IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`LARGAN PRECISION CO., LTD.,
`
`Plaintiff,
`
`v.
`
` ABILITY OPTO-ELECTRONICS
` TECHNOLOGY CO., LTD., ET AL.,
`
`Defendants.
`
`Case No. 4:19-cv-00696-ALM
`
`EXPERT DECLARATION OF DR. RONGGUANG LIANG
`REGARDING CLAIM CONSTRUCTION
`
`EX 2009 Page 1
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`

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`I.
`II.
`III.
`IV.
`
`V.
`
`TABLE OF CONTENTS
`QUALIFICATIONS AND EXPERIENCE ........................................................................ 1
`MY ASSIGNMENT ........................................................................................................... 4
`SUMMARY OF MY OPINIONS ....................................................................................... 6
`CLAIM CONSTRUCTION FRAMEWORK ..................................................................... 7
`A.
`Level of Ordinary Skill in the Art ........................................................................... 7
`B.
`Plain and Ordinary Meaning ................................................................................. 11
`C.
`Definiteness........................................................................................................... 11
`TECHNOLOGY BACKGROUND .................................................................................. 12
`A.
`Light, Images, and Lenses .................................................................................... 15
`B.
`Multiple Lens Systems .......................................................................................... 20
`C.
`Lens Design .......................................................................................................... 24
`THE ASSERTED PATENTS ........................................................................................... 28
`VI.
`“ASPHERIC” .................................................................................................................... 29
`VII.
`VIII. “LENS ELEMENT” ......................................................................................................... 34
`“HALF OF THE DIAGONAL LENGTH OF THE EFFECTIVE PIXEL AREA OF THE
`IX.
`ELECTRONIC SENSOR IS IMGH” ............................................................................... 38
`ADDITIONAL AMENDED OR SUPPLEMENTAL OPINIONS .................................. 42
`
`
`X.
`
`
`
`
`
`i
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`EX 2009 Page 2
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`I, Rongguang Liang, Ph.D., hereby declare as follows:
`I have been retained by counsel for Largan Precision Co., Ltd. to prepare this declara-
`1.
`tion addressing the proper constructions of certain claim terms in U.S. Patent Nos. 7,274,518 (“the
`’518 Patent”); 8,395,691 (“the ’691 Patent”); 8,988,796 (“the ’796 Patent”); and 9,146,378 (“the
`’378 Patent”) (collectively, the “Asserted Patents”).
`QUALIFICATIONS AND EXPERIENCE
`I.
` Since 2011, I have been a Professor of Optical Sciences at the University of Arizona,
`2.
`where I teach courses directly relating to lens design. For example, I teach graduate courses that
`range from introducing students to the principles, design requirements, and practices of optical
`instruments, to learning practical engineering skills for designing optical systems.
`I am also the Director of the Imaging and Applied Optics Lab at the University’s Col-
`3.
`lege of Optical Sciences, where researchers specialize in optical system design, fabrication, and
`testing. And I am the Director at the University’s Precision Freeform Optics Design, Fabrication,
`and Testing Facility, which contains state of the art instruments for fabrication and testing. These
`same types of instruments are employed by lens manufacturers.
`I earned a Doctorate degree in Optical Sciences in 2001 from the University of Arizona.
`4.
`My Ph.D. dissertation topic was “Measurement of Optical Phase and Polarization in the Media
`and Systems of Optical Data Storage.”
`Before my doctoral studies at the University of Arizona, I earned a Master of Science
`5.
`in Applied Optics in 1998 from the Rose-Hulman Institute of Technology in Terre Haute, Indiana,
`and a Bachelor of Science in Optical Instrumentation in 1989 from Zhejiang University in
`Zhejiang, China.
`After receiving my bachelor’s degree in 1989, I began working for Micro-optic Indus-
`6.
`trial Group (now Motic Inc.) as an Optics Engineer in the company’s Research & Development
`Department, a position I held for seven years. Between 1998 and 2001, after receiving my master’s
`degree, I served as a graduate researcher at the University of Arizona.
