IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`SOLAS OLED LTD., an Irish corporation,
`
`CASE NO. 6:19-CV-00236-ADA
`
`Plaintiff,
`
`JURY TRIAL DEMANDED
`
`v.
`
`LG DISPLAY CO., LTD., a Korean
`corporation; LG ELECTRONICS, INC., a
`Korean corporation; and SONY
`CORPORATION, a Japanese corporation,
`
`Defendants.
`
`DEFENDANTS LG DISPLAY CO., LTD., LG ELECTRONICS, INC.
`AND SONY CORPORATION’S FINAL JOINT INVALIDITY CONTENTIONS
`
`Defendants LG Display Co., Ltd., LG Electronics, Inc., and Sony Corporation
`
`(collectively, “Defendants”) hereby disclose their Final Joint Invalidity Contentions. Defendants
`
`contend that each of the claims asserted by Plaintiff Solas OLED Ltd. (“Solas” or “Plaintiff”) is
`
`invalid under at least 35 U.S.C. §§102, 103, and/or 112.
`
`I.
`
`GENERAL STATEMENT AND RESERVATION OF RIGHTS
`
`A.
`
`Asserted Claims
`
`On November 26, 2019, Solas served Defendants with Infringement Contentions, alleging
`
`infringement of U.S. Patent Nos. 7,432,891 (the “’891 patent”), 7,573,068 (the “’068 patent”), and
`
`7,907,137 (the “’137 patent”) (collectively, the “Asserted Patents”). Solas alleges Defendants
`
`infringe the following claims of the Asserted Patents (collectively, the “Asserted Claims”):
`
` Claims 1 and 3 of the ’891 patent;
`
` Claims 1, 5, 10, 12, 13, and 17 of the ’068 patent;
`
` Claims 10, 11, 15, 36, 37, and 39 of the ’137 patent.
`
`DEFENDANTS’ JOINT INVALIDITY CONTENTIONS – Page 1
`
`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 1
`
`

`

`
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`On March 20, 2020, Solas served Defendants with its First Amended Infringement
`
`Contentions. In its First Amended Infringement Contentions, Solas alleged additional
`
`infringement theories under the doctrine of equivalents for the ’891 patent and the ’068 patent.
`
`Additionally, Solas alleged additional literal infringement grounds for the ’068 patent. Unless
`
`otherwise noted, Defendants will hereinafter refer to Solas’ November 26, 2019 Infringement
`
`Contentions and March 20, 2020 First Amended Infringement Contentions collectively as “Solas’
`
`Infringement Contentions.”
`
`Pursuant to the Order Governing Proceedings-Patent Case, entered November 8, 2019
`
`(Dkt. 50) (“Order Governing Proceedings”), Defendants do not provide any contentions regarding
`
`any claims not asserted in Solas’ Infringement Contentions. To the extent that the Court permits
`
`Solas to assert additional claims against Defendants, each Defendant reserves the right to disclose
`
`new, amended, or supplemental invalidity contentions.
`
`Defendants provide these disclosures consistent with the schedule currently in place, and
`
`do so without waiving any right to receive from Solas such full and complete specific infringement
`
`disclosures as should have been provided from the outset. Solas’ Infringement Contentions are
`
`deficient in multiple respects and do not provide Defendants with sufficient information to
`
`understand the specific accused features and components and the alleged factual and evidentiary
`
`bases for Solas’ allegations. Among other things, Solas’ Infringement Contentions lack
`
`specificity, fail to properly identify accused instrumentalities and disclose Solas’ contentions for
`
`each such accused instrumentality, and do not adequately explain Solas’ infringement theory for
`
`numerous claim elements. Solas has thus substantially prejudiced Defendants’ ability to
`
`understand, for purposes of preparing these Final Invalidity Contentions, what Solas alleges to be
`
`the scope of the Asserted Claims. To the extent Solas modifies or amends any assertion or
`
`contention in Solas’ Infringement Contentions, or presents any new assertion or contention
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 2
`
`
`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 2
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`

