Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 672

*** EXHIBIT 4 FILED IN ERROR WITH CONFIDENTIAL INFORMATION . DOCUMENT LOCKED. DOCUMENT TO BE REFILED LATER.. *** EXHIBITS re #667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions (Briggs Declaration in Support of Samsung's Motion to Supplement Invalidity Contentions) filed bySamsung Electronics Co. Ltd.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11)(Related document(s) #667 ) (Maroulis, Victoria) (Filed on 1/27/2012) Modified on 1/27/2012 (feriab, COURT STAFF).

EXHIBIT 1

EXHIBIT V-4
SAMSUNG’S INVALIDITY CLAIM CHARTS FOR U.S. PATENT NO. 5,565,658 (GERPHEIDE ’658)
U.S. Patent No. 7,920,129
[1A] A capacitive touch sensor panel,
comprising:

Gerpheide ’658
Gerpheide ’658 discloses a capacitive touch sensor panel. See, e.g., id. at 1:10-14. For
example, Gerpheide ’658 states: “Apparatus and method for a capacitance-based proximity
sensor with interference rejection. A pair of electrode arrays establish a capacitance on a
touch detection pad, the capacitance varying with movement of a conductive object near the
pad. The capacitance variations are measured synchronously with a reference frequency
signal to thus provide a measure of the position of the object. Electrical interference is
rejected by producing a reference frequency signal which is not coherent with the
interference.” See id. at Abstract.

[1B] a first set of traces of conductive
material arranged along a first
dimension of a two-dimensional
coordinate system, the first set of
traces having one or more widths
including a maximum width;

Gerpheide ’658 discloses a first set of traces of conductive material (e.g., X Electrodes in
Fig. 2a) arranged along a first dimension of a two-dimensional coordinate system, the first
set of traces having one or more widths including a maximum width. See id. at Fig. 2a, 4:4154.
For example, Gerpheide ’658 states: “FIG. 2A illustrates the electrodes in a preferred
electrode array 12, together with a coordinate axes defining X and Y directions. One
embodiment includes sixteen X electrodes and twelve Y electrodes, but for clarity of
illustration, only six X electrodes 20 and four Y electrodes 22 are shown. It is apparent to
one skilled in the art how to extend the number of electrodes. The array is preferably
fabricated as a multilayer printed circuit board 24. The electrodes are etched electrically
conductive strips, connected to vias 26 which in turn connect them to other layers in the
array. Illustratively, the array 12 is approximately 65 millimeters in the X direction and 49
millimeters in the Y direction. The X electrodes are approximately 0.7 millimeters wide on
3.3 millimeter centers. The Y electrodes are approximately three millimeters wide on 3.3
millimeter centers.” Id. at 4:41-54.
As shown below, Fig. 2a of Gerpheide ’658 illustrates a first set of traces of conductive
material (e.g., X Electrodes) arranged along a first dimension of a two-dimensional
coordinate system. Fig. 2a of Gerpheide ’658 also discloses the first set of traces (e.g., X

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U.S. Patent No. 7,920,129

02198.51855/4377981.1

Gerpheide ’658
Electrodes) having one or more widths including a maximum width. See, e.g., Fig. 2a, 4:4154.

2

U.S. Patent No. 7,920,129

[1C] and a second set of traces of the
conductive material spatially separated
from the first set of traces by a
dielectric and arranged along a second
dimension of the two-dimensional
coordinate system, the second set of
traces having one or more widths
including a minimum width;

Gerpheide ’658
To the extent Apple argues this limitation requires the first set of traces be “substantially the
same width – a maximum width along their lengths,”1 Gerpheide ’658 discloses the first set
of traces that are substantially the same width – a maximum width along their lengths (e.g.,
X Electrodes in Fig. 2a). Id.
Gerpheide ’658 discloses a second set of traces of the conductive material (e.g., Y Electrodes
Fig. 2a) spatially separated from the first set of traces by a dielectric (e.g., Insulator 31 Fig.
2b) and arranged along a second dimension of the two-dimensional coordinate system, the
second set of traces having one or more widths including a minimum width. See, e.g., id. at
Fig. 2a-2b, 4:64-5:10.
For example, Gerpheide ’658 states: “The X electrodes 20, Y electrodes 22, ground plane 25
and component traces 27 are etched copper traces within a multilayer printed circuit board.
The ground plane 25 covers the entire array area and shields the electrodes from electrical
interference which may be generated by the parts of the circuitry. The component traces 27
connect the vias 26 and hence the electrodes 20, 22, to other circuit components of FIG. 1.
Insulator 31, insulator 32 and insulator 33 are fiberglass-epoxy layers within the printed
circuit board 24. They have respective thicknesses of approximately 1.0 millimeter, 0.2
millimeters and 0.1 millimeters. Dimensions may be varied considerably as long as
consistency is maintained. However, all X electrodes 20 must be the same size, as must all
Y electrodes 22..” Id. at 4:64-5:10.
As shown below, Fig. 2a of Gerpheide ’658 illustrates a second set of traces of conductive
material (e.g., Y Electrodes) arranged along a second dimension of a two-dimensional
coordinate system. Fig. 2a of Gerpheide ’658 further discloses the second set of traces (e.g.,
Y Electrodes) having one or more widths including a minimum width. See, e.g., id. at Fig.
2a, 4:41-54.