`
`
`
`1
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` For over thirty years, throughout my career as an optics engineer, student, and profes-
`7.
`sor, I researched and engineered lenses, lens systems, and other technology in the same fields as
`the technology at issue in the Asserted Patents. Specifically, from 2001 to 2007, I worked as a
`Senior Research Scientist, Principal Research Scientist, and Project Leader for the Eastman Kodak
`Company. Then, from 2007 until I joined the University of Arizona faculty in 2011, I served as
`Senior Principal Research Scientist and Project Leader for Carestream Health Inc., formerly East-
`man Kodak’s health group. In both my Kodak and Carestream roles, I worked daily to engineer
`lenses, invent lens and related optical technologies, and advise and lead research scientists doing
`the same.
`I am the author of the book Optical Design for Biomedical Imaging, SPIE Press (2011).
`8.
`I am also the editor of Biomedical Optical Imaging Technologies: Design and Applications,
`Springer Press (2012), the chapters of which are written by leading experts in optical engineering
`and biomedical imaging. I have also co-authored chapters in two books, Handbook of Optical
`Engineering, Marcel Dekker (2016), and Optical Interferometry, InTech (2017).
`I was elected to the Optical Society of America in 2019 and to SPIE (formerly the
`9.
`Society of Photo-Optical Instrumentation Engineers) in 2010. In 2017, I was a member of a team
`that NASA recognized with its RGH Exceptional Achievement for Engineering Team award, and
`in 2015, I was a member of a team that received NASA’s Group Achievement Award.
`I have published over 100 peer-reviewed technical articles and publications in the field
`10.
`of optical imaging. Some of my publications relate to the subject matter of the Asserted Patents.
`Below is a sample list, with a more comprehensive list included in my curriculum vitae, attached
`as Exhibit A:
`
`• John Tesar, Rongguang Liang, and Masud Mansuripur, “Optical modeling combin-
`ing geometrical ray tracing and physical-optics software,” Opt. Eng. 39, 1845-1849
`(2000);
`• Zhenyue Chen, Xia Wang, and Rongguang Liang, “RGB-NIR multispectral cam-
`era,” Opt. Express 22, 4985-4994 (2014);
`• Zhenyue Chen, Xia Wang, Shaun Pacheco, and Rongguang Liang, “Impact of CCD
`camera SNR on polarimetric accuracy,” Appl. Opt. 53, 7649-7656 (2014);
`
`
`2
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`EX 2009 Page 4
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`• Donglin Ma, Zexin Feng, and Rongguang Liang, “Freeform illumination lens de-
`sign using composite ray mapping,” Appl. Opt. 54, 498-503 (2015);
`• Donglin Ma, Zexin Feng, and Rongguang Liang, “Deconvolution method in de-
`signing freeform lens array for structured light illumination,” Appl. Opt. 54, 1114-
`1117 (2015);
`• Rengmao Wu, Hong Hua, Pablo Benítez, Juan C. Miñano, and Rongguang Liang,
`“Design of compact and ultra efficient aspherical lenses for extended Lambertian
`sources in two-dimensional geometry,” Opt. Express 24, 5078-5086 (2016);
`• Zexin Feng, Brittany D. Froese, Rongguang Liang, Dewen Cheng, and Yongtian
`Wang, “Simplified freeform optics design for complicated laser beam shaping,”
`Appl. Opt. 56, 9308-9314 (2017);
`• Chih-Yu Huang and Rongguang Liang, “Modeling of surface topography on dia-
`mond-turned spherical and freeform surfaces,” Appl. Opt. 56, 4466-4473 (2017);
`• Yujie Luo, Xiao Huang, Jian Bai, and Rongguang Liang, “Compact polarization-
`based dual-view panoramic lens,” Appl. Opt. 56, 6283-6287 (2017);
`• Gannon, Caleb, and Rongguang Liang. “Using spherical harmonics to describe
`large-angle freeform lenses.” Applied optics 57, no. 28 (2018): 8143-8147; and
`• Xisheng Xiao, Qinghua Yu, Guilin Chen, and Rongguang Liang. “Locating optimal
`freeform surfaces for off-axis optical systems.” Optics Communications (2020):
`125757.
