`
`
`
`
`
`
`
`EXHIBIT F-4
`EXHIBIT F-4
`
`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 1 of 161
`
`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 1 of 161
`
`

`

`Exhibit F-4
`
`U.S. Patent No. 8,946,574 (“’574 Patent”)
`
`U.S. Patent No. 7,030,860 (“Hsu”)
`
`U.S. Patent No. 7,030,860 (“Hsu”) was filed on October 8, 1999, and issued on April 18, 2006. Hsu qualifies as prior art to U.S.
`Patent No. 8,946,574 (“’574 Patent”) at least under 35 U.S.C. §102(b) (pre-AIA) and anticipates and, alone or with other references,
`renders obvious one or more of claims 1–4, 6–11, and 13–15. To the extent Hsu does not disclose one or more limitations of the
`claims, it would have been obvious to combine the teachings of Hsu with the knowledge of one of ordinary skill in the art and one or
`more of the references below to render the claims at issue in the ’574 patent invalid.
`
`• U.S. Patent Publication No. 2012/0127079 (“Trend”) was filed on November 23, 2010 and published on May 24, 2012. Trend
`qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(e) (pre-AIA).
`• U.S. Patent No. 5,386,219 (“Greanias”) was filed on July 28, 1993 and published on January 31, 1995. Greanias qualifies as
`prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent No. 6,970,160 (“Mulligan”) was filed on December 19, 2002 and published on November 29, 2005. Mulligan
`qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent No. 7,538,760 (“Hotelling760”) was filed on March 30, 2006 and published on May 26, 2009. Hotelling760
`qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent No. 7,395,717 (“DeAngelis”) was filed on February 10, 2006 and published on July 8, 2008. DeAngelis qualifies
`as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent Publication No. 2011/0007011 (“Mozdzyn”) was filed on June 26, 2010 and published on January 13, 2011.
`Mozdzyn qualifies as prior art to the ’574 Patent under 35 U.S.C. §§ 102(a) and 102(e) (pre-AIA).
`• U.S. Patent Publication No. 2010/0123670 (“Philipp”) was filed on April 10, 2009 and published on May 20, 2010. Philipp
`qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent Publication No. 2009/0002337 (“Chang”) was filed on May 16, 2008 and published on January 1, 2009. Chang
`qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent Publication No. 2009/0219257 (“Frey”) was filed on February 26, 2009 and published on September 3, 2009. Frey
`qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent No. 5,305,017 (“Gerpheide”) was filed on July 13, 1992 and published on April 19, 1994. Gerpheide qualifies as
`prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`
`LEGAL02/39531529v4
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`1
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 2 of 161
`
`

`

`• U.S. Patent No. 5,880,411 (“Gillespie”) was filed on March 28, 1996 and published on March 9, 1999. Gillespie qualifies as
`prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent Publication No. 2008/0158167 (“Hotelling167”) was filed on January 3, 2007 and published on July 3, 2008.
`Hotelling qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`• U.S. Patent Publication No. 2010/0045632 (“Yilmaz”) was filed on April 10, 2009 and published on February 25, 2010.
`Yilmaz qualifies as prior art to the ’574 Patent under 35 U.S.C. § 102(b) (pre-AIA).
`
`
`The excerpts cited herein are exemplary. For any claim limitation, Defendant may rely on excerpts cited for any other limitation
`and/or additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a
`reference’s disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional
`descriptions of that figure should be understood to be incorporated by reference as if set forth fully herein.
`
`These invalidity contentions are not an admission by Defendants that the accused products or components, including any current or
`past version of these products or components, are covered by, or infringe the asserted claims, particularly when these claims are
`properly construed and applied. These invalidity assertions are also not an admission that Defendants concede or acquiesce to any
`claim construction(s) implied or suggested by Plaintiff in its Complaint or the associated infringement claim charts. Nor are
`Defendants asserting any claim construction positions through these charts, including whether the preamble is a limitation. Defendants
`also do not concede or acquiesce that any asserted claim satisfies the requirements of 35 U.S.C. §§ 112 or 101 and submit these
`invalidity contentions only to the extent Plaintiff’s assertions may be understood.