1

See Apple’s Infringement Contentions at Exhibit 19, p. 1 (contending the Samsung Galaxy Tab 10.1 meets this limitation
because “each of the first set of traces has substantially the same width – a maximum width along their entire lengths”).
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U.S. Patent No. 7,920,129

Gerpheide ’658

As shown below, Fig. 2b of Gerpheide ’658 illustrates the identified second set of traces
spatially separated from the first set of traces by a dielectric insulator. See Fig. 2b, 5:4-9.

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U.S. Patent No. 7,920,129

Gerpheide ’658

To the extent Apple argues this limitation requires the second set of traces be “substantially
the same width – a maximum width along their lengths,”2 Gerpheide ’658 discloses the
second set of traces that are substantially the same width – a minimum width along their
lengths (e.g., Y Electrodes in Fig. 2a). See, e.g., id. at Fig. 2a.
[1D] wherein the minimum width of
Gerpheide ’658 discloses the minimum width of the second set of traces (e.g., Y Electrodes
the second set of traces is substantially in Fig. 2a) is substantially greater than the maximum width of the first set of traces (e.g., X
greater than the maximum width of the Electrodes in Fig. 2a) at least at an intersection of the first and second sets of traces to
first set of traces at least at an
provide shielding for the first set of traces. See, e.g., id. at Fig. 2a, 4:41-54.
2

See Apple’s Infringement Contentions at Exhibit 19, p. 2 (contending the Samsung Galaxy Tab 10.1 meets this limitation
because “each of the second set of traces has substantially the same width – a minimum width along their entire lengths”).
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U.S. Patent No. 7,920,129
intersection of the first and second sets
of traces to provide shielding for the
first set of traces;

Gerpheide ’658
For example, Gerpheide ’658 states: “FIG. 2A illustrates the electrodes in a preferred
electrode array 12, together with a coordinate axes defining X and Y directions. One
embodiment includes sixteen X electrodes and twelve Y electrodes, but for clarity of
illustration, only six X electrodes 20 and four Y electrodes 22 are shown. It is apparent to
one skilled in the art how to extend the number of electrodes. The array is preferably
fabricated as a multilayer printed circuit board 24. The electrodes are etched electrically
conductive strips, connected to vias 26 which in turn connect them to other layers in the
array. Illustratively, the array 12 is approximately 65 millimeters in the X direction and 49
millimeters in the Y direction. The X electrodes are approximately 0.7 millimeters wide on
3.3 millimeter centers. The Y electrodes are approximately three millimeters wide on 3.3
millimeter centers.” Id. at 4:41-51.
As shown below, Fig. 2a of Gerpheide ’658 further illustrates the width of the Y Electrodes
is substantially greater than the width of the X Electrodes at least at an intersection of the
first and second sets of electrodes.

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U.S. Patent No. 7,920,129

Gerpheide ’658

In addition to Fig. 2a, Gerpheide ’658 teaches that the minimum width of the Y Electrodes is
greater than four times the maximum width of the X Electrodes. See, e.g., id. at 4:41-54
(teaching that the width of the Y Electrodes is 3 mm, while the width of the X Electrodes is
only 0.7 mm).
To the extent Gerpheide ’658 does not explicity disclose shielding for the first set of traces,
one of ordinary skill in the art would understand that it is inherent in the electrode
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U.S. Patent No. 7,920,129

Gerpheide ’658
arrangement disclosed in Gerpheide ’658 that the wider second set of traces would provide
shielding for the first set of traces.
Moreover, to the extent not inherent or otherwise disclosed in Gerpheide ’658, making the
minimum width of the second set of traces substantially greater than the maximum width of
the first set of traces at an intersection of the first and second set of traces to provide
shielding for the first set of traces would have been obvious to one of ordinary skill in the art.
One of ordinary skill in the art would recognize that increasing the width of a conductor
placed above a source of electromagnetic interference, in order to shield the interference
from other system components, would be an obvious design choice that would yield
predictable results obtained.
Furthermore, using the wider second traces disclosed in Gerpheide ’658 to provide shielding
was well-known in the art and would also have been obvious to one of ordinary skill in the
art in light of U.S. Patent No. 5,083,118 to Kazama (“Kazama ’118”). Gerpheide ’658
recognized the benefit of protecting a capacitive touchscreen against electromagnetic
interference arising from underlying circuitry. Gerpheide 658’s solution to this problem was
to dispose a ground shield 25 between the circuitry and the second traces. See id. at 4:645:2 . For example, Gerpheide ’658 states: “The ground plane 25 covers the entire array area
and shields the electrodes from electrical interference which may be generated by the parts of
the circuitry.” Id.
It was well-known in the art that by widening the second set of traces one could eliminate the
need to “provide a further shield layer, which layer is grounded to relieve an influence from
the noise of the tube surface.” See, e.g., Kazama ’118 at 1:42-46.
Kazama ’118 discloses a capacitive touch sensor panel designed to be mounted on a CRT
tube or LCD screen. See, e.g., id. at Abstract. The touch sensor panel comprises a first set
of traces of conductive material arranged along a first dimension of a two-dimensional
coordinate system, and a second set of traces of the conductive material spatially separated
from the first set of traces by a dielectric, wherein the second set of traces has a minimum
width that is substantially greater than the maximum width of the first set of traces at least at

