PTAB

IPR2013-00066

ChiMei Innolux Corp v. Semiconductor Energy Laboratory Co Ltd

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1. Case Identification

2. Patent Overview

  • Title: Electronic Apparatus with a Flexible Printed Circuit and a Transparent Conductive Layer
  • Brief Description: The ’413 patent describes an electronic display apparatus, such as a liquid crystal display (LCD), designed to mitigate display defects. The technology specifically addresses uneven brightness or color caused by height differences where external connection lines cross over a sealant to connect with a flexible printed circuit (FPC). The invention purports to solve this by using adjustment layers to level the surface and by including auxiliary wiring to reduce the electrical resistance of the external connection lines.

3. Grounds for Unpatentability

Ground 1: Obviousness over APA and Sukegawa - All challenged claims (1-2, 4-7, 9-11, 13-18, 20-22, 24-25, and 27-29) are obvious over Admitted Prior Art in view of Sukegawa.

  • Prior Art Relied Upon: Admitted Prior Art ("APA") from the ’413 patent itself and Sukegawa (Patent 5,636,329).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the APA (based on Figs. 13 and 14 of the ’413 patent) discloses the foundational structure of the challenged claims, including an LCD with a substrate, wiring, insulating films, an FPC, and a sealant separating internal and external circuits. The petitioner argued that the allegedly novel features, such as a multi-layer wiring structure with an auxiliary line to reduce resistance, were already taught by Sukegawa. Sukegawa was argued to disclose a multi-layer connection with a lower metal wiring (first wiring), an interlayer insulating film, and an upper metal wiring (second wiring), which achieves the same benefits of reduced resistance and improved connection security claimed in the ’413 patent. The petitioner’s expert, Dr. Hatalis, supported the assertion that Sukegawa’s structure maps directly onto the elements recited in the challenged claims.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) reviewing the display structure in the APA would recognize the known problem of high resistance in long external connection lines. Petitioner argued that a POSITA would have been motivated to look for solutions and would have found Sukegawa, which explicitly teaches using a multi-layer wiring structure to reduce resistance and prevent peeling in LCD terminal connections. Therefore, applying Sukegawa’s teachings to the APA’s display was presented as a combination of known elements to solve a known problem for a predictable result.
    • Expectation of Success: Petitioner contended there would have been a high expectation of success because both the APA and Sukegawa relate to conventional LCD manufacturing. Implementing Sukegawa's established wiring structure within the standard display configuration of the APA would involve routine techniques and was expected to yield the predictable benefits described in Sukegawa.

Ground 2: Obviousness over Sukegawa and Nakamoto - All challenged claims (1-2, 4-7, 9-11, 13-18, 20-22, 24-25, and 27-29) are obvious over Sukegawa in view of Nakamoto.

  • Prior Art Relied Upon: Sukegawa (Patent 5,636,329) and Nakamoto (Japanese Patent Publication No. H08-160446).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented Sukegawa as the primary reference teaching the core multi-layer structure, including a first wiring, first insulating film, second wiring, second insulating film, and a transparent conductive layer connecting to an FPC. Petitioner argued that Sukegawa teaches nearly all claimed elements. Nakamoto was introduced as a secondary reference that describes another configuration for connecting an LCD display with a tape carrier package, disclosing a sealant over signal lines and insulating layers. Petitioner asserted that Nakamoto reinforces the conventionality of using sealants and layered structures in the manner claimed.
    • Motivation to Combine: The petitioner argued that a POSITA starting with Sukegawa’s design would be motivated to combine it with the teachings of Nakamoto to achieve a robust and manufacturable connection. Nakamoto shows how to integrate a sealant with the terminal connection area, a common requirement in LCD panel assembly. A POSITA would combine the specific layered wiring of Sukegawa with the sealant configuration of Nakamoto to produce the claimed device, as it represented a simple and logical combination of known display manufacturing techniques.
    • Expectation of Success: Success was argued to be highly probable, as the combination involves integrating two well-understood technologies for LCD fabrication. The function of each element (Sukegawa's wiring, Nakamoto's sealant) remains the same in the combined device, leading to predictable results.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the PTAB should issue a standing order to manage a co-pending continuation application related to the ’413 patent. This request was made to prevent the Patent Owner from prosecuting patentably indistinct claims in the continuation application as an "end-around" to the IPR proceeding. Petitioner cited the Patent Owner's alleged history of "egregious conduct" in other proceedings as justification for the requested order, which would require the Patent Owner to provide notice of the IPR to the Examiner of the continuation application and to remind the Examiner of any estoppel impact from the IPR.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-2, 4-7, 9-11, 13-18, 20-22, 24-25, and 27-29 of Patent 7,876,413 as unpatentable.