`
`
`
`LEGAL02/39531529v4
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`2
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 3 of 161
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`

`

`
`
`Asserted Claims
`
`Claim 1
`
`[1pre] An apparatus comprising:
`
`Prior Art Disclosures
`
`
`
`Hsu, alone or in combination with the references listed above and/or the knowledge of a person
`of ordinary skill in the art, discloses and/or renders obvious the apparatus recited in claim 1.
`For example, Hsu anticipates and/or alone or in combination with (1) any one of Trend,
`Greanias, Mulligan, Hotelling760, DeAngelis, Mozdzyn, Philipp, and Chang; (2) any one of
`Greanias, Mulligan, Hotelling760, and DeAngelis in view of any one of Mozdzyn, Philipp, and
`Chang; and further in light of the knowledge of a person of ordinary skill in the art, discloses
`and/or renders obvious the apparatus recited in claim 1.
`
`For example, Hsu discloses:
`
`Hsu at Abstract:
`
`A transparent, capacitive sensing system particularly well suited for input to electronic
`devices is described. The sensing system can be used to emulate physical buttons or
`slider switches that are either displayed on an active display device or printed on an
`underlying surface. The capacitive sensor can further be used as an input device for a
`graphical user interface, especially if overlaid on top of an active display device like an
`LCD screen to sense finger position (X/Y position) and contact area (Z) over the
`display. In addition, the sensor can be made with flexible material for touch sensing on
`a three-dimensional surface. Because the sensor is substantially transparent, the
`underlying surface can be viewed through the sensor. This allows the underlying area to
`be used for alternative applications that may not necessarily be related to the sensing
`system. Examples include advertising, an additional user interface display, or apparatus
`such as a camera or a biometric security device.
`
`Hsu at 1:8-12:
`
`The present invention relates to touch sensing transducers and systems. More
`particularly, the present invention relates to flexible and transparent object position
`
`LEGAL02/39531529v4
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`3
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
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`Page 4 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`recognition devices useful in applications such as cursor movement and user input for
`computing devices and other applications.
`
`Hsu at 8:1-26:
`
`In yet another embodiment, FIG. 7 shows a two-dimensional transparent capacitive
`sensor 36. Transparent substrate 84 is adhered using transparent insulator 74 to
`transparent conductor layer 64. Transparent conductor 64 contains the X trace pattern
`as shown in FIG. 5A and is coated onto transparent substrate 86. On the other surface
`of transparent substrate 86, transparent conductor layer 70 contains Y trace array shown
`FIG. 5B. Finally, transparent substrate 88 is adhered to transparent conductor 70 with
`transparent insulator 74. This particular embodiment, with substrate 86 coated on both
`sides with transparent conductor layers may allow for less error when aligning
`diamonds in the X trace array and the Y trace array. Because substrate 86 contains both
`conductor layers 64 and 70, the alignment of trace arrays can occur prior to the
`etching/deposition of the trace arrays with the opaque photoresist pattern, greatly
`simplifying pattern alignment of X and Y traces. Proper alignment of the X and Y trace
`arrays is critical to the overall transparency of two-dimensional sensor 36 because the
`human eye can easily detect any systematic misalignment between the trace array
`patterns.
`
`Examples of transparent, electrically insulating substrates 84,86, and 88 have been
`described in previous embodiments of two-dimensional sensor 36 and one-dimensional
`sensor 20.
`
`Hsu at Figure 7:
`
`LEGAL02/39531529v4
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`4
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 5 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`[1a] a first optically clear adhesive
`(OCA) layer between a first cover
`sheet and a substrate;
`
`
`A POSITA would have understood that the apparatus is configured to recognize the position of
`an object using optically clear adhesive (OCA) layers, cover sheets, substrates, drive and sense
`electrodes, a touch sensor, conductive mesh, and a display.