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U.S. Patent No. 7,920,129

Gerpheide ’658
an intersection of the first and second sets of traces to provide shielding for the first set of
traces.
Kazama ’118 provides as follows: “Electrode wires 2 and 3 shown in exploded form in FIG.
2 are arranged perpendicularly on the tablet 1. The electrode wires Z [sic] and 3 are formed
of ITO, which are subjected to vapor deposition etching as transparent electrodes on films 4,
4. With respect to the spacing arrangement of the electrode wires 2 and 3, the electrode wire
3 closer to CRT 5 is wider, as shown in FIG. 2, a gap therebetween being narrow.” Id. at
2:36-43.
Fig. 2 of Kazama ’118 below illustrates the arrangement of traces disclosed by Kazama.

Kazama ’118 recognized problems associated with electromagnetic interference arising from
the underlying CRT tube or LCD screen and coupling onto the traces of the touch panel. See
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U.S. Patent No. 7,920,129

Gerpheide ’658
id. at Abstract. Kazama ’118, however, also recognized the problems associated with
providing a separate shield layer to reduce electromagnetic interference.
For example, Kazama ’118 states: “In use, it has been necessary to provide a further shield
layer, which layer is grounded to relieve an influence from the noise of the tube surface.
This results in problems of higher cost, and in deteriorating the transparency.” Id. at 1:42-46.
Instead of a separate ground layer, Kazama teaches increasing the width of the second set of
traces so that it is substantially greater than the width of the first set of traces at least at an
intersection of the first and second sets of traces to provide shielding for the first set of traces
For example, Kazama ’118 states: “one end of the electrode wire of the tablet was grounded
with a low resistance, and a pattern of a layer close to the CRT tube surface was increased in
width to narrow the gap of the pattern, whereby this layer functioned as a shield layer,
enabling reduction of the noise of the tube surface.” Id. at 2:5-10.
Kazama ’118 further states: “an increased with of the electrode wire on the side of the
display surface of the input device such as a CRT, LCD, etc. to narrow a gap between the
electrode wires, whereby the electrode wire not applied with a pulse functions as a shield
layer.” Id. at 1:67-2:3; see also id. at Abstract (disclosing “a noise preventive means for
relieving a noise from the display surface of the input device such as CRT, LCD, etc., said
noise prevention means having . . . a pattern of each of the electrode wires of a layer close to
the tube surface of CRT being increased and the gap between the electrode wires being
narrowed”); see also id. 1:64-2:11, 1:49-56, 3:25-4:31, 2:27-44.
Kazama ’118 further discloses that the “wider parallel electrode wires … act as a shield to
reduce the effects of noise emanating from the display surface on the coordinate indications
means,” where the coordinate indication means includes the first set of traces. See id. at 4:25.
It would have been obvious to a person of ordinary skill in the art to combine the teachings
of Gerpheide ’658 and Kazama ’118, resulting in a capacitive touch panel comprising a

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U.S. Patent No. 7,920,129

Gerpheide ’658
second set of traces with a minimum width that is substantially greater than the maximum
width of a first set of traces at least at an intersection of the first and second sets of traces to
provide shielding for the first set of traces. More specifically, it would have been obvious to
a person of ordinary skill to remove the shield layer of Gerpheide ’658 and instead widen the
second set of traces so that they function as a shield layer, as taught by Kazama ’118. The
motivation for doing so is found in Kazama: to “enable[] reduction of the noise” from
components or circuitry underlying the touch panel, while at the same time solving
“problems in terms of cost and transparency.” Id. at 2:3-11.