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`relevant to Defendants’ Final Invalidity Contentions, Defendants may modify, amend, and/or
`
`supplement their Final Invalidity Contentions. Defendants’ compliance with the current schedule
`
`should not be viewed as a waiver of any right to seek relief regarding the deficiencies in Solas’
`
`Infringement Contentions, which Defendants expressly reserve.
`
`B.
`
`Claim Construction
`
`The Court held the Markman hearing on May 22, 2020 and issued the Claim Construction
`
`Order on June 9, 2020. Dkt. 82 (“Claim Construction Order”). The Court construed the claim
`
`terms disputed by the parties as follows:
`
`Term
`
`Final Constructions
`
`“a gradation current having a current
`value”
`
`a current, which conveys
`information about a level
`
`Relevant
`Claims
`
`Claims 10 and
`36 of ’137
`patent
`Claims 10, 15,
`36, 37, and 39
`of ’137 patent
`Claims 15 and
`39 of the ’137
`patent
`
`Claims 10 and
`36 of ’137
`patent
`
`“gradation signal”
`
`“generates, as the gradation signal, a
`nonlight emitting display voltage having a
`predetermined voltage value”
`
`
`“a non-light emitting display voltage
`having a predetermined voltage value for
`allowing the optical element to perform a
`non-light emitting operation is generated
`as the gradation signal”
`“through a data line”
`
`
`“through the data line”
`
`signal conveying information
`about a level
`
`Not indefinite.
`
`Plain and ordinary meaning1
`
`1 [Footnote is not for the jury]
`The threshold voltage is
`detected through and the
`compensation voltage is applied
`through the same data line that
`the gradation current is supplied
`through.
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`Claim 10 of
`’137 patent
`Claim 36 of
`’137 patent
`
`“before”
`
`“after”
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 3
`
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 3
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`

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`
`
`Term
`
`Final Constructions
`
`Relevant
`Claims
`Claims 1 and 3
`of ’891 patent
`
`“a third thin film transistor which during
`driving its gate through a driving
`conductor taps a diode driving current at
`an output of said first current-driving
`transistor and supplies a current
`measuring-[measuring] and voltage
`regulating circuit, said current measuring-
`and voltage regulating circuit providing to
`the data conductor a voltage signal which
`is dependent on a current measuring result
`and a voltage comparison”
`
`Plain and ordinary meaning.
`
`
`The claimed “providing” by the
`current measuring- and voltage
`regulating circuit (“said current
`measuring- and voltage
`regulating circuit providing to
`the data conductor a voltage
`signal which is dependent on a
`current measuring result and a
`voltage comparison”) is not
`required to occur during driving
`of the third thin film transistor’s
`gate.
`Plain and ordinary meaning
`
`wherein all above mentioned
`elements of the driving circuit
`are electrically connected to and
`physically located on the same
`side of the layers of said light
`emitting diode
`formed on said plurality of
`supply lines over the length or
`direction of said plurality of
`supply lines
`
`connected to said plurality of
`supply lines over the length or
`direction of said plurality of
`supply lines
`Note: The Court believes that it
`is unnecessary to separately
`construe part of a claim term
`and/or prior to construing the
`entire claim term. Therefore,
`the Court’s preliminary
`construction for this term is
`contained within the Court’s
`preliminary construction for
`“patterned together.”
`patterned to fit together, wherein
`patterned may consist of one or
`more fabrication steps
`Plain and ordinary meaning
`wherein the plain and ordinary
`
`Claims 1 and 3
`of ’891 patent
`Claim 3 of ’891
`patent
`
`“current measuring”
`
`“wherein all above mentioned elements of
`the driving circuit are located at a same
`side of said light emitting diode”
`
`Claim 1 of ’068
`patent
`
`“formed on said plurality of supply lines
`along said plurality of supply lines”
`
`Claim 13 of
`’068 patent
`
`“connected to said plurality of supply lines
`along said plurality of supply lines”
`
`Claims 1 and 13
`of ’068 patent
`
`“patterned”
`
`Claims 1 and 13
`of ’068 patent
`
`“patterned together”
`
`Claims 1 and 13
`of ’068 patent
`
`“signal lines”
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 4
`
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 4
`
`

