UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before The Honorable Bryan F. Moore
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN ACTIVE MATRIX
`ORGANIC LIGHT-EMITTING DIODE
`DISPLAY PANELS AND MODULES
`FOR MOBILE DEVICES, AND
`COMPONENTS THEREOF
`
`Investigation No. 337-TA-1351
`
`RESPONDENT MIANYANG BOE’S MOTION IN LIMINE NO. 2:
`
`TO STRIKE PORTIONS OF TESTIMONY REGARDING U.S. PATENT
`NO. 7,414,599 IN THE DIRECT WITNESS STATEMENT OF SDC’S
`EXPERT DR. FONTECCHIO
`
`Pursuant to 19 C.F.R. § 210.15 and Ground Rule 11.3, Respondent Mianyang BOE
`
`Optoelectronics Co., Ltd. (“BOE” or “Respondent”) hereby moves in limine to strike and preclude
`
`portions of testimony in the Direct Witness Statement of Samsung Display Co., Ltd.’s (“SDC” or
`
`“Complainant”) expert Dr. Adam Fontecchio.
`
`Ground Rule 5.1 Certification
`
`Pursuant to Ground Rule 5.1, Respondent Mianyang BOE certifies that it has met and
`
`conferred regarding the content of this motion. Complainant Samsung Display Co. Ltd. (“SDC”)
`
`indicated that it would oppose the motion and Staff has indicated that he will take a position after
`
`reviewing the papers.
`
`

`

`TABLE OF CONTENTS
`
`Page
`
`I.
`
`II.
`
`INTRODUCTION ............................................................................................................ 1
`
`ARGUMENT ..................................................................................................................... 2
`
`A.
`
`B.
`
`C.
`
`
`The ALJ Should Strike Dr. Fontecchio’s New Opinion That
` (Ex. 1 at
` Is Representative Of
`Q85, 88, 94 and Q177-179, Q184-193, Q197-199, and Q205-209) .......................... 2
`
`The ALJ Should Strike Dr. Fontecchio’s New Theory That
` Is Representative Of SDC’s
` Domestic
`Industry Products (Ex. 1 at Q394-405) .................................................................... 6
`
`
`
`The ALJ Should Strike Dr. Fontecchio’s New Allegation That Dr. Foty’s
`Opinions That Sakamoto Invalidates Claim 7 Are Inconsistent with His
`Position with Respect to BOE’s Redesigns (Ex. 6 at Q130-131) .............................. 9
`
`III.
`
`CONCLUSION ................................................................................................................ 10
`
`i
`
`

`

`Ex. No.
`
`Exhibit Description
`
`TABLE OF EXHIBITS
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`Direct Witness Statement of Dr. Fontecchio, CX-1629C-NCT
`
`Joint Stipulation Regarding Representative Products, EDIS ID No. 808453
`
`Excerpts of Initial Expert Report of Dr. Fontecchio,
`CX-1327C-NCT, CX-1328C-NCT, CX-1331C-NCT, CX-1340C-NCT-PSC
`
`U.S. Patent No. 7,414,599, JX-0001
`
`Excerpts of Rebuttal Expert Report of Dr. Foty, CX-3972C
`
`Rebuttal Witness Statement of Dr. Fontecchio, CX-1242C-NCT
`
`Excerpts of Rebuttal Expert Report of Dr. Fontecchio, CX-1341C-PSC_NCT, CX-
`1342C-PSC_NCT
`
`ii
`
`