Moreover, it was well-known in the art of capacitive touch panels that a second set of traces
could be used to provide shielding for the first set of electrode traces. For example, U.S.
Patent No. 7,154,481 to Cross (“Cross ’481”), U.S. Patent Application Publication No.
2006/0227114 to Geaghan et al. (“Geaghan ’114”), and WIPO Publication No. WO
2005/073834 to Parkinson et al. (“Parkinson ’834”), which are all analogous art and directed
to touch sensor panels with two-dimensional arrangements of traces of conductive material,
disclose using a second set of traces to provide shielding for a first set of traces.
For example, Cross ’481, which is also directed to a capacitive touch panel with a twodimensional array of conductive traces, states: “The use of the bottom layer 514 as the
reference layer advantageously provides shielding for the touch sensor from electromagnetic
interference (EMI) originating in a display, such as an LCD or CRT display (not shown),
located below the touch screen. This may eliminate the need for an additional conductive
layer, usually found in present capacitive touch screens, to act as an EMI shield between the
display and the touch sensor.” Id. at 9:61-10:1. Cross ’481 further discloses a transparent
capacitive touch sensor panel designed to be mounted over a CRT or LCD, wherein a large
conductive mutual capacitance reference trace is used to shield the upper one or more mutual
capacitance measurement traces from electro-magnetic interference caused by the display.
See, e.g., id. at Figure 5, 9:49-10:6.
Cross ’481 further states: “The use of the bottom layer 514 as the reference layer
advantageously provides shielding for the touch sensor from electromagnetic interference
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U.S. Patent No. 7,920,129

Gerpheide ’658
(EMI) originating in a display, such as an LCD or CRT display (not shown), located below
the touch screen. This may eliminate the need for an additional conductive layer, usually
found in present capacitive touch screens, to act as an EMI shield between the display and
the touch sensor. An optional pattern of conductive segments (not shown) disposed on the
surface of the conductive layer and coupled to the contacts 515 , 516 , 517 , 518 may be used
to linearize the electric field across the surface of the top conductive layer.” Id. at 9:49-10:6.
Geaghan ’114, which is directed to a capacitive touch panel with a two-dimensional array of
conductive traces oriented 90 degrees from each other, states: “Rear electrodes can provide
limited EMI shielding in lieu of a transparent rear shield layer. Driven rear electrodes can
reduce currents due to parasitic capacitance.” Id. at [0076], see also id. at [0037](stating “[i]f
driven with the same AC signal as the top resistive layer 344, 444 of the touch panel 330,
450, the rear electrodes 342, 451, 452, 453, 454, reduce capacitive coupling to the
conductive elements behind the touch panel 330, 450, typically including the display and/or
chassis”). Geaghan ’114 further claims: “11. The device of claim 7, wherein the one or
more electrodes are driven with an AC signal. 12. The device of claim 7, wherein the one or
more electrodes are configured to shield portions of the electrode layer from EMI.” Id. at
Claims 11-12; see also id. [0026] – [0027]
Parkinson ’834, which is also directed to a capacitive touch panel with a two-dimensional
array of conductive traces, states: “the rear layer 52 is used as a shield to shield the front
layer 50 from interferences from the LCD 15.” Id. at [0040].
It would have been obvious to one of ordinary skill in the art to combine the disclosure of
Gerpheide ’658 with any one of Cross ’481, Geaghan ’114, or Parkinson ’834 to make the
width of the second set of traces substantially greater than the maximum width of the first set
of traces at least at an intersection of the first and second sets of traces to provide shielding
for the first set of traces. Combining Gerpheide ’658 with any of Kazama ’118, Cross ’481,
Geaghan ’114, or Parkinson ’834 would have been combining prior art elements according to
known methods to yield predictable results. There would also be motivation to combine
Gerpheide ’658 with any one of Cross ’481, Geaghan ’114, and Parkinson ’834: to reduce
costs and improve transparency by removing the additional shield layer.

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U.S. Patent No. 7,920,129
[1E] and wherein sensors are formed
at locations at which the first set of
traces intersects with the second set of
traces while separated by the
dielectric.

Gerpheide ’658
Gerpheide ’658 discloses sensors formed at locations at which the first set of traces intersects
with the second set of traces while separated by the dielectric. See [1C].
For example, Gerpheide ’658 states: “FIG. 4 shows one specific embodiment of a
synchronous electrode capacitance measurement unit 14 connected to the electrode array 12,
in which algebraic sums of mutual capacitances between electrodes are measured. The
components are grouped into four main functional blocks. A virtual electrode synthesis block
70 connects each of the X electrodes to one of the wires CP or CN, and each of the Y
electrodes to one of the wires RP or RN. The electrodes are selectively connected to the
wires by switches , preferably CMOS switches under control of the position locator
apparatus 18 (FIG. 1) to select appropriate electrodes for capacitance measurement. All
electrodes connected to the CP wire at any one time are considered to form a single "positive
virtual X electrode". Similarly, the electrodes connected to CN, RP, and RN form a
"negative virtual X electrode", a "positive virtual Y electrode", and a "negative virtual Y
electrode", respectively.” Id. at 6:1-18; see also id. at 5:4:64- 5:25, 5:52-67, Fig. 2a-2b, Fig.
4.
Gerpheide ’658 discloses the first set of traces and the second set of traces separated by the
dielectric. See, e.g., id. at Fig. 2b, 4:64-5:10.

