see
`
`purple source driver labelled as “1”), which was the sole basis for allowance of the Claims.
`
`Moreover, the Odd Row/Even Row configurations in Figure 10 of the Sharp Reference and
`
`Figure 4B of the ‘550 Patent are indistinguishable. In the Sharp Reference, the first data
`
`line 5 (the red line) is connected to the sources (the red dots) of the TFTs located in the odd
`
`rows (the red boxes in R1, R3) of the first column C1, and the second data line 5 (the green
`
`line) in the same column is connected to the sources (the green dot) of the TFTs located in
`
`the even rows (the green box in R2). Like the ‘550 Patent, the Sharp Reference teaches
`
`that this Odd Row/Even Row configuration improves image quality. (Ex. 1002, Sharp
`
`Reference, Pars. [0030], [0144]-[0145]).
`
`
`
`
`4
`
`

`

`
`
`
`
`
`
`As set forth in the expert declaration of Michael J. Marentic (“Marentic Decl.”)
`
`submitted herewith, the Sharp Reference anticipates Claims 1-3 because it discloses all of
`
`their claim elements, including “gate lines” connected to “gate drivers” and “data lines”
`
`connect to “source drivers.” Additional grounds for the invalidity of Claims 1-3 are set forth
`
`below.
`
`Dependent Claims 4 and 5 require that the gate driver is a “chip installed on glass,”
`
`and that the gate driver is an “an integrated . . . circuit installed on glass,” respectively. U.S.
`
`Patent No. 6,407,795 to Kamizono et al. (“Kamizono,” Ex. 1004), which was filed years
`
`before the ‘550 Patent, teaches that chip on glass (“COG”) is the preferred way of
`
`implementing gate drivers, particularly in large-screen LCD displays. (Ex. 1004, Kamizono,
`
`Col. 1:12-58). Similarly, the Sharp Reference teaches that the gate driver can be an
`
`
`
`
`5
`
`

`

`
`
`integrated circuit “to improve the drive force of the pixel transistor that accompanies larger
`
`screen size.” (Ex. 1002, Sharp Reference, Par. [0160]). As explained by Mr. Marentic,
`
`Claims 4 and 5 would have been obvious to a person having ordinary skill in the art
`
`(“PHOSITA”) in view of the Sharp Reference and Kamizono since, inter alia, both
`
`references address the same need.
`
`Claims 1-5 are also obvious over Shimada in view of Kamizono. Shimada also
`
`teaches an LCD panel that is virtually identical to the claimed LCD driving device. As
`
`shown in Figure 4 of Shimada (annotated below), the first and second data lines (red and
`
`green) are connected to the same source driver 108 and also includes the exact same Odd
`
`Row/Even Row configuration as the ‘550 Patent. (Ex. 1003, Shimada, Cols. 2:66-3:2 and
`
`Col. 5:49-66).
`
`
`
`
`
`
`
`
`6
`
`

`

`
`
`Kamizono discloses the claimed source and gate drivers of Claims 1 and 2. (See,
`
`e.g., Ex. 1004, Kamizono, Fig. 15). As discussed above, Kamizono addresses design
`
`needs for large-screen LCD displays, as does Shimada. Because both references address
`
`the same need, under KSR and as explained by Mr. Marentic, a PHOSITA making a large
`
`sized LCD panel would have been motivated to include the source and gate drivers of
`
`Kamizono in the driving device of Shimada. KSR Int’l Co. v. Teleflex, 550 U.S. 398, 416
`
`(2007). As such, Claims 1-5 are also invalid as obvious.
`
`For at least the foregoing and following reasons, there is a reasonable likelihood that
`
`Petitioner will prevail in establishing that Claims 1-5 are invalid and Inter Partes Review of
`
`these Claims should thus be instituted.
`
`II.
`
`MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(a)(1)
`A.
`Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1)
`Petitioners Sharp Corporation, Sharp Electronics Corporation, and Sharp Electronics
`
`Manufacturing Company of America, Inc. are the real parties-in-interest.
`
`Related Matters Under 37 C.F.R. § 42.8(b)(2)
`B.
`The ‘550 Patent is the subject of litigation in the District of Delaware, namely,
`
`Surpass Tech Innovation LLC v. Sharp Corporation et al., Case No. 1:14-cv-00338-LPS (D.
`
`Del.) (“the Litigation”). Petitioners are among the named defendants in that Litigation. The
`
`‘550 Patent is also the subject of another litigation in the District of Delaware, Surpass Tech
`
`Innovation LLC v. Samsung Display Co., Ltd. et al., Case No. 1:14-cv-00337-LPS (D. Del.).
`
`
`
`
`7
`
`

