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 2

EXHIBIT P-9
SAMSUNG’S INVALIDITY CLAIM CHARTS FOR A.K. LEEPER, “INTEGRATION OF A CLEAR
CAPACITIVE TOUCH SCREEN WITH A 1/8-VGA FSTN-LCD TO FORM LCD-BASED TOUCHPAD”
(“LEEPER”)
U.S. Patent No. 7,663,607
[1A] A touch panel comprising a
transparent capacitive sensing medium
configured to detect multiple touches
or near touches that occur at a same
time and at distinct locations in a plane
of the touch panel and to produce
distinct signals representative of a
location of the touches on the plane of
the touch panel for each of the
multiple touches,

Leeper4
Leeper teaches a touch panel comprising a transparent capacitive sensing medium (e.g.,
Synaptics Capacitive TouchPad Sensor of Figure 2) configured to detect multiple touches or
near touches that occur at a same time and at distinct locations in a plane of the touch panel
and to produce distinct signals representative of a location of the touches on the plane of the
touch panel for each of the multiple touches.

Leeper states: “The Synaptics ClearPad is a unique and innovative touch screen for personal
computers and portable handheld devices. The clear and thin sensing surface allows
Synaptics proven capacitive touch sensing technology to be placed upon any surface without
impacting the view-ability of the underlying component. Capacitive finger sensing is far
4

Leeper describes a commercial product from Synaptics Incorporated called the ClearPad (or cPad). This commercial product is
also an invalidating reference in its own right. The invalidity analysis for this commercial product is believed to be identical (or
substantially similar) to the analysis shown here. Samsung is in the process of requesting additional information about the ClearPad
from Synaptics Incorporated and reserves the right to supplement this Exhibit after that information is received.
103

U.S. Patent No. 7,663,607

Leeper4
more sensitive than all other transparent membrane touch technologies.” Id. at 187.
“The Synaptics ClearPad is based on the same principles of operation as a standard Synaptics
TouchPad (see Figure 2). The touch sensor is comprised of two arrays of sensor traces
perpendicular to one another, separated by an insulating material, and covered by insulating
surface material. To form a clear sensor, the traces are made of a clear conductor such as
indium tin oxide (ITO) and the insulation layers consist of optically clear adhesives and clear
polyethylene terephthalate (PET), a plastic resin and a form of polyester. Each trace
possesses a capacitance to free space that can be measured by the controlling circuitry” Id. at
188.
“Synaptics’ proprietary ASIC utilizes a custom analog circuit to measure trace
capacitance…. the controller is capable of computing finger pressure as an increase in the
finger contact area (thereby adding capacitance to more traces), as well as detecting the
presence of multiple fingers.” Id. at 188.

[1B] wherein the transparent
capacitive sensing medium comprises:
a first layer having a plurality of
transparent first conductive lines that
are electrically isolated from one
another; and

Leeper teaches a transparent capacitive sensing medium (e.g., Synaptics Capacitive
TouchPad Sensor of Figure 2) comprising a first layer (e.g., first array of sensor traces of
Figure 2) having a plurality of transparent first conductive lines that are electrically isolated
from one another.

[1C] a second layer spatially
separated from the first layer and
having a plurality of transparent
second conductive lines that are
electrically isolated from one another,

Leeper teaches a second layer (e.g., second array of sensor traces of Figure 2) spatially
separated from the first layer and having a plurality of transparent second conductive lines
that are electrically isolated from one another.

See [1A].

See [1A].

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U.S. Patent No. 7,663,607
[1D] the second conductive lines
being positioned transverse to the first
conductive lines,

Leeper4
Leeper teaches the second conductive lines being positioned transverse to the first
conductive lines.

[1E] the intersection of transverse
lines being positioned at different
locations in the plane of the touch
panel, each of the second conductive
lines being operatively coupled to
capacitive monitoring circuitry;

Leeper teaches the intersection of transverse lines being positioned at different locations in
the plane of the touch panel, each of the second conductive lines being operatively coupled
to capacitive monitoring circuitry (e.g., custom analog circuit, controlling circuitry and/or
module PCB).

See [1A].

Leeper states: “The presence of a finger changes the capacitance of the nearest traces by
about 10%. This capacitance change is measured by the controlling circuitry and finger
position is computed from this information.” Id. at 188.
“Synaptics’ proprietary ASIC utilizes a custom analog circuit to measure trace capacitance.
This involves the controller outputting a fixed current over a set time period and then
measuring the resultant voltage on each trace. Because finger presence is computed by
changes in trace array capacitances, the controller is capable of computing finger pressure as
an increase in the finger contact area (thereby adding capacitance to more traces), as well as
detecting the presence of multiple fingers.” Id.
“To minimize transcapacitance and maximize sensor performance, the ClearPad sensor was
transformed from a single sensor trail design into a double tail design with separate
connections for the x and y sensor traces. This resulted in four individual tails that needed to
be joined to the cPad module PCB (x/y tails of the LCD and the x/y tails of the ClearPad
sensor).” Id.