`
`Hsu, alone or in combination with the references listed above and/or the knowledge of a person
`of ordinary skill in the art, discloses and/or renders obvious “a first optically clear adhesive
`(OCA) layer between a first cover sheet and a substrate.” For example, Hsu anticipates and/or
`alone or in combination with any one of Trend, Greanias, Mulligan, Hotelling760, and
`DeAngelis; and further in light of the knowledge of a person of ordinary skill in the art,
`discloses and/or renders obvious “a first optically clear adhesive (OCA) layer between a first
`cover sheet and a substrate.”
`
`For example, Hsu discloses:
`
`Hsu at 8:2-6:
`
`LEGAL02/39531529v4
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`5
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`IPR2020-00459
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`Page 6 of 161
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`Asserted Claims
`
`Prior Art Disclosures
`
`Transparent substrate 84 [i.e., the top-most layer in Fig. 7] is adhered using transparent
`insulator 74 to transparent conductor layer 64. Transparent conductor 64 contains the X
`trace pattern as shown in FIG. 5A and is coated onto transparent substrate 86.
`
`Layer 74 acts as both an adhesive and an insulator.
`
`Hsu at Figure 7:
`
`
`A POSITA would have looked to the earlier embodiments for a suitable insulating material that
`could also serve to adhere such an electrically insulating layer to a layer such as layer 64 of
`Figure 7.
`
`In connection with the embodiment of Figure 2, Hsu discloses:
`
`A top transparent and electrically insulating substrate 52 is adhered with an optically
`transparent and electrically insulating adhesive 54 to another transparent, electrically
`insulating substrate 58 that is coated with a transparent conductor 56.
`
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`6
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`IPR2020-00459
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`Page 7 of 161
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`Asserted Claims
`
`Prior Art Disclosures
`
`Hsu at Figure 2:
`
`
`
`Hsu at 4:55-56:
`
`One example of a transparent, electrically insulating adhesive is 3M #8142.
`
`A POSITA would have found it obvious, and been motivated, to look to the adhesion materials
`and functions of Hsu to form the adhesion layers.
`
`To the extent this reference does not expressly disclose this limitation, it inherently discloses it.
`Furthermore, to the extent this limitation is not disclosed, this limitation is rendered obvious in
`light of this reference by itself, this reference combined with the knowledge of a POSITA, and
`this reference combined with the references below and/or the other references charted for this
`patent. These references all are in comparable fields and have similar disclosures such that they
`are readily combinable. For example, at least certain of the prior art references below and/or
`the prior art references charted for this patent disclose touch sensors configured to detect the
`presence and location of a touch by a finger or an object, such as a stylus, within an area of an
`external interface of the touch sensor, as established in these charts. Thus, it would have been
`
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`7
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`IPR2020-00459
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`Page 8 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`obvious to a POSITA to combine the teachings of this reference with the references below
`and/or the other references charted for this patent.
`
`Additional motivation arises from this reference and/or the below references from a desire to
`provide (1) a cover sheet to protect the drive mesh electrodes, sense mesh electrodes, substrate,
`and/or display; (2) a cover sheet to provide a surface for an object, such as a finger or stylus, to
`make contact with the touch sensor; (3) an adhesive layer to combine a cover sheet, a substrate,
`and/or drive and/or sense mesh electrodes so as to be optically clear; (4) a single-substrate
`touch sensor device; (5) mesh electrodes made of a metal mesh conductive material; (6) metal
`mesh electrodes made of highly conductive metal; (7) mesh segments of mesh electrodes that
`have a width to provide sufficient light from the display to pass around the mesh electrodes to
`make the electrodes essentially invisible to the eye; (8) one or more mesh segments that
`provides greater transparency of the position-sensing panel to reduce visibility of the electrodes
`to the human eye and reduce perceptible darkening or other loss of display quality;
`(9) conductive meshes having an optical transmissivity so that the position-sensing panel is less
`visible to the human eye; (10) sense electrodes disposed on a surface of the substrate and drive
`electrodes disposed on another surface of the substrate so that a capacitance change can be
`detected when an external influence, such as a finger or stylus, comes into proximity of the
`overlap of drive and sense electrodes; (11) increased coverage of a sensing area of a
`touchscreen with little loss of optical quality; (12) increasing the number of sensing nodes or
`discrete sensing areas in a touchscreen; (13) creation of mesh segments of mesh electrodes that
`spans the sensing area to maximize the touch sensitive area; (14) creation of an optically
`uniform touch-sensitive display; (15) improvement of touchscreen detection and functionality;
`and/or (16) improved performance of a touch sensor.