[2A] The capacitive touch sensor
panel of claim 1, further comprising a
liquid crystal display (LCD) adjacent
to the touch sensor panel, the LCD
emitting a modulated Vcom signal,

To the extent Apple argues this claim requires a “touchscreen based on mutual capacitance,”3
Gerpheide ’658 discloses a touchscreen based on mutual capacitance. Id.
Gerpheide ’658 discloses the capacitive touch sensor panel of claim 1, further comprising a
liquid crystal display (LCD) adjacent to the touch sensor panel, the LCD emitting a
modulated Vcom signal. For example, Gerpheide ’658 discloses the use of capacitive
touchscreens with displays in discussing the prior art. See id. at 1:10-32.
To the extent Gerpheide ’658 does not explicitly disclose a LCD adjacent to the touch sensor
panel, the LCD emitting a modulated Vcom signal, one of ordinary skill in the art would

3

See Apple’s Infringement Contentions at Exhibit 19, p. 5 (contending the Samsung Galaxy Tab 10.1 meets this limitation
because “the Samsung Galaxy Tab 10.1 uses a touchscreen based on mutual capacitance”).
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U.S. Patent No. 7,920,129

Gerpheide ’658
understand that the capacitive touchscreen disclosed in Gerpheide ’658 inherently discloses a
LCD adjacent to the touch sensor panel, the LCD emitting a modulated Vcom signal.
To the extent that Philipp ’898 does not explicitly disclose emitting a modulated Vcom
signal, one of ordinary skill in the art would understand that an LCD emitting a modulated
Vcom signal is inherent in the LCD touch panel disclosed in Philipp ’898. See, e.g., id. at Id.
at 8:19-28, 7:53-56, Figs. 3A-3B, Fig. 5. Moreover, it was well-known in the art that LCD
displays emitted a modulated Vcom signal. See, e.g., Sarma, "Liquid Crystal Displays,"
Chapter 32 of _Electrical Measurement, Signal Processing, and Displays_, Volume 18 of
_Principles and Applications of Engineering_, CRC Press LLC, 2004, p. 32-19, para. 1
(“Sarma”).
For example, Sarma states: “Column driver voltage can be reduced by using a Vcom
modulation drive method. In this method, the Vcom node (which is connected to all pixels in
the display) is driven above and below a 5 V range of the column drivers. Each and every
row time, the Vcom node is alternated between a voltage above and a voltage below the 5 V
output range of the column drivers. This achieves 10 V across the LC material using 5 V
column drivers. This method requires additional components and consumes additional power
due to the oscillation of the Vcom node. In addition, to avoid capacitive injection problems,
the row drivers usually have their negative supply modulated with the same frequency as the
Vcom node. Note, however, that compared to 10 V column drivers, 5 V column drivers
consume less power, and are simpler to design and fabricate using small-geometry CMOS.
The Vcom modulation drive method can be used with a row (polarity) inversion scheme only
(for elimination of pixel •icker) which results in some horizontal cross talk. However,
column inversion and pixel inversion schemes provide better image quality with muchreduced cross talk, but they cannot be used with the Vcom modulation drive.” Id.
See also U.S. Patent No. 6,128,045 to Anai at Figs. 7-8 and 5:7-21 (stating: “The common
voltage generating circuit CVG generates a common voltage VCOM, whose level is inverted
with respect to a reference voltage, in every horizontal scanning period and every vertical
scanning period under the control of a polarity inversion signal POL supplied from the
timing generating circuit 14. The common voltage VCOM is supplied to the counter

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U.S. Patent No. 7,920,129

[2B] and the second set of traces
configured for shielding the first set of
traces from the modulated Vcom
signal.

Gerpheide ’658
electrode. In synchronism with the level inversion of the common voltage VCOM, the
polarity inverting circuit PV level-inverts the high vision video signal, NTSC video signal or
multiplexed video signal supplied from the video signal processing circuit 19 with respect to
the reference voltage in an opposite phase, and outputs the level-inverted signal. As a result,
the polarity of voltage applied to the liquid crystal is periodically inverted.”)
See also U.S. Patent No. 7,825,885, U.S. Patent No. 6,873,312, and U.S. Patent No.
6,232,937.
See [1D] and [2A].
To the extent Gerpheide ’658 does not explicitly disclose the second set of traces configured
for shielding the first set of traces from a modulated Vcom signal, one of ordinary skill in the
art would understand that it is inherent in the capacitive touchscreen display disclosed in
Gerpheide ’658, which discusses the use of an LCD device, that the inventors contemplated
using the disclosed arrangement of conductive traces to shield against interference emitted
from LCD screens, which would include modulated Vcom signals emitted from such
screens.
To the extent this claim element is not inherent in the disclosure of Gerpheide ’658, as
discussed above (see [1D]), it would have been obvious to one of ordinary skill in the art in
light of the teachings of Kazama ’118, that wider lower electrodes could provide shielding
from noise emitted from an LCD screen, including that from a modulated Vcom signal.
Moreover, it would have been obvious to one of ordinary skill in the art to combine
Gerpheide ’658 with Kazama ’118 to provide shielding from LCD noise by widening the
second set of traces. Doing so would have resulted in a combination of prior art elements
according to known methods to yield predictable results.
See [1D], [2A], and [2B].