`

`Pursuant to 19 C.F.R. § 210.15 and Ground Rule 11.3, Respondent Mianyang BOE
`
`Optoelectronics Co., Ltd. (“BOE”) moves in limine to strike portions of the Witness Statements of
`
`Samsung Display Co., Ltd.’s (“SDC”) expert, Dr. Fontecchio, (Ex. 1) containing opinions that are
`
`both new and inconsistent with the parties’ stipulation concerning representative products.
`
`I.
`
`INTRODUCTION
`
`Pursuant to the schedule the ALJ set in Order No. 11, on November 13, 2023 SDC and BOE
`
`filed a Joint Stipulation Regarding Representative Products. EDIS ID No. 808453 (“Representative
`
`Product Stipulation”) (for convenience, attached as Ex. 2). With respect to U.S. Patent No. 7,414,599
`
`(the “’599 Patent”) the parties agreed
`
`
`
`. The parties agreed to a
`
`single “representative” product for each group of accused and domestic industry products.
`
`The Representative Product Stipulation allowed the parties to simplify the dispute. If SDC
`
`met its burden to prove that a representative product practiced a claim, then each of the corresponding
`
`products in that group would also be deemed to practice that claim. If SDC failed to prove that a
`
`representative product practiced a claim, then none of the corresponding products in that group would
`
`be found to practice that claim.
`
`The parties agreed on
`
` because many of the
`
`
`
` products operated differently with respect to the asserted ’599 Patent claims.
`
`For example, BOE agreed that the accused
`
` was representative of the accused
`
` but not representative of
`
`.
`
`
`
`
`
`In his Witness Statement, however, Dr. Fontecchio did not consider whether each of the
`
`
`
`representative products practiced the claims of the ’599 Patent. Instead, he addressed only
`
` of the
`
` representative accused products
`
` and
`
` of the
`
` representative DI products
`
`1
`
`

`

` and then opined they were representative
`
`of
`
` of the accused and domestic industry products. This was not only a new opinion not disclosed
`
`in his expert report, but it contradicts the parties’ stipulation.
`
`Thus, BOE respectfully requests that the ALJ strike Dr. Fontecchio’s opinions that products
`
`in groups that do not correspond to the representative products he addressed practice the ’599 Patent’s
`
`claims. See G.R. 9 (expert reports “shall contain a complete statement of all opinions to be expressed
`
`and the basis and reasons therefor”) and G.R. 13.6.6 (limiting an “expert’s testimony at the trial… in
`
`accordance with the scope of the expert’s report(s) and deposition testimony”); see also Certain Flash
`
`Memory Chips, Inv. No. 337-TA-893, Order No. 41, 2014 WL 5386815, at *2 (Sept. 25, 2014) (striking
`
`portions of expert witness statement not disclosed in expert report); Certain Video Analytics Software,
`
`Inv. No. 337-TA-795, Order No. 33, 2012 WL 2930760, at *1 (July 16, 2012) (same).
`
`II.
`
`ARGUMENT
`
`A.
`
`The ALJ Should Strike Dr. Fontecchio’s New Opinion That
` Is Representative Of
`Q85, 88, 94 and Q177-179, Q184-193, Q197-199, and Q205-209)
`
`
` (Ex. 1 at
`
`The Representative Product Stipulation divided the BOE products accused of infringing the
`
`’599 Patent into
`
`. The parties agreed that
`
` is representative of
`
` and that it was
`
` representative of the other accused products
`
`:
`
`
`
`
`
`Ex. 2 at 3.
`
`2
`
`

`

`Thus, to meet its burden to prove infringement of the
`
` products, SDC must
`
`separately address BOE’s accused
`
` products and prove
`
`that each product meets every limitation of an asserted claim.
`
`In his opening expert report, SDC’s expert, Dr. Fontecchio, sought to meet this burden by
`
`providing discrete opinions separately analyzing each representative accused product. See Ex. 3
`
`¶¶ 209-387
`
`, ¶¶ 414-580
`
`, ¶¶ 609-621
`
`, ¶¶ 623-696
`
`, App. D ¶¶ 1-177
`
`, and ¶¶ 698-870
`
`. In his expert report, Dr. Fontecchio did
`
`opine that
`
`
`
`was representative of the
`
`. Id.
`
`In his Witness Statement, Dr. Fontecchio provides 34 pages of testimony as to why he believes
`
`the accused
`
` displays each meet every limitation of the asserted claims of the ’599
`
`Patent. See Ex. 1 at Q95-175 and Q217-249. He addressed
`
` because they
`
`are not representative of each other.
`
` Thus, in a single
`
`answer, he opines that
`
` infringe for the same reason as
`
`
`
` because the parties had stipulated that
`
`, this testimony
`
`Id. at Q176. While BOE disputes that
`
`is appropriate.
`
`Dr. Fontecchio also opines that the other accused displays also infringe the asserted claims of
`
`the ’599 Patent. But his Witness Statement does
`
`explain how any of the other three representative
`
`products allegedly meet each limitation of any asserted claim. Instead, Dr. Fontecchio testifies that,
`
`for example,
`
` (and the products they are representative of) allegedly infringe because
`
`“each contain a pixel circuit that has the same relevant structure as
`
`” and, thus,
`
`“infringe claims 2, 3, 13, 15, and 16 of the ’599 Patent for the same reasons that I explained with
`
`respect to
`
`.” Ex. 1 at Q178; see also Q193 (“
`
` product infringes claims 3, 13,
`
`and 15 of the ’599 Patent for the same reasons that I explained with respect to
`
`.”),
`
`3
`
`