`

`
`
`Relevant
`Claims
`
`Term
`
`“feed interconnections”
`
`Claims 1, 10,
`12, 13, and 17
`of ’068 patent
`
`Dkt. 82.
`
`Final Constructions
`
`meaning is conductive lines
`supplying signals
`conductive structures in a
`different layer or layers than the
`supply line that also provide
`connections to a source that
`supplies voltage and/or current
`
`The parties also agreed to the following constructions:
`
`Relevant
`Claims
`
`Claims 10 and
`36 of ’137
`patent
`Claims 1, 13 of
`the ’068 patent
`
`
`Term
`
`Final Constructions
`
`“luminance gradation”
`
`light emitting level
`
`“supply lines”
`
`conductive lines supplying
`current or voltage
`
`Defendants provide these Final Invalidity Contentions in light of the aforementioned Claim
`
`Construction Order and applying the Court’s constructions, and their present understanding of
`
`Solas’ Infringement Contentions.. In some instances, Solas’ Infringement Contentions contradict
`
`the teachings of the Asserted Patents, contradict the understanding of the claim terms by a person
`
`of ordinary skill in the art, are internally inconsistent, and are vague and conclusory concerning
`
`how the claim limitations supposedly read on the accused products or activities. As a result,
`
`Defendants are currently unable to fully discern Solas’ position regarding the construction of these
`
`claim limitations. Defendants reserve all rights to modify, amend, and/or supplement these Final
`
`Invalidity Contentions, including, without limitation, in response to any alleged supporting
`
`evidence offered by Solas, any position taken by Solas concerning claim construction that is
`
`inconsistent with the Court’s aforementioned constructions and/or for claim terms other than the
`
`aforementioned construed terms, any position taken by Solas concerning infringement or validity
`
`issues, or pursuant to the Order Governing Proceedings.
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 5
`
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 5
`
`

`

`
`
`While Defendants provide these Final Invalidity Contentions in light of the Claim
`
`Construction Order, Defendants’ Final Invalidity Contentions do not represent their agreement or
`
`view as to the meaning of any claim term contained in that order, and Defendants preserve and do
`
`not waive their objections to any construction differing from Defendants’ proposed constructions.
`
`To the extent Defendants assert that prior art is anticipatory or renders obvious claims based on
`
`any apparent or implicit construction of the Asserted Claims by Solas, Defendants’ Final Invalidity
`
`Contentions are not—and should not be interpreted as—adoptions or admissions as to the accuracy
`
`of that claim scope or construction. Thus, Defendants’ contentions herein are not, and should in
`
`no way be seen as, admissions or adoptions as to any particular claim scope or construction
`
`advocated by Solas, any priority date, any admission that any claims have been properly asserted
`
`in this case, or as any admission that any aspect of any accused products or systems meets any
`
`particular claim element in any particular way. Defendants object to any attempt to imply claim
`
`construction from the attached charts. These Final Invalidity Contentions are made under a variety
`
`of alternatives and do not represent Defendants’ agreement or view as to the meaning, definiteness,
`
`written description support for, or enablement of any claim contained therein.
`
`While Defendants provide these Final Invalidity Contentions in light of the Claim
`
`Construction Order, Defendants do not take an affirmative position on any matter of claim
`
`construction in these Final Invalidity Contentions. Defendants may propose any claim
`
`construction they consider appropriate and contest any claim construction they consider
`
`inappropriate. Defendants also may argue that certain claim terms, phrases, and elements are
`
`indefinite, lack written description, are not enabled, are not patentable, are not novel and/or are
`
`otherwise invalid under 35 U.S.C. § 101 or § 112.
`
`C.
`
`Doctrine of Equivalents
`
`Solas has provided deficient contentions regarding its allegations of infringement under the
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 6
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 6
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`