`Additionally, I have served in several editorial positions for journals in the optical tech-
`11.
`nology field. This includes serving as an editor of the journals Applied Optics and Optica, a guest
`editor of the journals Biomedical Optics Express and Optical Engineering, and on the editorial
`board of Scientific Reports. I have also served as conference or session chair for numerous confer-
`ences pertaining to optical technology. And I have led or served on a number of committees, in-
`cluding as chair of the OSA Paul F. Forman Engineering Excellence Award committee, on the
`SPIE Scholarship Committee, and as biophotonics co-team leader for the National Technology
`Roadmap for Photonics. My curriculum vitae at Exhibit A contains a complete listing of my ser-
`vice on boards and in organizations whose work relates to the technology at issue in this case.
`I am also a named inventor on 45 U.S. patents, some of which directly relate to the
`12.
`technology at issue in this case, including patents on various cameras and imaging technologies.
`For example, U.S. Patent No. 6,820,982, titled “Method and Apparatus for Forming an Image on
`a Curved Diffusive Surface,” U.S. Patent No. 7,275,826, titled “Fundus Camera Having Curved
`
`
`
`3
`
`
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`Mirror Objective,” and U.S. Patent No. 7,241,011, titled “Fundus Imaging System,” relate to var-
`ious multiple lens systems and devices.
`II. MY ASSIGNMENT
`I have been retained as an expert on behalf of Largan in this case. I am being compen-
`13.
`sated for my time at my usual consulting rate of $250 per hour, plus actual expenses. No part of
`my compensation depends on the outcome of this case or on the opinions that I render.
`I have been asked to provide my opinion on how certain terms appearing in the asserted
`14.
`claims of the Asserted Patents would have been understood by a person of ordinary skill in the art
`(“POSITA”) in the field of optical engineering at the time of the invention based on my technical
`understanding of those terms, in light of the intrinsic and extrinsic evidence.
`I understand that Largan has asserted both independent claims and dependent claims.
`15.
`And I understand that while an independent claim is a standalone claim that contains all the limi-
`tations necessary to define an invention, a dependent claim refers to a claim previously set forth
`and further limits that claim. In other words, a dependent claim incorporates by reference all the
`limitations of the claim to which it refers and adds at least one further limitation. I also understand
`that when a term appears in different claims within the same patent, that term is presumed to have
`the same meaning throughout.
`For purposes of my declaration, I understand that each of the four Asserted Patents in
`16.
`this case was filed with the United States Patent and Trademark Office (USPTO) between 2006
`and 2013, and three of those four patents claim priority to patent applications filed in Taiwan.
`Specifically:
`• The ’518 Patent was filed with the USPTO on October 6, 2006. It does not claim
`an earlier priority;
`• The ’691 Patent was filed with the USPTO on October 26, 2010. It claims priority
`to a patent application filed in Taiwan on August 20, 2010;
`• The ’796 Patent was filed with the USPTO on December 13, 2013. It claims priority
`to a patent application filed in Taiwan on October 29, 2013; and
`
`
`4
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`o The ’378 Patent was filed with the USPTO on December 2, 2013. It claims priority
`
`to a patent application filed in Taiwan on October 18, 2013.
`
`17.
`
`Based on these filing dates, it is my understanding that the priority dates for each ofthe
`
`Asserted Patents are: October 6, 2006 for the ’518 Patent; August 20, 2010 for the ’69] Patent;
`
`October 29, 2013 for the ’796 Patent; and October 18, 2013 for the ’378 Patent.
`
`18.
`
`Specifically, I have been asked to provide my opinions for the following terms of the
`
`Asserted Patents:
`
`“aspheric”
`
`’518 claim 1; ’69] claim 21; ’796
`claims 1, 15, and 21; ’378 claims 1
`and 8
`
`“half ofthe diagonal length ofthe effective pixel
`area of the electronic sensor is Im ”
`
`,691 claims 26 and 27
`
`“lens element(s)”
`
`’518 claim 1; ’69] claim 21; ’796
`claims 1, 15, and 21; ’378 claims 1
`and 8
`
`
`
`
`
`19.