`

`
`
`The ‘550 Patent was also the subject of an earlier petition for inter partes review filed
`
`by Petitioners on October 3, 2014 (Case IPR2015-00022). On March 10, 2015, the Board
`
`declined to institute of inter partes review based on the earlier petition, citing Petitioner’s
`
`lack of expert declaration. (IPR2015-00022, Paper 9). The present Petition relies on
`
`completely new grounds, as it includes prior art which Petitioners were not aware of at the
`
`time that the earlier petition was filed. The new grounds set forth in this Petition are fully
`
`supported by Mr. Marentic’s expert declaration submitted herewith. The ‘550 Patent is also
`
`currently the subject of IPR2015-00887, which was requested by different petitioners on
`
`March 17, 2015.
`
`The asserted patents in the litigations include the ‘550 Patent and U.S. Patent No.
`
`7,202,843, which is currently the subject of IPR2015-00021, which was requested by
`
`Petitioners. On November 21, 2014, the District Court ordered that the Litigation be stayed.
`
`Lead and Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3)
`C.
`Pursuant to 37 C.F.R. §§ 42.8(b)(3) and 42.10(a), Petitioner provides the following
`
`designation of lead and back-up counsel, as well as their respective service information.
`
`Lead Counsel
`Anthony F. Lo Cicero (Reg. No. 29,403)
`Amster, Rothstein & Ebenstein LLP
`90 Park Avenue
`New York, NY 10016
`Telephone: (212) 336–8110
`Facsimile: (212) 336–8001
`E-mail: alocicero@arelaw.com
`
`Back-Up Counsel
`Brian A. Comack (Reg. No. 45,343)
`Amster, Rothstein & Ebenstein LLP
`90 Park Avenue
`New York, NY 10016
`Telephone: (212) 336–8098
`Facsimile: (212) 336–8001
`E-mail: Sharp-550IPR@arelaw.com
`
`
`
`
`
`8
`
`

`

`
`
`Pursuant to 37 C.F.R. § 42.10(b), Petitioners’ Powers of Attorney accompany this
`
`Petition.
`
`Service Information Under 37 C.F.R. § 42.8(b)(4)
`D.
`Service information (by e-mail, postal mailing, or hand-delivery) for lead and back-up
`
`counsel is provided in the above designation of lead and back-up counsel. Petitioners also
`
`consent to electronic service by e-mail at Sharp-550IPR@arelaw.com, with cc to
`
`alocicero@arelaw.com.
`
`III.
`
`PAYMENT OF FEES UNDER 37 C.F.R. § 42.103
`The undersigned hereby provides authorization to charge Deposit Account No. 01-
`
`1785 to cover the fee of $23,000 for this Petition, as specified in 37 C.F.R. § 42.15(a). If
`
`this amount is insufficient or excessive, the Commissioner is authorized to deduct any
`
`underpayment from, or credit any overpayment to, Deposit Account No. 01-1785.
`
`IV.
`
`GROUNDS FOR STANDING UNDER 37 C.F.R. § 42.104(a)
`Petitioners certify that the ‘550 Patent is available for Inter Partes Review and the
`
`estoppel provisions of 35 U.S.C. § 315(e)(1) do not bar or estop Petitioners from requesting
`
`Inter Partes Review of any claim of the ‘550 Patent on the grounds raised herein.
`
`Petitioners submit that, under 35 U.S.C. § 315(b), they are not barred from filing this Petition
`
`because Petitioners (including any privies) were not served with a complaint asserting
`
`infringement of the ‘550 Patent more than one year prior to filing this Petition.
`
`
`
`
`9
`
`

`

`
`
`V.
`
`IDENTIFICATION OF CHALLENGED CLAIMS UNDER 37 C.F.R. § 42.104(b) AND
`RELIEF REQUESTED
`Petitioners request Inter Partes Review and initiation of trial under 37 C.F.R.
`
`§ 42.108 and cancellation of Claims 1-5 of the ‘550 Patent as unpatentable based on the
`
`statutory grounds set forth and explained below. In accordance with 37 C.F.R. §§ 42.6(c)
`
`and 42.63, a copy of the ‘550 Patent is submitted as Exhibit 1001. The publicly available
`
`records in the Office indicate that the ‘550 Patent is currently assigned to Surpass Tech
`
`Innovation LLC.
`
`A.
`
`Claims for Which Inter Partes Review Is Requested Under 37 C.F.R.
`§ 42.104(b)(1)
`Petitioner requests Inter Partes Review of Claims 1-5 of the ‘550 Patent.
`
`B.
`
`The Specific Art and Statutory Grounds on Which the Challenge Is
`Based Under 37 C.F.R. § 42.104(b)(2)
`This Petition is based on the following references, which are all prior art to the ‘550
`
`Patent under 35 U.S.C. § 102(b): (1) the Sharp Reference (Ex. 1002), which was published
`
`on November 22, 1996; (2) Shimada (Ex. 1003), which issued on June 27, 2000; and (3)
`
`Kamizono (Ex. 1004), which issued on June 18, 2002.
`
`Petitioner requests cancellation of Claims 1-5 based upon the following specific
`
`grounds:
`
`Ground 1: Claims 1-3 are invalid under 35 U.S.C. § 102(b) as anticipated by the
`
`Sharp Reference;
`
`
`
`
`10
`
`