`
`Exemplary Combination with Trend
`
`For example, Trend discloses:
`
`Trend at [0030]:
`
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`8
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`IPR2020-00459
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`Page 9 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`In another arrangement illustrated in FIG. 3B, the sense electrodes 301 and the drive
`electrodes 303 may be formed on opposing surfaces of the same substrate 313. In this
`example, the sense electrodes 301 are on the upper surface of the substrate 313 and the
`drive electrodes 303 are on the lower surface opposite the upper surface of the substrate
`313. As with FIG. 3A, a light source 311 such as a display or a backlight may be
`arranged to transmit light through the position sensing panel towards a user. A
`transparent cover sheet 317 may be separated from the sense electrodes 301 by
`pressure-sensitive adhesive layer 315.
`
`Trend at [0032]:
`
`Substrates 307, 309, 313 and cover sheet 317 may each be formed from a transparent,
`non-conductive material such as glass or a plastic. Plastic substrates and cover sheets
`are suitable to provide flexibility to the position-sensing panel. Examples of suitable
`plastic substrate materials include, but are not limited to polyethylene terephthalate
`(PET), polyethylene naphthalate (PEN), or polycarbonate (PC). Examples of suitable
`plastic materials for the transparent cover sheet 317 include, but are not limited to,
`polycarbonate and poly(methyl methacrylate) (PMMA).
`
`Trend at Figure 3B:
`
`LEGAL02/39531529v4
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`9
`
`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 10 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`
`A POSITA would have been motivated to use an adhesive layer that is optically clear. A
`POSITA would have understood that a purpose of the touch screen is to permit light from the
`display to be transmitted through the position sensor. A POSITA would have understood that
`using optically clear adhesives can achieve this purpose.
`
`A POSITA would have been motivated to combine the teachings of these references to achieve
`this element at least because they disclose touch sensors configured to detect the presence and
`location of a touch by a finger or an object, such as a stylus, within an area of an external
`interface of the touch sensor. Further, these references sought to address the same problem. For
`example, Hsu provides that a “primary object of this invention is a positioning system that uses
`a low-cost, highly integrated, low power, capacitive transparent sensor.” Hsu, Abstract.
`Similarly, Trend provides position sensors with improved transparency using drive and sense
`
`LEGAL02/39531529v4
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`10
`
`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 11 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`electrodes that can detect the presence and location of a touch by both a finger and an object
`such as a stylus. Trend, [0001]-[0004].
`
`Moreover, both references disclose a substrate, an adhesive layer, and a cover sheet. Hsu, 4:55-
`56, 8:2-6, Figs. 2, 7; Trend, [0030], [0032], Fig. 3B. Thus, a POSITA would have been
`motivated to combine the teachings of these references at least because they sought to address
`the same problem with similar features and/or functionalities.
`
`A POSITA seeking to apply the teachings of these references would have been motivated to
`practice this limitation for the reasons set forth in these references and as a matter of common
`sense. Additional motivation arises from a desire to overcome known problems and implement
`a touch sensor using known techniques. Additional motivation to do so arises from combining
`prior art elements according to known methods to yield predictable results to improve a similar
`device. Doing so would have been within the abilities of a POSITA, would not have required
`undue effort, and would have led to expected results. Practicing this limitation amounts to
`merely choosing from a finite number of identified, predictable solutions, with a reasonable
`expectation of success. For example, combining prior art elements according to known
`methods would have yielded a predictable result with a reasonable expectation of success.