[3] The capacitive touch sensor panel
of claim 1, wherein the second set of
traces are widened to substantially
electrically isolate the first set of traces
from a liquid crystal display (LCD).
[5] The capacitive touch sensor panel Gerpheide ’658 discloses the capacitive touch sensor panel of claim 1 that further comprises
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U.S. Patent No. 7,920,129
of claim 1, further comprising a
computing system that incorporates
the sensor panel.
[7] The capacitive touch sensor panel
of claim 5, further comprising a digital
audio player that incorporates the
computing system.

Gerpheide ’658
a computing system that incorporates the sensor panel. See, e.g., id. at Fig. 1, 4:20-36.

See [5].
To the extent Gerpheide ’658 does not explicitly or inherently disclose a digital audio player
that incorporates the sensor panel, it would have been obvious to one of ordinary skill in the
art to incorporate the touch sensor panel disclosed in Gerpheide ’658 into a digital audio
player. A person or ordinary skill in the art would have recognized that is was well known at
the time of the invention to use touch sensor panels, such as the panel disclosed by
Gerpheide ’658, to provide input to various types of digital systems, including digital audio
systems. Using Gerpheide ’658’s touch sensor panel in a digital audio system would have
resulted in a combination of prior art elements according to known methods to yield
predictable results.
Furthermore, a person of ordinary skill in the art would have been motivated to incorporate
the touch sensor panel and computing system of Gerpheide ’658 into a digital audio player
in light of the teachings of U.S. Patent Application Publication No. 2003/0210286 to
Gerpheide et al. (“Gerpheide ’286”). Gerpheide ’286 discloses a capacitive touch sensor that
maybe “The present invention can be used in portable electronic appliances…. Portable
electronic appliances should be considered to include PDAs, mobile telephones, notebook
computers, audio playback devices such as MP3 music players, and other similar devices that
can display a list of items. ” Id. at [0043]. The motivation for incorporating the capacitive
touch screen and computer system of Gerpheide ’658 in the digital audio player of
Gerpheide ’286 would be to provide a robust display that would enable a digital audio player
user to view information and receive feedback related to his input.
See also U.S. Patent No. 7,932,898 to Philipp (“Philipp ’898”) at 14:45-54.

[9A] A digital audio player having a
capacitive touch sensor panel, the
touch sensor panel comprising:
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See [7].

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U.S. Patent No. 7,920,129
[9B] a first set of traces of conductive
material arranged along a first
dimension of a two-dimensional
coordinate system, the first set of
traces having one or more widths
including a maximum width;
[9C] and a second set of traces of the
conductive material spatially separated
from the first set of traces by a
dielectric and arranged along a second
dimension of the two-dimensional
coordinate system, the second set of
traces having one or more widths
including a minimum width;
[9D] wherein the minimum width of
the second set of traces is substantially
greater than the maximum width of the
first set of traces at least at an
intersection of the first and second sets
of traces to provide shielding for the
first set of traces;
[9E] and wherein sensors are formed
at locations at which the first set of
traces intersects with the second set of
traces while separated by the
dielectric.
[10A] A capacitive touch sensor
panel, comprising:
[10B] sense traces having one or more
widths including a maximum width;

Gerpheide ’658
See [1B].

See [1C].

See [1D].

See [1E].

See [1A].
See [1B].
Gerpheide ’658 discloses sense traces (e.g., X Electrodes in Fig. 2a) having one or more
widths including a maximum width. See, e.g., id. at Fig. 4 and 6:48-63

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U.S. Patent No. 7,920,129
[10C] and drive traces spatially
separated from the sense traces by a
dielectric, the drive traces having one
or more widths including a minimum
width,
[10D] the minimum width of the drive
traces being substantially greater than
the maximum width of the sense traces
at least at an intersection of the sense
and drive traces to provide shielding
for the sense traces;
[10E] wherein sensors are formed at
locations at which the sense traces
intersect with the drive traces while
separated by the dielectric.
[11A] The capacitive touch sensor
panel of claim 10, further comprising a
liquid crystal display (LCD) adjacent
to the touch sensor panel, the LCD
emitting a modulated Vcom signal,
[11B] and the drive traces configured
for shielding the sense traces from the
modulated Vcom signal.
[12] The capacitive touch sensor
panel of claim 10, wherein the drive
traces are widened to substantially
electrically isolate the sense traces
from a liquid crystal display (LCD).
[14] The capacitive touch sensor
panel of claim 10, further comprising a
computing system that incorporates
the sensor panel.
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Gerpheide ’658
See [1C].
Gerpheide ’658 discloses drive traces (e.g., Y Electrodes in Fig. 2a) spatially separated from
the sense traces by a dielectric, the drive traces having one or more widths including a
minimum width. See, e.g., id. at Fig. 4 and 6:48-63
See [1D], [10B], and [10C].