`
`I understand that Largan previously asserted the ’691 Patent in a lawsuit against Genius
`
`Electronic Optical Co. in the Northern District of California. I understand that the court in the
`
`Genius case issued a claim construction opinion, but that none of the claim terms at issue here
`
`were construed in that opinion.2 I also understand that the court decided that case on summary
`
`judgment, ruling that while the Genius products met the asserted claims of the patents-in—suit,
`
`1 For consistency, this is the same afl'ected claims information the Defendants’ included in their
`Local Patent Rule 4-l(a) Disclosure, served on May 28, 2020. My understanding is that any addi-
`tional asserted claim not listed here would also be an affected claim if the disputed claim term is
`expressly recited in the additional asserted claim or is recited in the corresponding independent
`claim.
`
`2 It is my understanding that the term “aspheric” was included as a disputed term through the claim
`construction briefing in the Genius case, and that Genius ultimately removed the term for con-
`struction in the parties’ Final Joint Claim Construction and Prehearing Statement. Final Joint
`Claim Construction and Prehearing Statement, Case No. 3: 13-cv-02502-JD in the Northern Dis-
`trict of California, Dkt. No. 96.
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`•
`
`including the ’691 Patent, only the Genius products that Genius shipped directly into the United
`States infringed.
`SUMMARY OF MY OPINIONS
`III.
`20.
`It is my opinion that a POSITA would understand:
`• The term “aspheric” is a commonly understood term of art that would have its plain
`and ordinary meaning – that is, non-spherical and non-plano. Further, a POSITA
`would understand that an aspheric surface can be represented by a number of dif-
`ferent mathematical equations;
` “Lens element” is a commonly understood term that would have its plain and or-
`dinary meaning – that is, each individual lens within the lens system, rather than
`including some portion of the individual lens and excluding others; and
`• The term “half of the diagonal length of the effective pixel area of the electronic
`sensor is ImgH” is definite and is itself a definition of “ImgH.” Further, a POSITA
`would understand that the term “effective pixel area” is a term commonly used in
`the art when describing parameters of electronic image sensors for the purposes of
`lens system design.
`I base my opinion on the expertise that I have acquired throughout my more-than-three
`21.
`decades as a lens designer, scientist, researcher, and scholar of optical sciences and optical design
`and related fields, as well as through my analysis of the Asserted Patents, their applications, file
`histories, and other relevant evidence.
`I realize that new information occasionally comes to light during the course of litiga-
`22.
`tion, including as a result of additional discovery. Therefore, I reserve the right to supplement or
`amend this declaration as appropriate in light of any information obtained in this case through
`discovery or other proper means after I submit this declaration. Likewise, should the court or any
`party in this case ask me to testify in this case, I reserve the right to use and rely on this declaration,
`on any exhibits that accompany it or are referenced in it, and on demonstrative devices or other
`information to support, or to summarize, my testimony.
`
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`IV. CLAIM CONSTRUCTION FRAMEWORK
`I understand that claim construction is governed by a number of legal principles. Alt-
`23.
`hough I am not a lawyer, Largan’s counsel has advised me on the relevant legal principles and I
`have applied them in forming my opinions.
`I understand that, generally, claim terms and phrases are to be given the meaning that
`24.
`they would have to a POSITA at the time of the invention. I also understand that, when a term’s
`plain and ordinary meaning is apparent, then subjective, ad hoc, or specialized definitions of the
`term should not apply unless the patent applicants made clear that they intended only those spe-
`cialized definitions to apply. In addition, I understand that dictionaries, articles, and other extrinsic
`evidence may assist the court in construing a claim term.
`For example, I understand that in construing terms, the court first considers the intrinsic
`25.
`record. Most importantly, the words of the claims are to be given their ordinary meaning in the
`context of the patent as interpreted by a POSITA. In considering the intrinsic record, the court
`recognizes that the patentee can act as his own lexicographer. And in determining the intended
`claim language, the court first looks at the other claims and the specification for context. I under-
`stand that the prosecution history and other documents in the patent’s file wrapper can be helpful,
`but that courts are to view them with more skepticism when compared to the plain language of the
`claims themselves. After considering the intrinsic record, the court may also look to extrinsic evi-
`dence, though it is considered of secondary importance.