`

`Q206 (“it is my opinion that
`
` product and
`
` have the same arrangement of
`
`circuit elements described in the claim limitations of the asserted claims, and that
`
`
`
`product therefore infringes claims 2, 3, 13, 15, and 16 of the ’599 Patent for the same reasons that I
`
`explained with respect to
`
`.”).
`
`In other words, the
`
`basis for Dr. Fontecchio’s opinion that BOE’s
`
`
`
` products (and the
`
` displays of which they are representative)
`
`infringe the ’599 Patent is because he believes that the
`
` displays infringe. These opinions
`
`should be struck for two reasons. First, the parties stipulated
`
` is
`
` representative of these
`
`other accused devices and thus, even were
`
` infringe, that does not establish that the other devices
`
`infringe. See Ex. 2 at 3 (Representative Product Stipulation). Second, Dr. Fontecchio did not disclose
`
`in his expert report any opinion that
`
` infringe for the same reason
`
`. See Ex. 3; G.R. 13.6.6 (limiting an “expert’s testimony at the trial… in accordance with the
`
`scope of the expert’s report(s) and deposition testimony”).
`
`BOE would be prejudiced were Dr. Fontecchio permitted to introduce entirely new opinions
`
`that contradict the parties’ Representative Product Stipulation. For example, one reason that, as the
`
`parties agreed,
`
` because the asserted
`
`claims of the ’599 Patent require three input signals with a specific timing relationship (a “current scan
`
`signal,” a “scan signal just before the current scan signal,” and a “current light-emitting signal”). See,
`
`e.g., Ex. 4 at 8:53-9:12 (claims 1 and 2) and Fig. 4. As explained by BOE’s expert, Dr. Foty,
`
`
`
`failure to even consider the timing issue means his infringement analysis fails.1 See, e.g., Ex. 5 (CX-
`
` and Dr. Fontecchio’s
`
`1 Dr. Fontecchio’s opening report merely mentioned timing in the context of these
`
` as follows: (i) a reference to an unidentified “timing diagram” in the infringement allegations
`with respect to claim 2 against
` (Ex. 3 ¶ 465); (ii) an inclusion of
` timing
`diagram in the infringement allegations with respect to claim element 1[d] against
`
`
`4
`
`

`

`3972C, Foty Rebuttal Report) ¶¶ 228-32, 248, 252-53, 307-11, 406-07 (identifying deficiencies). After
`
`Dr. Foty’s rebuttal report identified the gaps in his infringement analysis, Dr. Fontecchio provided a
`
`new opinion in his direct witness statement and asserted, for the first time, “I have reviewed the
`
`available timing diagrams for the accused BOE products” and “the timing sequences for the
`
` products follow the same timing sequence as
`
`
`
`
`
`.”2 Ex. 1 at Q85; see also id. at Q87-88, Q94.
`
`SDC has suggested it will argue that Dr. Fontecchio’s opening expert report cited pages in
`
`BOE’s production that showed both the pixel circuit and timing diagrams. While Dr. Fontecchio
`
`referenced those pages in his expert report, he only analyzed the pixel circuit diagrams and ignored
`
`the timing diagrams. See, e.g., Ex. 3 (Fontecchio Opening Report) ¶¶ 616, 618 (no analysis of
`
` ¶¶ 701-02 (no analysis of
`
`) and App. D ¶¶ 3-5 (no analysis of
`
`
`
`).
`
`Because Dr. Fontecchio did not disclose any analysis with respect to the timing of the inputs to the
`
`accused devices in his expert report, the new opinions on this issue in his witness statement should be
`
`struck because BOE has no opportunity to respond.
`
`Thus, the ALJ should strike the new opinions in Dr. Fontecchio’s Direct Witness Statement
`
`that contradict the parties’ Representative Product Stipulation and were not disclosed in his expert
`
`report. See, e.g., G.R. 13.6.6. This includes (i) his opinions in Ex. 1 at Q177-179, Q184-193, Q197-
`
`199, Q205-209 that the
`
` products allegedly infringe for
`
` (id.
` timing diagram is applicable
`product, without any explanation as to why
`¶ 727); (iii) a reference to “that timing diagram” in the infringement allegations with respect to claim
` product (id. ¶ 748); and (iv) a discussion of signal timing and inclusion of a
`2 against
` product and claim element 1[d] and claim 2 (id. App. D
`timing diagram with respect to
`¶¶ 29-30, 52-54). The reference to an unidentified or wrong timing diagram with respect to
`
` renders their analysis deficient, and the infringement analysis
` fails to include a
`timing analysis entirely.
`
`2
`
`Dr. Fontecchio opines that “the
`also applicable to
`
`See Ex. 2 at 3. But
` timing sequence applies to
` as well….” Ex. 1 at Q86-87.
`
` (id.) and
`” and “is
`
`5
`
`