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`
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`doctrine of equivalents for the ’891 patent and ’068 patent. See Solas’ March 20, 2020 First
`
`Amended Infringement Contentions, First Amended Exhibit A and First Amended Exhibit B.
`
`Specifically, among other things, Solas’ doctrine of equivalents arguments set out in its First
`
`Amended Infringement Contentions lack specificity and do not adequately explain Solas’
`
`infringement theories beyond parroting the legal standard for doctrine of equivalents.
`
`Additionally, Solas has also not provided any contention that any claim limitation of the ’137 is
`
`allegedly infringed under the doctrine of equivalents. Should Solas receive leave to amend to
`
`add to its contentions any specific allegations of infringement under the doctrine of equivalents,
`
`Defendants may amend and supplement these Final Invalidity Contentions as appropriate.
`
`D.
`
`Ongoing Discovery and Disclosures
`
`Discovery and Defendants’ investigation, including Defendants’ search for prior art, are
`
`ongoing. In particular, discovery has only recently begun and Defendants are still investigating
`
`sources of prior art in the possession of third parties. Defendants plan to issue appropriate
`
`subpoenas to third parties requesting information relating to prior art and the invalidity of the
`
`Asserted Claims. Also, Solas has not yet provided all documentation regarding prior art,
`
`conception, or reduction to practice of the alleged inventions in its possession, custody, or control.
`
`Accordingly, Defendants may supplement, amend, and/or alter the positions taken and
`
`information disclosed in these Invalidity Contentions after review of the documents produced in
`
`response to the applicable disclosures, or requests for production. To the extent Solas’ document
`
`production is incomplete with respect to documents relating to the invalidity of the Asserted
`
`Claims, Defendants may supplement, amend, or alter the positions taken and information disclosed
`
`in these Final Invalidity Contentions, if and when Solas or a third party produces additional
`
`relevant documents.
`
`Defendants may supplement, amend, and/or alter the positions taken and information
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 7
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 7
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`

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`disclosed in these Final Invalidity Contentions including, without limitation, the prior art and
`
`grounds of invalidity set forth herein, to take into account information or defenses that may come
`
`to light as a result of Defendants’ discovery efforts. Defendants may supplement, amend, and/or
`
`alter the positions taken and information disclosed in these Final Invalidity Contentions, pursuant
`
`to the Order Governing Proceedings. Defendants hereby incorporate by reference the relevant
`
`testimony of any fact witnesses who are deposed, provide declarations, or otherwise testify in this
`
`lawsuit. Defendants also hereby incorporate by reference the reports and testimony of any expert
`
`witnesses who opine on Defendants’ behalf regarding the Asserted Patents.
`
`E.
`
`Additional Reservations of Rights
`
`The accompanying invalidity claim charts (Appendices A-C) identify specific instances
`
`where prior art references disclose, either expressly, implicitly in the larger context of the passage,
`
`or inherently, each limitation of the Asserted Claims and/or examples of disclosures in view of
`
`which a person of ordinary skill in the art would have considered each limitation obvious.
`
`Citations included in these charts for independent claims necessarily also apply to their associated
`
`dependent claims. Defendants have endeavored to identify the most relevant portions of the
`
`references, but the references may contain additional support for particular claim limitations.
`
`Defendants may rely on uncited portions of the prior art references, other documents, and/or
`
`operational systems, as well as fact and expert testimony, to provide context or to aid in
`
`understanding the cited portions of the references. Defendants may also rely on any prior art
`
`system referenced, embodied, or described in any of the prior art references identified herein, or
`
`which embodies any of the prior art references identified herein. Moreover, Defendants may
`
`further rely on inventor admissions concerning the scope of the prior art relevant to the Asserted
`
`Patents found in, inter alia, the prosecution histories of the Asserted Patents and related patents
`
`and/or patent applications, any testimony or declarations of the named inventors concerning the
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 8
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 8
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`