[1F] wherein the capacitive
monitoring circuitry is configured to
detect changes in charge coupling
between the first conductive lines and
the second conductive lines.

Leeper teaches the claimed touch panel wherein capacitive monitoring circuitry (e.g., custom
analog circuit and/or cPad module PCB) is configured to detect changes in charge coupling
between the first conductive lines and the second conductive lines.
See [1E].
105

Leeper4

U.S. Patent No. 7,663,607

[2] The touch panel as recited in claim Leeper teaches the touch panel as recited in claim 1 wherein the conductive lines on each of
1 wherein the conductive lines on each the layers are substantially parallel to one another.
of the layers are substantially parallel
to one another.
See [1A].
[3] The touch panel as recited in claim Leeper teaches the touch panel as recited in claim 2 wherein the conductive lines on different
2 wherein the conductive lines on
layers are substantially perpendicular to one another.
different layers are substantially
perpendicular to one another.
See [1A].
[6] The touch panel as recited in claim Leeper teaches the touch panel as recited in claim 1 wherein the conductive lines are formed
1 wherein the conductive lines are
from indium tin oxide (ITO).
formed from indium tin oxide (ITO).
Leeper states: “To form a clear sensor, the traces are made of a clear conductor such as
indium tin oxide (ITO) and the insulation layers consist of optically clear adhesives and clear
polyethylene terephthalate (PET), a plastic resin and a form of polyester.” Id. at 188.
[7] The touch panel as recited in claim Leeper teaches the touch panel as recited in claim 1, wherein the capacitive sensing medium
1, wherein the capacitive sensing
is a mutual capacitance sensing medium.
medium is a mutual capacitance
sensing medium.
See [1E].
[8] The touch panel as recited in claim Leeper teaches the touch panel as recited in claim 7, further comprising a virtual ground
7, further comprising a virtual ground charge amplifier coupled to the touch panel for detecting the touches on the touch panel.
charge amplifier coupled to the touch
panel for detecting the touches on the
See [1E].
touch panel.
To the extent a virtual ground charge amplifier is not expressly disclosed or inherent in the
proprietary ASIC or controlling circuitry disclosed in Leeper, the use of a virtual ground
106

U.S. Patent No. 7,663,607

[10A] A display arrangement
comprising: a display having a screen
for displaying a graphical user
interface; and

Leeper4
charge amplifier coupled to the touch panel would have been obvious to one of ordinary skill
in the art as a predictable variant and a matter of simple implementation design. For
example, Perski ’455 shows a virtual ground charge amplifier coupled to the touch panel for
detecting the touches on the touch panel. See Exhibit P-1, [8]. Because both Perski ’455
and Leeper describe very similar transparent capacitive touchscreens, it would have been
obvious to include the charge amplifier of Perski ’455 into the Leeper design in order to filter
the signals obtained from the touchscreen from stray or parasitic noise, as is common in
signal processing techniques. The resulting implementation would have been a predictable
variation well within the purview of one of ordinary skill in the art.
Leeper teaches a display arrangement comprising a display (e.g., LCD of Figure 1) having a
screen for displaying a graphical user interface.

See [1A].
Leeper states: “Synaptics cPad, as pictured in Figure 1, is the trade name given to a specific
application of the ClearPad sensor over a 40 by 60mm 1/8 VGA (240 x 160 pixel) LCD
designed to function as an enhanced PC notebook TouchPad.”
[10B] a transparent touch panel
allowing the screen to be viewed
therethrough and capable of
recognizing multiple touch events that

Leeper teaches a transparent touch panel allowing the screen to be viewed therethrough and
capable of recognizing multiple touch events that occur at different locations on the touch
panel at a same time and to output this information to a host device to form a pixilated
image.
107

U.S. Patent No. 7,663,607
occur at different locations on the
touch panel at a same time and to
output this information to a host
device to form a pixilated image;
[10C] wherein the touch panel
includes a multipoint sensing
arrangement configured to
simultaneously detect and monitor the
touch events and a change in
capacitive coupling associated with
those touch events at distinct points
across the touch panel; and
[10D] wherein the touch panel
comprises: a first glass member
disposed over the screen of the
display;

Leeper4
See [1A].

Leeper teaches the claimed touch panel including a multipoint sensing arrangement
configured to simultaneously detect and monitor the touch events and a change in capacitive
coupling associated with those touch events at distinct points across the touch panel.
See [1A].