`

`the same reason as
`
` product and (ii) his new opinions in Ex. 1 at Q85, Q88, and Q94
`
`concerning the timing of the inputs to the accused products and that they are all the same as for
`
`
`
`.3
`
`B.
`
`
`The ALJ Should Strike Dr. Fontecchio’s New Theory That
` Is Representative Of SDC’s
` Domestic Industry
`Products (Ex. 1 at Q394-405)4
`
`SDC alleges that
`
` phones include SDC displays that practice claims of the ’599
`
`Patent. SDC bears the burden of establishing this domestic industry (“DI”) and SDC undeniably is
`
`in the best position to understand whether its own DI products operate the same or differently with
`
`respect to SDC’s domestic industry claims. In the Representative Product Stipulation, SDC divided
`
`its
`
` and identified a “representative” product for each group. Thus,
`
`for example, the parties agreed that if SDC proved
`
` practices the DI claims, then the displays in the
`
`
`
`
`
` also practice those DI claims. But for SDC to
`
`prove that the displays in the
`
`
`
` practice any DI claim, then SDC must prove that the display in the
`
` practices a DI claim. And the same is true for
`
`the
`
` products:
`
`3 For simplicity, BOE has focused on the substance of Dr. Fontecchio’s analysis. But throughout his
`witness statement, Dr. Fontecchio refers to and summarizes his conclusion that BOE’s
`
` products allegedly infringe. See, e.g., Ex. 1 at Q17, Q76. Such summaries and
` products (or the
`
`any opinion that the
`products for which they are representative) infringe should also be struck and BOE will work with
`SDC to prepare a redacted version of Dr. Fontecchio’s witness statement that complies with the ALJ’s
`decision on this motion.
`4 The group numbering herein is based on the parties’ Representative Product Stipulation. See Ex. 2
`at 5. Dr. Fontecchio’s Direct Witness Statement reversed the ordering of
`
`
`6
`
`

`

`Ex. 2 at 5.
`
`Consistent with this, in his opening expert report Dr. Fontecchio separately addressed each of
`
`the
`
` “Representative Products” and provided an element-by-element explanation as to why
`
`7
`
`

`

`he believed that each representative product practiced the DI claims. See Ex. 3 ¶¶ 1901-2069
`
`, ¶¶ 2090-2256
`
`
`
`
`
` ¶¶ 2280-2354
`
`, and ¶¶ 2378-2545
`
`In his Direct Witness Statement, Dr. Fontecchio separately considers whether
`
`
`
`.
`
`meet each element of the DI claims. Ex. 1 at Q334-386 and Q406-432. But for the first time, Dr.
`
`Fontecchio opines that each of the
`
`
`
`. Id. at Q394-405. Dr. Fontecchio does not explain how
`
`
`
`
`
` allegedly practice any DI claim. Instead, he
`
`opines that each of the
`
` products practice the DI claims “for the same reasons
`
`that I explained with respect to the
`
` product” (id.) that the parties agreed was
`
`representative of
`
`. Ex. 2 at 5.
`
`Dr. Fontecchio’s new opinion that
`
` display is representative of SDC’s
`
`
`
` products (and, thus, that those products practice a DI claim if
`
`should be struck for two reasons. First, it contradicts the parties’ stipulation that
`
` does)
`
` is
`
`representative of the
`
` products. Ex. 2 at 5. Second, Dr. Fontecchio did
`
`not disclose that opinion in his expert report. See, e.g., Ex. 3 ¶¶ 2090-2256 and ¶¶ 2378-2545 (separate
`
`analysis of
`
` Representative Products and not suggesting that
`
` was
`
`representative of those groups).
`
`While G.R. 13.6.6 does not require BOE to show prejudice, BOE would clearly be prejudiced
`
`were SDC permitted to retract its stipulation and have its expert provide previously undisclosed
`
`opinions. For example, the reason SDC had represented that
`
` display was
`
`8
`
`