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`Asserted Patents or related patents, and any papers or evidence submitted by Plaintiff in connection
`
`with this litigation, any other pending or future litigation brought by Plaintiff involving the
`
`Asserted Patents or related patents, or inter partes review or other proceedings involving the
`
`Asserted Patents or related patents. Defendants also may establish what was known to a person
`
`having ordinary skill in the art through other publications, products, and/or testimony.
`
`Where Defendants cite to a particular figure in a reference, the citation should be
`
`understood to encompass the caption of the figure and other text relating to and/or describing the
`
`figure. Similarly, where Defendants cite to particular text referring to a figure, the citation should
`
`be understood to include the figure and related figures as well.
`
`Moreover, Defendants may rely on uncited portions of the identified prior art, other art, or
`
`expert testimony to provide context to or aid in understanding the cited portions of the identified
`
`prior art. Defendants also may rely upon treatises, published industry standards, and similar
`
`documents to demonstrate the knowledge of one of ordinary skill in the relevant art.
`
`Defendants may rely on any invalidity challenge, including contentions previously served
`
`or subsequently served in any related litigations, including but not limited to Solas OLED Ltd. v.
`
`Apple Inc., Civil Action No. 6:19-cv-00537-ADA, pending in the United States District Court for
`
`the Western District of Texas; Solas OLED Ltd. v. Google Inc., 6:19-cv-00515-ADA, pending in
`
`the United States District Court for the Western District of Texas; Solas OLED Ltd. v. Dell Inc.,
`
`6:19-cv-00514-ADA, pending in the United States District Court for the Western District of Texas;
`
`Solas OLED Ltd. v. LG Display Co., Ltd., Civil Action No. 6:19-cv-00236-ADA, pending in the
`
`United States District Court for the Western District of Texas; Solas OLED Ltd. v. Samsung
`
`Display Co., Ltd. et al., Civil Action No. 2:19-cv-00152-JRG, pending in the United States District
`
`Court for the Eastern District of Texas; and Solas OLED Ltd. v. HP, Inc., Civil Action No. 6:19-
`
`cv-00631-ADA, pending in the United States District Court for the Western District of Texas, in
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 9
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 9
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`Inter Partes Review No. 2020-00177, in Inter Partes Review No. 2020-01238, in Inter Partes
`
`Review No. 2020-01055, and all other challenges to the Asserted Claims or foreign equivalents.
`
`All invalidity challenges are hereby incorporated by reference herein.
`
`Defendants’ identification in the prior art of claim elements recited in the preamble of any
`
`claims is not intended to indicate that any such preamble is limiting. All such disclosures are made
`
`only to the extent the preamble is determined to be limiting.
`
`As described above, Defendants also intend to seek discovery from third parties to
`
`demonstrate earlier invention of the claimed inventions under 35 U.S.C. § 102(g). Defendants
`
`further intend to take discovery on the issues of improper inventorship and/or derivation under 35
`
`U.S.C. § 102(f), public use and/or the on-sale bar under 35 U.S.C. § 102(b), and/or failure to
`
`comply with 35 U.S.C. § 112. Defendants may therefore modify, amend, and/or supplement these
`
`Final Invalidity Contentions if and when further information becomes available.
`
`Subject to the foregoing statements and qualifications, Defendants provide the following:
`
`II.
`
`INVALIDITY CONTENTIONS
`
`A.
`
`U.S. Patent No. 7,432,891 (’891 patent)
`
`1. Alleged Priority Date
`
`Solas alleges that the priority date of the ’891 patent is “no later than November 22, 2002,
`
`the filing date of patent application DE 102 54 511.1 in the German Patent and Trade Mark Office.”
`
`See Solas’ March 20, 2020 First Amended Infringement Contentions at 7; see also Solas’ Resp.
`
`and Objs. to Defendants’ 1st Set of Interrogatories at Interrogatory No. 2, p. 6-7. The ’891 patent
`
`is not entitled to any date of invention earlier than this date. Defendants object to Solas alleging
`
`or providing evidence of any earlier date of invention. To the extent Solas is able and permitted
`
`to assert an earlier date of invention for the ’891 Patent, Defendants reserve all rights to modify,
`
`amend, and/or supplement these Final Invalidity Contentions, including, but not limited to the
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 10
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 10
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`identification and production of additional prior art.
`
`2. General State of the Art at the Time of the Alleged Invention
`
`The prior art admitted in the ’891 patent (including the “References Cited” on the face of
`
`the ’891 patent) may provide background and context pertinent to the teachings, and interpretation