`

`
`
`Ground 2: Claims 1-3 and 5 are invalid under 35 U.S.C. § 103(a) as obvious over
`
`the Sharp Reference;
`
`Ground 3: Claims 1-5 are invalid under 35 U.S.C. § 103(a) as obvious over the
`
`Sharp Reference in view of Kamizono; and
`
`Ground 4: Claims 1-5 are invalid under 35 U.S.C. § 103(a) as obvious over Shimada
`
`in view of Kamizono.
`
`For the reasons set forth herein, there is a reasonable likelihood that Petitioners will
`
`prevail in establishing that at least one of Claims 1-5 of the ‘550 Patent is unpatentable
`
`based on Grounds 1-4.
`
`VI.
`
`SUMMARY OF THE ‘550 PATENT
`The ‘550 Patent is entitled “Liquid Crystal Display Driving Device of Matrix Structure
`
`Type and Its Driving Method” and issued on September 2, 2008 from U.S. Patent
`
`Application No. 10/929,473 (“the ‘473 Application”), filed on August 31, 2004. According to
`
`the Patent Office records, the ‘550 Patent does not claim priority to any earlier domestic or
`
`foreign patent application.
`
`Specification of the ‘550 Patent
`A.
`As discussed below, the alleged invention in the ‘550 Patent relates to a specific way
`
`of connecting the gate and data lines to the TFTs in an LCD panel.
`
`LCD Panels and Driving Devices Were Known in the Prior Art
`1.
`As acknowledged in the ‘550 Patent, the applicants for the ‘550 Patent did not invent
`
`LCD panels or driving devices. (Ex. 1001, ‘550 Patent, Col. 1:23-61, Figs. 1A-1B). Nor did
`
`11
`
`
`

`

`
`
`the applicants invent the use of gate and data lines, source and gate drivers, or switches in
`
`LCD panels. (Id. at Col. 1:34-61, Figs. 1A-1B).
`
`According to the ‘550 Patent and as shown below by multiple shaded blocks in
`
`annotated Figure 1A, the “Prior Art” driving device for LCD panels included multiple source
`
`drivers 11 and multiple gate drivers 12. (Id. at Fig. 1A). The source drivers 11 (see the
`
`purple boxes) provide image signals (i.e., video signals) to an LCD panel 10 through a
`
`plurality of data lines 111 (see the purple lines), while the gate drivers 12 (see the orange
`
`boxes) provide scanning signals (i.e., control signals) to the LCD panel 10 through a
`
`plurality of gate lines 121 (see the orange lines).
`
`As shown above, prior art LCD panels included data lines 111 and gate lines 121
`
`arranged in a matrix array. (See id. at Fig. 1A). According to the ‘550 Patent, the data lines
`
`111 and gate lines 121 in the “Prior Art” shown in Figures 1A and 1B are “insulated with
`
`
`
`each other.” (Id. at Col. 1:45-47).
`
`
`
`
`12
`
`

`

`
`
`In this prior art LCD panel, a pixel 13 is formed within each area enclosed by
`
`intersecting data lines (e.g., purple line D1) and gate lines (e.g., orange line G1). (Ex. 1007,
`
`Marentic Decl. at Par. 41). As was well known, each pixel 13 includes a thin film transistor
`
`Q1 (TFT, highlighted in yellow), which is switched on and off by a control signal from the
`
`gate driver 12 through a gate line G1. (Id. at Par. 42). The source of the TFT Q1 receives
`
`the image signal sent from the source driver 11 through the data line D1. (Id. at Par. 43). A
`
`voltage is output from the TFT Q1, which drives liquid crystal molecules corresponding to
`
`the pixel 13 to form an image. (Id.; see also Ex. 1001, ‘550 Patent at Col. 1:45-57, Fig. 1B).
`
`The time that an LCD needs to react to the driving voltage output by each TFT is
`
`called “response time,” and the image quality of an LCD panel is dependent on this
`
`response time. (Ex. 1007, Marentic Decl. at Par. 44). In this regard, the image quality may
`
`be poor if the LCD response time is too long. (Id.).
`
`The Alleged Invention of the ‘550 Patent
`2.
`The “chief object” of the ‘550 Patent is to provide an LCD driving device 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. (Ex. 1001, ‘550 Patent at Col.
`
`3:18-20, 35-40). This configuration is illustrated in annotated Figure 4B below.
`
`
`
`
`13
`
`