`
`Exemplary Combination with Greanias
`
`For example, Greanias discloses:
`
`Greanias at 19:31-47:
`
`FIG. 6 is a cross-sectional representation of a face-out overlay structure. In this
`structure, both lower conductors 91 and upper conductors 93 are deposited on a single
`substrate 101. As shown, the lower conductors 91 are oriented down and the upper
`conductors 93 are oriented up. Top cover 98 is attached by adhesive layer 96 to the
`upper surface of the substrate. A bottom cover 103 may be attached to the lower surface
`of the substrate 101 by adhesive layer 92, and attached to the LCD 18 by adhesive layer
`99. In an alternative embodiment, the bottom cover layer can be dispensed with entirely
`
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`11
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`Exhibit 2003
`IPR2020-00459
`
`Page 12 of 161
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`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`and the face-out overlay glued directly to the LCD 18. Eliminating the bottom cover
`103 would improve the transparency of the overlay 16 as there would be fewer layers
`for the LCD display 18 to shine through, as well as increasing the durability of the
`lower conductors 91.
`
`Greanias at Figure 6:
`
`Greanias at 18:9-37:
`
`
`
`Several of the following comments regarding materials, supplementary layers and
`conductors spacing are equally applicable to the overlay structures depicted in FIGS. 6,
`7, and 8. All components of the overlay are chosen for maximum optical
`transmissibility. As mentioned previously, the preferred transparent conductor material
`is ITO. None of the overlays depicted in FIG. 5, 6, 7 and 8 are drawn to scale. The
`indium tin oxide conductors 91, 93 are approximately 600 to 1600 Angstroms in
`thickness, much thinner than the substrate or adhesive layers. The exact thickness of the
`ITO depends on the desired sheet resistance of the overlay conductors. A preferred ITO
`thickness of 900 Angstroms yields a resistance of approximately 80 ohms per square
`inch. The substrate layers and top cover are preferably of biaxially oriented
`polyethylene terephthalate (PET), or polyester, formed in the desired thickness for the
`particular layer. A number of transparent adhesives can be used to attach the substrate
`
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`12
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`Exhibit 2003
`IPR2020-00459
`
`Page 13 of 161
`
`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`together. A sheet form is preferred for manufacturing purposes. A variety of heat
`setting polyester adhesive layers are attractive because their hardness can be matched
`closely to the hardness substrate layers to minimize the forces exerted on the ITO
`conductors, particularly when a relatively hard adhesive is directly below a down facing
`ITO conductor layer. A pressure sensitive acrylic adhesive is more transparent than the
`polyester adhesive and can produce a more attractive, if somewhat less durable overlay.
`
`A POSITA would have been motivated to combine the teachings of these references to achieve
`this element at least because they disclose touch sensors configured to detect the presence and
`location of a touch by a finger or an object, such as a stylus, within an area of an external
`interface of the touch sensor. Further, these references sought to address the same problem. For
`example, Hsu provides that a “primary object of this invention is a positioning system that uses
`a low-cost, highly integrated, low power, capacitive transparent sensor.” Hsu, Abstract.
`Similarly, Greanias provides an “improved touch overlay for the viewing surface of a display
`for detecting both finger touch and stylus location.” Greanias, Abstract.
`
`Moreover, both references disclose a substrate, an adhesive layer, and a cover sheet. Hsu, 4:55-
`56, 8:2-6, Figs. 2, 7; Greanias, 19:31-47, Fig. 6. Thus, a POSITA would have been motivated
`to combine the teachings of these references at least because they sought to address the same
`problem with similar features and/or functionalities.
`
`A POSITA seeking to apply the teachings of these references would have been motivated to
`practice this limitation for the reasons set forth in these references and as a matter of common
`sense. Additional motivation arises from a desire to overcome known problems and implement
`a touch sensor using known techniques. Additional motivation to do so arises from combining
`prior art elements according to known methods to yield predictable results to improve a similar
`device. Doing so would have been within the abilities of a POSITA, would not have required
`undue effort, and would have led to expected results. Practicing this limitation amounts to
`merely choosing from a finite number of identified, predictable solutions, with a reasonable
`expectation of success. For example, combining prior art elements according to known
`methods would have yielded a predictable result with a reasonable expectation of success.
`
`LEGAL02/39531529v4
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`13
`
`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 14 of 161
`
`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`Exemplary Combination with Mulligan
`
`For example, Mulligan discloses:
`
`Mulligan at 3:60-4: 27:
`
`FIG. 2 is an exploded view of an exemplary embodiment of touch-sensitive screen 210.