See [1E], [10B], and [10C].

See [2A].

See [2B] and [10C].

See [3] and [10C].

See [5].

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U.S. Patent No. 7,920,129
[16] The capacitive touch sensor
panel of claim 14, further comprising a
digital audio player that incorporates
the computing system.
[17A] A method for shielding a
capacitive touch sensor panel from
capacitive coupling of modulated
signals, comprising:
[17B] forming a first set of sense
traces having one or more widths
including a maximum width;
[17C] orienting the sense traces along
a first dimension of a two-dimensional
coordinate system;
[17D] forming a second set of drive
traces spatially separated from the first
set of sense traces by a dielectric, the
second set of drive traces having one
or more widths including a minimum
width,
[17E] the minimum width of the drive
traces being substantially greater than
the maximum width of the sense traces
at least at an intersection of the first
and second sets of traces to provide
shielding for the sense traces;
[17F] and orienting the drive traces
along a second dimension of the twodimensional coordinate system to form
sensors at locations at which the sense
traces intersect with the drive traces
while separated by the dielectric.
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Gerpheide ’658
See [7].

See [1A], [2A], and [2B].

See [1B] and [10B].

See [1B] and [10B].

See [1C], [10B], and [10C].

See [1D] and [10D].

See [1C], [1E], and [10E].

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U.S. Patent No. 7,920,129
[18] The method of claim 17, further
comprising affixing a liquid crystal
display (LCD) adjacent to a side of the
touch sensor panel closest to the drive
traces, the LCD capable of emitting a
modulated Vcom signal.
[19] The method of claim 17, further
comprising widening the drive traces
to substantially electrically isolate the
sense traces from a liquid crystal
display (LCD).
[21A] A method for shielding a
capacitive touch sensor panel from a
source of capacitive coupling,
comprising:
[21B] forming a first set of traces
further from the source of capacitive
coupling than a second set of traces,
the first set of traces configured for
sensing changes in mutual
capacitance, the first set of traces
having one or more widths including a
maximum width;

Gerpheide ’658
See [2A] and [10C].

See [3], [10B], and [10C].

See [1A] and [1D].

See [1B], [1E], [2A], and [2B].
Gerpheide ’658 discloses the first set of traces further from the source of capacitive coupling
than a second set of traces, the first set of traces configured for sensing changes in
capacitance, the first set of traces having one or more widths including a maximum width.
For example, Gerpheide ’658 teaches a source of capacitive coupling is below the ground
plane shown in Fig. 2b of Gerpheide ’658. See, e.g., id. at 4:66-5:2. Gerpheide ’658
discloses a first set of traces (e.g., X Electrodes in Figs. 2a and 2b) further from the source of
capacitive coupling than a second set of traces (e.g., Y Electrodes in Figs. 2a and 2b).
Gerpheide ’658 further discloses the first set of traces configured for sensing changes in
mutual capacitance. See also Gerpheide ’658 at Fig. 4, 6:48-63. For example,
Gerpheide ’658 states: “The capacitance measurement element 78 also contains a noninverting drive buffer 76 which drives RN and negative virtual Y electrodes to change
voltage levels copying the drive enable signal transitions. The inverting buffer 74 drives RP
and the positive virtual Y electrodes to change voltage levels opposite the drive enable signal
transitions. Since CP and CN are maintained at virtual ground, these voltage changes are the

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U.S. Patent No. 7,920,129

[21C] orienting the first set of traces
along a first dimension of a twodimensional coordinate system;
[21D] forming the second set of traces
closer to the source of capacitive
coupling than the first set of traces and
spatially separated from the first set of
traces by a dielectric,
[21E] the second set of traces having
one or more widths including a
minimum width, the minimum width
of the second set of traces being
substantially greater than the
maximum width of the first set of
traces at least at an intersection of the
first and second sets of traces to
provide shielding for the first set of
traces,
[21F] the second set of traces
configured for being driven by low
impedance driver outputs;

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Gerpheide ’658
net voltage changes across the mutual capacitances which exist between virtual Y and virtual
X electrodes. Charges proportional to these voltage changes multiplied by the appropriate
capacitance values are thereby coupled onto nodes CP and CN (the "coupled charges"). The
charge transfer circuit therefore supplies a proportional differential charges at outputs Qol
and Qo2, which are proportional to the coupled charges and thus to the capacitances.” Id.
See [1B] and [21B].