`Level of Ordinary Skill in the Art
`A.
`26.
`As detailed above, I understand that U.S. Application 11/539,175, the application lead-
`ing to the ’518 Patent, was filed on October 6, 2006. And I understand that the ’691 Patent claims
`priority to Taiwan Application 99127879, filed on August 20, 2010, the ’796 Patent claims priority
`to Taiwan Application 102139029, filed on October 29, 2013, and the ’378 Patent claims priority
`to Taiwan Application 102137700, filed on October 18, 2013.
`Based on these filing dates, it is my understanding that the priority dates for each of the
`27.
`Asserted Patents are: October 6, 2006 for the ’518 Patent; August 20, 2010 for the ’691 Patent;
`
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`October 29, 2013 for the ’796 Patent; and October 18, 2013 for the ’378 Patent.
`I have concluded that a POSITA’s understanding of the terms “aspheric” and “lens
`28.
`element” would not have changed between October 6, 2006 and October 29, 2013, respectively
`the earliest and latest claimed priority dates for any of the Asserted Patents that employ those
`terms. Therefore, in constructing those terms, I have based my opinions on the understanding of a
`POSITA as of October 6, 2006.
`Because I understand that the earliest possible priority date for the ’691 Patent is Au-
`29.
`gust 20, 2010, and because that is the only Asserted Patent that contains the claim term “half of
`the diagonal length of the effective pixel area of the electronic sensor is ImgH,” I have construed
`that term based on the understanding of a POSITA as of August 20, 2010.
`I understand that the following factors may be considered when determining the criteria
`30.
`for a POSITA: (1) the educational level of the inventors; (2) the type of problems encountered in
`the art; (3) the prior art solutions to those problems; (4) the rapidity with which innovations are
`made; (5) the sophistication of the technology; and (6) the educational level of active workers in
`the field. I have applied these factors in determining the qualifications of a POSITA for purposes
`of my analysis of the claim terms in the Asserted Patents.
`31. With regard to factors (1) and (6), i.e., the educational level of the inventors and active
`workers in the field, it is my opinion that a POSITA would have at least an undergraduate degree
`in optical instrumentation, optical design, optical engineering, optical sciences, or a related field
`(e.g., physics, applied physics, advanced materials science, photonics, electronic engineering, or
`mechanical engineering). For example, I have been informed that each of the named inventors of
`the Asserted Patents held a bachelor’s or a master’s degree, or foreign equivalent, in physics, ad-
`vanced materials science, photonics, or mechanical engineering at the time of the inventions.
`Based on my experience over the last three decades, it is my opinion that lens designers, manufac-
`turers, and engineers generally hold a bachelor’s degree, or foreign equivalent, in optical instru-
`mentation, optical design, optical engineering, optical sciences, or a related field (e.g., physics,
`
`
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`applied physics, advanced materials science, photonics, electronic engineering, or mechanical en-
`gineering).
`To understand the basics of lens design and manufacturing, a POSITA would have had
`32.
`to at least taken some introductory courses on lens and optics designs, and preferably more ad-
`vanced courses specifically relating to lens design, such as the OPTI503 Optical Design and In-
`strument course I teach at the University of Arizona. Preferably, a POSITA would have taken
`courses relating specifically to lens design because a POSITA would need to understand more than
`the basics of optics and lens design and have some familiarity with lens design software, such as
`Code V and Zemax, in order to properly design a working lens and optical system. Some of this
`education can also be replaced with one to two years of direct hands-on training in lens design and
`instrumentality. Moreover, it is my opinion that a POSITA who was attempting to solve problems
`in the art would likely need the same amount of education and/or experience as detailed above.
`Factors (2)-(5), i.e., the types of problems encountered, prior art solutions, rapidity of
`33.