`

`
`
`
`
`As shown above, the driving device includes a matrix array formed from rows
`
`(annotated as R1-R3) and columns (annotated as C1-C3) of TFTs (Q). (Ex. 1007, Marentic
`
`Decl. at Par. 46). Each TFT in the matrix is associated with a pixel (represented by the
`
`dashed rectangles). (Id.). The driving device further includes a certain number (“N”) of gate
`
`lines Gi (i=1, 2, ... N), and a certain number (“M”) of groups (e.g., pairs) of data lines Dj and
`
`Dj’ (j, j’=(1,1’), (2, 2’), ... (M, M’)). (Id.). For example, as shown in Figure 4B above, the
`
`driving device has three gate lines, G1, G2, and G3, and two groups of data lines ((D1, D1’ )
`
`and (D2, D2’)). (Id.).
`
`As shown above, the gate line Gi (e.g., G1, G2, and G3) in each row is connected to
`
`the gates of each TFT in that row. (Id. at Par. 51). However, for each column, the first and
`
`second data lines Dj and Dj’ that form a group of data lines are not connected to all TFTs in
`
`that column. (Id.). Instead, the first data line Dj in each column is connected only to the
`
`14
`
`
`

`

`
`
`sources of the TFTs in the odd rows (see the red boxes in R1, R3, etc.) of that column,
`
`while the second data line Dj’ in the same column is connected only to the sources of the
`
`TFTs in the even rows (see the green box in R2) of that column. (Id.; see also Ex. 1001,
`
`‘550 Patent at Col. 8:10-31).
`
`This alternating connection with the Odd Row/Even Row rows (“Odd Row/Even Row”
`
`configuration) allegedly reduces the response time of the LCD, but the ‘550 Patent does not
`
`explain how this reduction occurs. (Id. at Col. 3:35-40).
`
`The gate lines are connected to the gate driver and are “insulated with each other”
`
`and, the data lines are connected to the source driver and are “insulated with each other.”
`
`(Id. at 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., D1’ and D2) to prevent them from short
`
`circuiting. (Id. at Col. 8:31-36, Fig. 4C).
`
`As shown below in annotated Figure 6A, the first and second data lines Dj and Dj’
`
`(e.g., see the red and green lines D1 and D1’) in each group (i.e., pair) of data lines are
`
`connected to the same source driver (see the 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).
`
`In addition, all of the source drivers are installed on the same side (e.g., upper side) of the
`
`LCD panel. (See 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).
`
`
`
`
`15
`
`

`

`
`
`
`Finally, the ‘550 Patent 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”
`
`(“COG”) and “an integrated gate driver circuit on glass.”
`
`Claims 1-5 of the ‘550 Patent
`B.
`Claims 1-5 of the ‘550 Patent are directed to a display having a driving device of a
`
`matrix structure type. Independent Claims 1 and 2 both contain identical limitations directed
`
`to components that the ‘550 Patent admits were included in conventional LCD driving
`
`device (e.g., TFTs in a matrix array, gate and source drivers, gate and data lines). These
`
`claims also require that the first and second data lines in each group (e.g., pair) of data lines
`
`
`
`
`16
`
`

`

`
`
`are connected with the sources of the TFTs in the odd and even rows of the corresponding
`
`column, respectively (i.e., the “Odd Row/Even Row” configuration), as shown in Figure 4B.
`
`Additionally, Claims 1 and 2 recite that first and second data lines of each group (i.e.,
`
`pair) of data lines are connected to the same source driver. Claim 2 further recites that (1)
`
`each source driver is installed on the same side of the display panel (see each “Source
`
`Driver” in Figure 6A), and (2) the data transfer is switched by an electronic switch (see “S” in
`
`Figure 6A). Dependent Claim 3 requires that there be a space in between the neighboring
`
`data lines. Dependent Claims 4 and 5 require that the gate driver be a COG and an
`