Leeper teaches the claimed touch panel comprising a first glass member (e.g., substrate of
Figure 2) disposed over the screen of the display.
See [1A].
Even if Leeper did not expressly disclose a first glass member disposed over the screen of
the display, the use of such a glass member would have been obvious to one of ordinary skill
in the art as a simple design choice representing a trivial and predictable variation. Glass
was already widely used as a transparent substrate in many touchscreen designs, and the
plastic resins disclosed by Leeper were readily interchangeable with glass members. See
Exhibit P-1, [10D].

[10E] a first transparent conductive
layer disposed over the first glass
member,

Leeper teaches a first transparent conductive layer disposed over the first glass member.

[10F] the first transparent conductive
layer comprising a plurality of spaced

Leeper teaches the first transparent conductive layer comprising a plurality of spaced apart
parallel lines having the same pitch and linewidths.

See [1A].

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U.S. Patent No. 7,663,607
apart parallel lines having the same
pitch and linewidths;
[10G] a second glass member
disposed over the first transparent
conductive layer;

Leeper4
See [1A].
Leeper teaches a second glass member (e.g., insulating layer) disposed over the first
transparent conductive layer.
See [1A].
Even if Leeper did not expressly disclose a second glass member disposed over the first
transparent conductive layer, such an arrangement would have been obvious to one of
ordinary skill in the art as a simple design choice representing a trivial and predictable
variation. Glass was already widely used as a transparent substrate in many touchscreen
designs, and the plastic resins disclosed by Leeper were readily interchangeable with glass
members. See Exhibit P-1, [10D].

[10H] a second transparent
conductive layer disposed over the
second glass member,

[10I] the second transparent
conductive layer comprising a
plurality of spaced apart parallel lines
having the same pitch and linewidths,

Leeper teaches a second transparent conductive layer disposed over the second glass
member.
See [1A].
Even if Leeper did not expressly disclose a second transparent conductive layer disposed
over the second glass member, such an arrangement would have been obvious to one of
ordinary skill in the art as a simple design choice representing a trivial and predictable
variation. Glass was already widely used as a transparent substrate in many touchscreen
designs and the sensor traces disclosed in Leeper are transparent. See Exhibit P-1, [10D].
Leeper teaches the second transparent conductive layer comprising a plurality of spaced
apart parallel lines having the same pitch and linewidths.
See [1A].

109

U.S. Patent No. 7,663,607
[10J] the parallel lines of the second
transparent conductive layer being
substantially perpendicular to the
parallel lines of the first transparent
conductive layer;
[10K] a third glass member disposed
over the second transparent conductive
layer; and

Leeper4
Leeper teaches the parallel lines of the second transparent conductive layer being
substantially perpendicular to the parallel lines of the first transparent conductive layer.
See [1A].
Leeper teaches a third glass member disposed over the second transparent conductive layer.
See [1A].
Even if Leeper did not expressly a third glass member disposed over the second transparent
conductive layer, such an arrangement would have been obvious to one of ordinary skill in
the art as a simple design choice representing a trivial and predictable variation. Glass was
already widely used as a transparent substrate in many touchscreen designs, and the plastic
resins disclosed by Leeper were readily interchangeable with glass members. See Exhibit P1, [10D].

[10L] one or more sensor integrated
circuits operatively coupled to the
lines.

Leeper teaches one or more sensor integrated circuits operatively coupled to the lines.

[11] The display arrangement as
recited in claim 10 further including
dummy features disposed in the space
between the parallel lines, the dummy
features optically improving the visual
appearance of the touch screen by
more closely matching the optical
index of the lines.

Leeper teaches the display arrangement as recited in claim 10 further including dummy
features disposed in the space between the parallel lines, the dummy features optically
improving the visual appearance of the touch screen by more closely matching the optical
index of the lines.

See [1E].

See [1A].
Since Leeper clearly contemplates a transparent sensor in the form of a touchscreen, it would
have been obvious to one of ordinary skill in the art to incorporate “dummy features” that
optically improve the visual appearance of the touchscreen by more closely matching the
optical index of the lines, as taught by Perski ’455, Morag ’229 (Col. 12:64-13:32), or
Mackey ’935 (Col. 8:17-39), in order to reduce the visual differences between the conducting
110

U.S. Patent No. 7,663,607

Leeper4
and non-conducting areas. See, e.g., Exhibit P-1, [11]. In addition, both Leeper and
Mackey ’935 describe products by the same manufacturer and are assigned or authored by
the same entity (Synaptics Incorporated), providing yet another reason one skilled in the art
would combine the teachings of the references.

111