`
`of, the prior art referenced by the claim charts in Appendix A and described below. For example,
`
`the ’891 patent admits that “various compensation features for the drive current fluctuations of”
`
`an OLED had already been proposed in the art, and that drive circuits for OLED displays having
`
`compensation features “typically” used thin film transistors. ’891 patent at 1:22-31. The ’891
`
`patent also admits that driving circuits using thin film transistors “for supplying the LED current
`
`back to an external current-voltage conversion circuit and therefore allowing a feedback of the
`
`actual flowing current” were well known. Id. at 1:22-53. These are binding admissions by the
`
`patentee of what was known in the prior art. See Constant v. Advanced Micro-Devices Inc., 848
`
`F.2d 1560, 1570 (Fed. Cir. 1988).
`
`In addition, as the ’891 patent and the prior art references identified herein demonstrate,
`
`the asserted claims of the ’891 patent merely disclose concepts that were well-known in the state
`
`of the art as of the priority date of the ’891 patent. First, the patent admits that display screens
`
`using OLEDs were well known in the art. ’891 patent at 1:14-17. Second, the ’891 patent
`
`addresses a well-known problem with active matrix drive circuits: “manufacturing-dependent
`
`fluctuations of the parameters of the thin film transistors” affect the amount of current provided to
`
`each OLED. ’891 patent at 1:14-21, 1:22-36 (prior-art solutions for “driver current fluctuations”);
`
`Bu (Ex. 1003), [8]-[9]. Third, the general features of an OLED and its nonlinear switching
`
`characteristics were well known, including that it could “serve[] both the display and switching
`
`function[]” in a driving circuit. Tang, 3:3-8.
`
`The prior art references that anticipate and/or render obvious one or more Asserted Claims
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 11
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 11
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`of the ’891 patent are identified in the claim charts of Exhibits A1-A5 (collectively, “Appendix
`
`A”) and in the sections below. These prior art references generally relate to OLEDs, their drive
`
`circuits, and other circuitry commonly found in OLED drive circuits. This prior art is exemplary
`
`only, and is not in any way intended to limit the scope of what one of ordinary skill in the art would
`
`have understood at the time of the alleged invention. Defendants may rely upon additional prior
`
`art, information, expert opinion, and/or knowledge to demonstrate what one of ordinary skill would
`
`have understood prior to the date of alleged invention of the Asserted Claims of the ’891 patent.
`
`3. Disclosure of Prior Art References
`
`(a) Prior Art Patents, Patent Applications, and Publications
`
`Patent or Patent Application No. Country of Origin
`
`Date of Issue (if Issued Patent)
`
`/ Date of Publication (if Patent
`
`Application Publication)
`
`Korean
`
`Patent
`
`Application
`
`Korea
`
`April 15, 2002
`
`Publication No. 2002-0027957
`
`(Kim)
`
`United States Patent No. 6,809,706
`
`Japan
`
`October 26, 2004
`
`(Shimoda)
`
`United States Patent No. 6,433,488
`
`United States
`
`August 13, 2002
`
`(Bu)
`
`U.S.
`
`Patent
`
`Application
`
`United States
`
`August 1, 2002
`
`Publication No. 2002/0101395
`
`(Inukai)
`
`United States Patent No. 5,550,066
`
`United States
`
`August 27, 1996
`
`(Tang)
`
`U.S.
`
`Patent
`
`Application
`
`United States
`
`May 20, 2004
`
`Publication No.
`
` 2004/0095297
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 12
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`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 12
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`Patent or Patent Application No. Country of Origin
`
`Date of Issue (if Issued Patent)
`
`/ Date of Publication (if Patent
`
`Application Publication)
`
`(Libsch)
`
`U.S. Patent No. 6,535,185 (Kim-
`
`United States
`
`March 18, 2003
`
`185)
`
`U.S.
`
`Patent No.
`
`6,809,706
`
`United States
`
`October 26, 2004
`
`(Shimoda)
`
`UK Patent Application No.
`
`United Kingdom
`
`December 24, 2003
`
`2002013989 (Routley)
`
`US Patent No. 6,361,886 (Shi)
`
`United States
`
`March 26, 2002
`
`U.S.
`
`Patent No.
`
`6,777,724
`
`United States
`
`August 17, 2004
`
`(Duggal)
`
`U.S. Patent No. 5,970,318 (Choi) United States
`
`October 19, 1999
`
`U.S. Patent No. 6,836,075 (Park-
`
`United States
`
`December 28, 2004
`
`075)
`
`U.S. Patent No. 6,771,328 (Park-
`
`United States
`
`August 3, 2004
`
`328)
`
`U.S.
`
`Patent No.
`
`6,611,174
`
`United States
`
`August 26, 2003
`
`(Sherman)
`
`U.S. Patent No. 6,429,841 (Lee)
`
`United States
`
`August 6, 2002
`
`U.S.
`
`Patent
`
`Application
`
`United States
`
`August 1, 2002
`
`Publication No. 2002/0101395
`
`(Inukai)
`
`U.S.
`
`Patent
`
`Application
`
`United States
`
`April 17, 2003
`
`Publication No. 2003/0071821
`
`(Sundahl)
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 13
`
`
`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 13
`
`