See [1C] and [21B].

See [1D].

See [1C], [1D], and [1D].
To the extent Gerpheide ’658 does not explicitly disclose this element, one of ordinary skill
in the art would understand that it is inherent in the shielding electrode arrangement
disclosed in Gerpheide ’658 that the second set of traces are configured for being driven by
low impedance driver outputs. To the extent Gerpheide ’658 does not inherently or
otherwise disclose this element, modifying Gerpheide ’658 to drive the shielding traces by a
low impedance driver output would have been a simple design choice representing a trivial
and predictable variation that would yield predictable results. Moreover, to the extent
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U.S. Patent No. 7,920,129

[21G] and orienting the second set of
traces along a second dimension of the
two-dimensional coordinate system to
form sensors at locations at which the
first set of traces intersects with the
second set of traces while separated by
the dielectric.
[22] The method of claim 21, further
comprising widening the drive traces
to substantially electrically isolate the
sense traces from a liquid crystal
display (LCD).
[24A] A capacitive touch sensor
panel, comprising:
[24B] sense traces formed on a first
layer and arranged along a first
dimension of a two-dimensional
coordinate system;
[24C] and drive traces formed on a
second layer spatially separated from
the first layer by a dielectric, the drive
traces arranged along a second
dimension of the two-dimensional
coordinate system;
[24D] wherein the drive traces are
widened as compared to the sense
traces to substantially cover the second
layer except for a gap between
adjacent drive traces so as to
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Gerpheide ’658
Gerpheide ’658 does not disclose this element, substituting a low impedance driver output
for the disclosed arrangement would have been simple substitution of one known element for
another to obtain predictable results, i.e., shielding.
See [1C] and [1E].

See [3].

See [3].
See [1B], [10B] and [21B].

See [1C] and [10C].

See [1D], [3], [10B], and [10C].

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U.S. Patent No. 7,920,129
substantially electrically isolate the
sense traces from a liquid crystal
display (LCD);
[24E] wherein sensors are formed at
locations at which the sense traces
intersect with the drive traces while
separated by the dielectric;
[24F] and wherein each of the drive
traces is of a substantially constant
width.
[25A] A method for shielding a
capacitive touch sensor panel from
coupling of modulated signals,
comprising:
[25B] forming a first set of sense
traces on a first layer;
[25C] orienting the sense traces along
a first dimension of a two-dimensional
coordinate system;
[25D] forming a second set of
widened drive traces on a second layer
spatially separated from the first layer,
the drive traces widened as compared
to the sense traces to substantially
cover the second layer except for a gap
between adjacent drive traces so as to
substantially electrically isolate the
first set of sense traces from a liquid
crystal display (LCD);
[25E] and orienting the drive traces
along a second dimension of the twodimensional coordinate system to form
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Gerpheide ’658

See [1E] and [10E].

See [10C].

See [1A], [1D], [2A], and [2B].

See [1B] and [10B].
See [1B] and [10B].

See [1C], [3], [1D], [10B], and [10C].

See [1C], [1E], [10B], and [10C].

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U.S. Patent No. 7,920,129
sensors at locations at which the sense
traces intersect with the drive traces;
[25F] wherein each of the drive traces
is of a substantially constant width.
[26A] A touch sensitive computing
system, comprising:
[26B] a touch processor;
[26C] a display;
[26D] a touch sensor panel adjacent to
the display and coupled to the touch
processor,
[26E] the touch sensor panel
including sense traces formed on a
first layer, and drive traces formed on
a second layer spatially separated from
the first layer,
[26F] the drive traces widened as
compared to the sense traces to
substantially cover the second layer
except for a gap between adjacent
drive traces so as to substantially
electrically isolate the sense traces
from a liquid crystal display (LCD),
[26G] wherein sensors are formed at
locations at which the sense traces
intersect with the drive traces;
[26H] and wherein each of the drive
traces is of a substantially constant
width.
[28] The touch sensitive computing
system of claim 26, wherein the
computing system is incorporated into
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Gerpheide ’658

See [1C] and [10C].
See [5].
Gerpheide ’658 discloses a touch processor. See, e.g., id. at Fig. 1, 4.
Gerpheide ’658 discloses a display. See [2A].
See [2A]-[2B].

See [1B], [1C], [10B], and [10C].

See [1D], [3], [10B], and [10C].

See [1E], [10E], and [21E].

See [1C] and [10C].

See [5] and [7].
To the extent Gerpheide ’658 does not inherently disclose this limitation, incorporating the
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U.S. Patent No. 7,920,129
a media player.

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Gerpheide ’658
computing system of claim 26 into a digital media player would have been obvious to one of
ordinary skill in the art. Incorporating the computing system of claim 26 into a digital media
player would have been a simple design choice representing a trivial and predictable
variation that would yield predictable results.

25