`innovations, and sophistication of technology, also support a requirement of at least an undergrad-
`uate degree in optical instrumentation, optical design, optical engineering, optical sciences, or a
`related field (e.g., physics, applied physics, advanced materials science, photonics, electronic en-
`gineering, or mechanical engineering), and some work in optical engineering or design. During
`the time of the inventions, lenses were getting smaller and smaller while demand for higher per-
`formance lenses continued. There was a constant need to improve and innovate lens systems in
`order to keep up with the changes and innovations in electronic devices. Further, the POSITA
`would also need to keep abreast of the changes and innovations in available materials and manu-
`facturing capabilities and technology. The ability to keep up with these constant changes would
`only come with at least one to two years of experience working in optical engineering or design.
`Based on the analysis set forth above and based on my decades of experience in the
`34.
`optical engineering field, it is my opinion that, with respect to the subjects and technology of the
`Asserted Patents, a POSITA would have had at least a bachelor’s degree in optical instrumentation,
`
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`optical design, optical engineering, optical sciences, or a related field (e.g., physics, applied phys-
`ics, advanced materials science, photonics, electronic engineering, or mechanical engineering), as
`well as one or two years of experience working in optical engineering or design, including at least
`some experience with lens research, design, or fabrication. At the time of the claimed effective
`filing dates of each of the Asserted Patents, I was at least a POSITA based on my qualifications,
`described above.
`I am well aware of the qualifications of a POSITA because I have worked with, super-
`35.
`vised, instructed, and recruited researchers, scientists, and engineers with these qualifications for
`over 20 years. More specifically, I worked with, supervised, instructed, and recruited such POSI-
`TAs during the period in which applications for the Asserted Patents were filed in Taiwan and in
`the United States. By 2006, the earliest priority for any of the Asserted Patents, I had held my
`bachelor’s degree in optical instrumentation for 17 years and my Ph.D. in optical sciences for five
`years. And by that time, I had also worked as a graduate research assistant in optical sciences and
`as an optics engineer, research scientist, and project leader, with progressively greater responsibil-
`ity for supervising optics engineers, researchers, and scientists in each of those positions.
`The optical engineers, researchers, and scientists with whom I worked and researched,
`36.
`as well as those I supervised, both at the University of Arizona and in private industry, met the
`POSITA criteria I stated above. Specifically, most held bachelor’s degrees in the relevant fields
`and had at least several years of work experience in the relevant optical engineering or design
`fields. They all possessed basic knowledge regarding lenses and optical systems.
`I have met the POSITA criteria I described above since well before October 6, 2006,
`37.
`the earliest priority date of any of the Asserted Patents. Therefore, I am highly familiar with the
`understanding and knowledge that a POSITA would have held from October 6, 2006 through Oc-
`tober 29, 2013 (the earliest priority date of the ’796 Patent, which is the latest of any of the four
`Asserted Patents). Thus, I understand the perspective of a POSITA, and I have applied that per-
`spective in my analysis of, and conclusions regarding, the Asserted Patents, asserted claims and
`the construction of the claim terms at issue.
`
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`Plain and Ordinary Meaning
`B.
`I have been informed that a claim term should be understood according to its plain and
`38.
`ordinary meaning unless it is certain that the inventors intended for the term to refer only to some
`other alternative meaning. I understand that, as a legal matter, the plain and ordinary meaning of
`the term applies unless the inventor either specifically defined the term differently in the patent
`specification or explicitly disavowed its plain and ordinary meaning during prosecution. And a
`POSITA will interpret a term according to its plain and ordinary meaning in the relevant field
`unless the patent specification explicitly and clearly directs otherwise. Indeed, in the field of lens
`design, those designing and developing lenses tend to use the same terms for describing specific
`parameters of a lens or lens element, including the claim terms at issue here. This is unsurprising
`as the design, fabrication, and manufacture of such small components requires great precision, and
`having a field using accepted and understood terms is vital to achieve such precision.
`It is my understanding that patent specifications often provide examples or illustrations
`39.