`

`
`
`Patent or Patent Application No. Country of Origin
`
`Date of Issue (if Issued Patent)
`
`/ Date of Publication (if Patent
`
`Application Publication)
`
`European Patent Application No.
`
`Europe
`
`May 31, 2000
`
`EP 1,005,013 (Dodabalapur)
`
`U.S. Patent No. 6,873,309 (Suzuki) United States
`
`March 29, 2005
`
`U.S. Patent No. 6,229,508 (Kane) United States
`
`May 8, 2001
`
`U.S. Patent No. 7,154,454 (Okabe) United States
`
`December 26, 2006
`
`U.S. Patent Publication No.
`
`United States
`
`June 5, 2003
`
`20030103022 (Noguchi)
`
`
`
`U.S. Patent No. 6,583,775 (Sekiya) United States
`
`June 24, 2003
`
`U.S. Patent No. 5,552,678 (Tang-
`
`United States
`
`September 3, 1996
`
`678)
`
`U.S. Patent No. 2001/0043173
`
`United States
`
`November 22, 2001
`
`(Troutman)
`
`U.S.
`
`Patent No.
`
`7,714,813
`
`United States
`
`May 11, 2010
`
`(Uchino)
`
`JPH 10254410A (Imai)
`
`Japan
`
`September 25, 1998
`
`U.S. Patent No. 6,917,350 (Pae)
`
`United States
`
`July 12, 2005
`
`U.S.
`
`Patent No.
`
`5,900,779
`
`United States
`
`May 4, 1999
`
`(Giacomini)
`
`JPS 63-250873 (Komei)
`
`Japan
`
`October 18, 1988
`
`U.S.
`
`Patent No.
`
`7,129,918
`
`United States
`
`October 31, 2006
`
`(Kimura-918)
`
`U.S.
`
`Patent No.
`
`6,706,544
`
`United States
`
`March 16, 2004
`
`(Yamazaki-544)
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 14
`
`
`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 14
`
`