`FIG. 2 only illustrates the principle components in touch-sensitive screen 210. Other
`components may be added without deviating from the principles of the invention.
`
`Touch-sensitive screen 210 is made up of a series of layers laminated together. In this
`embodiment, touch-sensitive screen 210 includes a touch pane 220 and a lattice touch-
`sensing element 230. The lattice touch-sensing element 230 includes a first sensor layer
`240, a second sensor layer 260, and an intermediate dielectric layer 250 disposed
`between the first sensor layer 240 and the second sensor layer 260.
`
`The touch pane 220 is the uppermost layer of the touch-sensitive screen 210. The touch
`pane 220 may be made of an optically clear substance. The touch pane 220 may be
`manufactured from a chemically strengthened glass, transparent plastic, or any other
`acceptable dielectric material. One side of the touch pane 220 serves as the touch
`surface of the touch-sensitive screen 210, while the other side of the touch pane 220 is
`attached to the lattice touch-sensing element 230. The touch pane 220 provides the
`necessary dielectric material between the touching object and the sensing element, as
`well as protecting the touch-sensing element 230 from environmental hazards.
`
`The top layer of the lattice touch-sensing element 230 is the first sensor layer 240. The
`first sensor layer 240 includes a plurality of capacitive touch-sensitive sensor bars 270
`arranged substantially parallel to each other in a unidirectional manner. They are
`preferably constructed of indium tin oxide (ITO) for optical transparency, but may be
`constructed of any conductive transparent material for transparent applications, such as
`other transparent conductive oxides as well as transparent conductive polymers.
`
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`14
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`Exhibit 2003
`IPR2020-00459
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`Page 15 of 161
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`

`Asserted Claims
`
`Prior Art Disclosures
`
`Alternatively, the sensor bars may be constructed from conductive non-transparent
`material for applications that do not require transparency.
`
`Mulligan at Figure 2:
`
`
`A POSITA would have been motivated to combine the teachings of these references to achieve
`this element at least because they disclose touch sensors configured to detect the presence and
`
`LEGAL02/39531529v4
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`15
`
`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
`
`Page 16 of 161
`
`

`

`Asserted Claims
`
`Prior Art Disclosures
`
`location of a touch by a finger or an object, such as a stylus, within an area of an external
`interface of the touch sensor. Further, these references sought to address the same problem. For
`example, Hsu provides that a “primary object of this invention is a positioning system that uses
`a low-cost, highly integrated, low power, capacitive transparent sensor.” Hsu, Abstract.
`Similarly, Mulligan provides “a lattice touch-sensing system for detecting a position of a touch
`on a touch-sensitive surface. The lattice touch-sensing system may include two capacitive
`sensing layers, separated by an insulating material, where each layer consists of substantially
`parallel conducting elements, and the conducting elements of the two sensing layers are
`substantially orthogonal to each other.” Mulligan, Abstract.
`
`Moreover, both references disclose a substrate, an adhesive layer, and a cover sheet. Hsu, 4:55-
`56, 8:2-6, Figs. 2, 7; Mulligan, 3:60-4: 27, Fig. 2. Thus, a POSITA would have been motivated
`to combine the teachings of these references at least because they sought to address the same
`problem with similar features and/or functionalities.
`
`A POSITA seeking to apply the teachings of these references would have been motivated to
`practice this limitation for the reasons set forth in these references and as a matter of common
`sense. Additional motivation arises from a desire to overcome known problems and implement
`a touch sensor using known techniques. Additional motivation to do so arises from combining
`prior art elements according to known methods to yield predictable results to improve a similar
`device. Doing so would have been within the abilities of a POSITA, would not have required
`undue effort, and would have led to expected results. Practicing this limitation amounts to
`merely choosing from a finite number of identified, predictable solutions, with a reasonable
`expectation of success. For example, combining prior art elements according to known
`methods would have yielded a predictable result with a reasonable expectation of success.