`of a claim term’s scope, including formulas, that are narrower than the full scope of the claim
`term’s intended meaning. Such examples are generally not intended, and should not be read, to
`narrow the invention’s scope beyond the plain and ordinary meaning of its terms. Unless the in-
`ventor clearly and unambiguously intended the illustrative definition to replace the plain and ordi-
`nary definition of a term, or explicitly disavowed it, POSITAs must still interpret the term accord-
`ing to its plain and ordinary meaning.
`Definiteness
`C.
`40.
`I understand that a patent must satisfy the definiteness requirement of 35 U.S.C. § 112
`in order to be valid. In particular, I understand that requirement to mean that a claim must be
`sufficiently clear and particular to inform those skilled in the art of the scope of the invention with
`reasonable certainty. This standard necessarily depends upon the perspective of a POSITA, and
`not, for example, an untrained layperson. Terms that might seem ambiguous or indefinite to some-
`one without a POSITA’s knowledge and skill may often be clear and precise to a POSITA. That
`is, when a term’s plain and ordinary meaning suffices to inform a POSITA of the invention’s
`
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`scope, that term is definite.
`TECHNOLOGY BACKGROUND
`V.
`The four Asserted Patents relate to compact imaging lens systems. These imaging lens
`41.
`systems are found in the cameras of electronic devices, such as smartphones, tablets, laptops, gam-
`ing systems, and webcams, as well as in automobiles and medical devices.
`Largan is the undisputed leader in this technology, with its lenses found in the iPhone
`42.
`and products sold by Amazon, Google, Microsoft, and Samsung, among others.
`Founded in 1987, Largan was a pioneer in developing and manufacturing plastic as-
`43.
`pherical lenses. Largan created and began selling hybrid lenses (glass and plastic) for use in tradi-
`tional cameras in 1992, scanners in 1997, and digital cameras in 1998. Around 2000, Largan rec-
`ognized an opportunity to develop lenses for computer cameras and mobile phones.3
`This opportunity was the result of innovation in electronic devices increasing, and con-
`44.
`sumers starting to expect the quality of images and photographic capabilities usually reserved for
`a “professional” handheld DSLR (digital single lens reflex) camera in their cellular devices that
`could fit in their pocket. This demand for higher performance cameras in smaller devices has con-
`tinued to the present, resulting in the development of higher performance and more compact lenses.
`For instance, the lens in an iPhone may look like a simple piece of plastic. But that
`45.
`piece of plastic, measuring at hundredths of an inch, is designed and manufactured with utmost
`precision to replicate the optical properties found in a nine-inch and twelve-inch reflex camera
`made by companies like Nikon, Canon, and others. And it is those properties that allow the user
`to take an “in focus” picture no matter the distance and zoom. For example, below are an image of
`a Nikon system showing the various internals and lens elements, a representative exploded view
`of the lens system found in an iPhone, and an image of the lens system in a Nokia Lumia phone:
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`3 http://www.largan.com.tw/html/about/about en.php
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`4 https://www.ephotozine.com/article/nikon-d5-dslr-hands-on-preview-28654
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` https://www.techpolicyviews.com/micro-lens-making-patents-makes-largan-shinning-star/
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`This is possible in such a small space because the lens isn’t simply a single lens, but
`46.
`instead multiple lenses stacked on top of one another, as shown above. And these tiny components
`are designed and manufactured with great precision.
`During the period from 2006 to 2013, the demand for smaller and smaller cameras with
`47.
`higher and higher performance capabilities increased as demand for personal electronic devices
`like laptops and smartphones soared. Therefore, new and innovative lenses needed to be devel-
`oped. And that is exactly what the Asserted Patents sought to do. For example, as the ’796 Patent
`summarizes:
`
`In recent years, with the popularity of mobile terminals having camera functionalities, the
`demand of miniaturized optical systems has been increasing. As the advanced semiconduc-
`tor manufacturing technologies have allowed the pixel size of sensors to be reduced and
`compact optical systems have gradually evolved toward the field of higher megapixels,
`there is an increasing demand for compact optical systems featuring better image quality.7
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`In order to meet this demand for lens systems with short total track length while main-
`48.
`taining, or even improving, image quality, the Asserted Patents p