`

`
`
`Patent or Patent Application No. Country of Origin
`
`Date of Issue (if Issued Patent)
`
`/ Date of Publication (if Patent
`
`Application Publication)
`
`U.S. Patent No. 6,738,031 (Young-
`
`United States
`
`May 18, 2004
`
`031)
`
`U.S. Patent No. 6,791,129 (Inukai-
`
`United States
`
`September 14, 2004
`
`129)
`
`U.S.
`
`Patent No.
`
`6,475,845
`
`United States
`
`Nov. 5, 2002
`
`(Kimura-845)
`
`
`
`Title
`
`Date of Publication
`
`Author/Publisher
`
`Microelectronics – Digital and
`
`1979
`
`Jacob Millman
`
`Analog Circuits and Systems
`
`(“Millman”)
`
`Silicone Compatible Organic
`
`1994
`
`Helen H. Kim, et. al.
`
`Light Emitting Diode, 12 J. of
`
`Lightwave Tech. (“Helen Kim
`
`et al.”)
`
`Principles of VLSI Design
`
`1998
`
`Neil H.E. Weste & Kamran
`
`(“Weste”)
`
`Implementation
`
`and
`
`1989
`
`Applications
`
`of Current
`
`Sources
`
`and
`
`Current
`
`Receivers (“Burr-Brown”)
`
`Eshraghian
`
`Burr-Brown
`
`Transimpedance
`
`amplifier
`
`1995
`
`Phillips Semiconductors
`
`280MhZ (“NE5210)
`
`40.1: Invited Paper: Active 2000
`
`G. Rajeswaran, et. al.
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 15
`
`
`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 15
`
`

`

`
`
`Title
`
`Date of Publication
`
`Author/Publisher
`
`Matrix Low Temperature
`
`Poly-Si TFT/OLED
`
`Full
`
`Color Displays: Development
`
`Status (“Rajeswaran”)
`
`Organic EL Displays (Session
`
`2000
`
`The
`
`Institute
`
`of
`
`Image
`
`36, 40, 46, 51, Poster) (“IIITE
`
`Information and Television
`
`Article”)
`
`
`
`(b)
`
`Prior Art Systems
`
`Engineers
`
`Numerous systems are prior art to the ’891 patent under at least 35 U.S.C. §§ 102(a), (b)
`
`and/or (g), and anticipate and/or render obvious the Asserted Claims of the ’891 patent. These
`
`systems also include physical implementations of prior art patents, patent applications, and
`
`publications identified herein that were known, made, used, sold, offered for sale, or imported into
`
`this country prior to the effective filing dates of the ’891 patent, including those identified above
`
`and discussed in the sections below.
`
`In addition, Defendants may rely on systems or other embodiments of the subject matter
`
`described in each of the references described above. Each of the references cited in support of the
`
`above systems may also be prior art individually under 35 U.S.C. §§ 102(a), (b), (e), and/or (g).
`
`As discovery is ongoing, Defendants continue to investigate these items and may amend or
`
`supplement these contentions to include additional information or documents regarding such
`
`products and/or systems.
`
`4. Anticipation and Obviousness
`
`Reference to a particular circuitry, software program, device or product in the claim charts
`
`of Appendix A and in Section II.A.4.(c) should be interpreted as a reference to the product itself
`
`and any corresponding patents, publications, or product literature cited in Appendix A and Section
`
`DEFENDANTS’ FINAL JOINT INVALIDITY CONTENTIONS – Page 16
`
`
`LG DISPLAY CO., LTD. V. SOLAS OLED, LTD.
`IPR2020-01055
`Exhibit 2005
`Page 16
`
`

`

`
`
`II.A.4.(c) that relates to the cited circuitry, software program, device, or product. In addition,
`
`Defendants may rely on other documents or things that have not yet been located to support their
`
`contentions regarding such prior art circuit(s), software program(s), device(s) or product(s) that
`
`are referenced in the charts.
`
`Defendants incorporate by reference, as if set forth fully herein, all prior art cited during
`
`the prosecution of the ’891 patent. In addition, Defendants identify and hereby incorporate by
`
`reference as if set forth fully herein the prior art references that anticipate or render obvious an
`
`asserted claim as described in IPR2020-00177 and any future reexaminations or additional inter
`
`partes reviews of the ’891 patent, if any, that a requestor may file or the PTO may grant.
`
`Defendants further identify and hereby incorporate by reference as if set forth fully herein
`
`the prior art references and invalidity contentions as described in any other lawsuits wherein
`
`invalidity contentions have been, or will be, provided regarding the ’891 patent, its foreign
`
`cou