PTAB

IPR2015-00913

Sharp Corp v. Surpass Tech Innovation LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Liquid Crystal Display Driving Device of Matrix Structure Type and Its Driving Method
  • Brief Description: The ’550 patent discloses a liquid crystal display (LCD) driving device. The alleged invention is a specific circuit architecture where, in each column of thin-film transistors (TFTs), a first data line connects to TFTs in odd-numbered rows and a second data line connects to TFTs in even-numbered rows (an "Odd Row/Even Row" configuration) to improve the display quality of moving images.

3. Grounds for Unpatentability

Ground 1: Anticipation over Sharp Reference - Claims 1-3 are anticipated by the Sharp Reference under 35 U.S.C. §102.

  • Prior Art Relied Upon: Sharp Reference (Japanese Patent Application Publication No. H08-305322).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the Sharp Reference disclosed every element of claims 1-3. Specifically, Petitioner asserted that Figure 10 of the Sharp Reference taught an LCD device with the claimed "Odd Row/Even Row" configuration, where first and second source bus lines connect to TFTs in odd and even rows, respectively. Crucially, Petitioner contended that Sharp disclosed connecting the data lines within each column group to the same source driver, the very limitation added during prosecution to overcome a rejection over different prior art. The Sharp Reference was also alleged to teach source drivers installed on the same side of the display and data transfer switched by sampling switches, meeting limitations of dependent claims 2 and 3.
    • Key Aspects: The core of this ground was that the dispositive claim limitation added during prosecution—connecting paired data lines to the same source driver—was explicitly taught by the Sharp Reference, which was not considered by the Examiner.

Ground 2: Obviousness over Sharp Reference and Kamizono - Claims 1-5 are obvious over the Sharp Reference in view of Kamizono under 35 U.S.C. §103.

  • Prior Art Relied Upon: Sharp Reference (Japanese Patent Application Publication No. H08-305322), Kamizono (Patent 6,407,795).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the Sharp Reference provided the foundational LCD architecture, including the matrix array, drivers, and the "Odd Row/Even Row" configuration, as asserted in Ground 1. Kamizono was introduced to provide teachings for the limitations of dependent claims 4 and 5. Specifically, Kamizono taught that for large-screen LCDs, mounting gate drivers as a "chip on glass" (COG) (claim 4) was a preferred method for increased reliability and reduced product size. Kamizono also taught forming an "integrated gate driver circuit installed on glass" (claim 5) by mounting drivers on the panel substrate.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references because both addressed the same technical problem: improving the performance and manufacturability of large-sized LCD panels. A POSITA would have been motivated to implement the known and preferred driver mounting techniques from Kamizono (COG, integrated circuits) into the large-screen display architecture of the Sharp Reference to achieve predictable benefits like improved reliability and a smaller form factor.
    • Expectation of Success: The combination was presented as a predictable substitution of known elements, yielding no unexpected results. Applying Kamizono’s COG method to Sharp's display would predictably improve the display's form factor without altering the function of the "Odd Row/Even Row" configuration.

Ground 3: Obviousness over Shimada and Kamizono - Claims 1-5 are obvious over Shimada in view of Kamizono under §103.

  • Prior Art Relied Upon: Shimada (Patent 6,081,250), Kamizono (Patent 6,407,795).

  • Core Argument for this Ground:

    • Prior Art Mapping: As an alternative to the Sharp Reference, Petitioner argued that Shimada taught all key elements of claims 1-3. Shimada allegedly disclosed the "Odd Row/Even Row" configuration, connecting paired data lines to the same source driver, and installing the source driver on the same side of the display. Similar to Ground 2, Kamizono was then used to supply the teachings for claims 4 and 5, namely the use of COG and integrated gate drivers on glass for large-screen LCDs.
    • Motivation to Combine: The motivation was analogous to the previous ground. Both Shimada and Kamizono focused on improving large-screen LCDs. Shimada taught using the "Odd Row/Even Row" layout to reduce signal delay in larger devices, while Kamizono taught that increasing panel size necessitates additional driver ICs and that COG is a preferred implementation. A POSITA would have been motivated to combine Kamizono’s efficient driver implementation with Shimada’s display architecture to create a better large-screen LCD.
    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success, as the combination involved applying a known technique (Kamizono's driver mounting) to improve a similar device (Shimada's display) in a predictable manner.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 2) for claims 1-3 and 5 over the Sharp Reference alone. This ground argued that even if Sharp were interpreted to show only a single driver, the mere duplication of drivers to support a larger display would have been an obvious design choice that produced no unexpected result.

4. Key Claim Construction Positions

  • "Insulated with each other": For the claim phrases "gate lines . . . insulated with each other" and "data lines . . . insulated with each other," Petitioner proposed the construction "spaced apart from and parallel to each other." This construction was based on the patent's figures and was argued to be necessary to map the physical layouts shown in the prior art to the claim language.
  • "Gate Drivers" and "Source Drivers": Petitioner argued that under the broadest reasonable construction, these plural terms should encompass one or more driver circuits. This could mean multiple distinct driver ICs or a single circuit block with multiple outputs, a construction Petitioner contended was consistent with the prior art and prosecution history.

5. Arguments Regarding Discretionary Denial

  • Petitioner noted that a previous petition on the ’550 patent (IPR2015-00022) was denied institution due to a lack of expert declaration. Petitioner argued that this petition should not be denied on similar grounds because it relied on "completely new grounds," including prior art not previously considered, and was fully supported by an expert declaration, thereby overcoming the deficiency of the earlier filing.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-5 of Patent 7,420,550 as unpatentable.