`
`Exemplary Combination with Hotelling760
`
`For example, Hotelling760 discloses:
`
`Hotelling760 at 4:48-5:39:
`
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
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`Page 17 of 161
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`Asserted Claims
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`Prior Art Disclosures
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`Referring to FIG. 6, location and force touch pad 600 in accordance with another
`embodiment of the invention is shown in cross section. In this embodiment, cosmetic
`layer 605 comprises a polyester or polycarbonate film. Layer 610 comprises an acrylic-
`based pressure sensitive or ultraviolet light cured adhesive. Layer 615 functions as a
`two-sided circuit board that has a first plurality of conductive drive traces 620 oriented
`in a first direction on a “top” surface (i.e., toward cosmetic layer 605) and a plurality of
`conductive sense traces 625 oriented in a second direction on a “bottom” surface. In
`one embodiment, circuit substrate layer 615 comprises a low temperature plastic or
`thermoplastic resin such as polyethylene terephthalate (“PET”. In this embodiment,
`drive traces 620 and sense traces 625 may comprise printed silver ink. In another
`embodiment, circuit substrate layer 615 comprises a flexible circuit board, or fiberglass
`or glass and drive and sense traces (620 and 625) comprise Indium tin oxide (“ITO”) or
`copper. Layer 630, in one embodiment, comprises a layered combination consisting of
`adhesive-PET-adhesive, where the adhesive components are as described above with
`respect to layer 610. Layers 635, 640 and 645 comprise PET of varying thicknesses. As
`shown, the “bottom” surface of layer 640 has affixed thereon a second plurality of
`conductive drive traces 650 oriented in substantially the same orientation as first
`conductive drive traces 620. Raised and spatially offset support structures 655 and layer
`660 also comprise a layered combination consisting of adhesive-PET-adhesive (similar
`to layer 630, see above). Layers 605-660 are affixed to and supported by base or
`stiffener plate 665. For example, in a portable or notebook computer system, base 665
`could be formed from a rigid material such as a metal stamping that is part of the
`computer system's frame. Similarly, base 665 could be the internal framing within a
`personal digital assist and or mobile telephone. Table 1 identifies the thickness for each
`of layers 600-660 for one embodiment of touch pad 600.
`
`Hotelling760 at Table 1:
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`17
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00459
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`Page 18 of 161
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`Asserted Claims
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`Prior Art Disclosures
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`Hotelling760 at Figure 6:
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`
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`Exhibit 2003
`IPR2020-00459
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`Page 19 of 161
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`Asserted Claims
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`Prior Art Disclosures
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`
`A POSITA would have been motivated to combine the teachings of these references to achieve
`this element at least because they disclose touch sensors configured to detect the presence and
`location of a touch by a finger or an object, such as a stylus, within an area of an external
`interface of the touch sensor. Further, these references sought to address the same problem. For
`example, Hsu provides that a “primary object of this invention is a positioning system that uses
`a low-cost, highly integrated, low power, capacitive transparent sensor.” Hsu, Abstract.
`Similarly, Hotelling760 provides that “[i]n capacitive touch pads, a first set of conductive
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`Exhibit 2003
`IPR2020-00459
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`Page 20 of 161
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`Asserted Claims
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`Prior Art Disclosures
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`traces run in a first direction and are insulated by a dielectric insulator from a second set of
`conductive traces running in a second direction (generally orthogonal to the first direction).
`The grid formed by the overlapping conductive traces create an array of capacitors that can
`store electrical charge. When an object is brought into proximity or contact with the touch pad,
`the capacitance of the capacitors at that location change. This change can be used to identify
`the location of the touch event.” Hotelling760, 1:35-44.
`
`Moreover, both references disclose a substrate, an adhesive layer, and a cover sheet. Hsu, 4:55-
`56, 8:2-6, Figs. 2, 7; Hotelling760, 4:48-5:39, Table 1, Fig. 6. Thus, a POSITA would have
`been motivated to combine the teachings of these references at least because they sought to
`address the same problem with similar features and/or functionalities.
`
`A POSITA seeking to apply the teachings of these references would have been motivated to
`practice this limitation for the reasons set forth in these references and as a matter of common
`sense. Additional motivation arises from a desire to overcome kno