`

`representative of only
`
` was because
`
`
`
` Had SDC taken the position that those differences were irrelevant to the
`
`’599 Patent claims (that as Dr. Fontecchio now contends
`
`
`
`), then BOE could have argued that
`
`
`
`
`
` (so
`
`that by SDC’s logic the prior art invalidates the ’599 Patent claims). By stipulating that its domestic
`
`industry products fell into
`
` groups (
`
`
`
` SDC prevented BOE from presenting those invalidity arguments. And by
`
`withholding Dr. Fontecchio’s opinion that
`
`
`
` from his expert report, SDC denied BOE the opportunity to address that
`
`admission or rebut the new allegation.
`
`Thus, the ALJ should strike the new opinions at Q394-405 in Dr. Fontecchio’s Direct Witness
`
`Statement that
`
` is representative of
`
` DI products or that
`
`any of those products practice the DI claims simply because
`
` allegedly does.5
`
`C.
`
`The ALJ Should Strike Dr. Fontecchio’s New Allegation That Dr. Foty’s
`Opinions That Sakamoto Invalidates Claim 7 Are Inconsistent with His
`Position with Respect to BOE’s Redesigns (Ex. 6 at Q130-131)
`
`In his Rebuttal Witness Statement, Dr. Fontecchio alleges that Dr. Foty’s opinions that the
`
`prior-art reference Sakamoto invalidates Claim 7 are inconsistent with Dr. Foty’s position regarding
`
`5 As with infringement, throughout his witness statement Dr. Fontecchio refers to and summarizes
` products practice the DI claims. See, e.g., Ex. 1 at
`his conclusion that SDC’s
`Q17, Q318. Such summaries and any opinion that the
` products practice a DI
`claim or that SDC satisfies the’599 Patent’s domestic industry economic prong based on the
`
` products should also be struck. BOE will work with SDC to prepare redacted versions
`of SDC’s witness statements to comply with the ALJ’s decision on this motion.
`
`9
`
`

`

`BOE’s redesigns. Ex. 6 at Q130-131. This is a new opinion that Dr. Fontecchio did not make in his
`
`expert report. See Ex. 7 ¶¶ 352-359 (addressing Sakamoto as applied to claim 7).
`
`Thus, the ALJ should strike the new opinions at Q130-131 in Dr. Fontecchio’s Rebuttal
`
`Witness Statement that Dr. Foty’s opinions of how Sakamoto invalidates Claim 7 are inconsistent with
`
`his position with respect to BOE’s redesigns.
`
`III.
`
`CONCLUSION
`
`For the foregoing reasons, BOE respectfully requests that the ALJ grant this motion in limine
`
`and exclude the portions of Dr. Fontecchio’s Direct Witness Statement identified above.
`
`Dated: January 5, 2024
`
`Respectfully submitted,
`
`/s/ Bas de Blank
`Bas de Blank
`
`Sten Jensen, Esq.
`Steven Routh, Esq.
`Orrick, Herrington & Sutcliffe LLP
`Columbia Center
`1152 15th Street, NW
`Washington, DC 20005
`Tel: (202) 339-8400
`Fax: (202) 339-8500
`Email: BOE-1351-Service@orrick.com
`
`Xiang Wang, Esq.
`Orrick, Herrington & Sutcliffe LLP
`5701 China World Tower A
`No.1 Jianguomenwai Avenue
`Beijing, 100004
`People’s Republic of China
`Tel: +86 10 8595 5600
`Fax: +86 10 8595 5700
`Email: BOE-1351-Service@orrick.com
`
`Richard F. Martinelli, Esq.
`Wesley White, Esq.
`Tyler Miller, Esq.
`Jordan Fernandes, Esq.
`
`10
`
`

`

`Orrick, Herrington & Sutcliffe LLP
`51 West 52nd Street
`New York, NY 10019
`Tel: (212) 506-5000
`Fax: (212) 506-5151
`Email: BOE-1351-Service@orrick.com
`
`Bas de Blank, Esq.
`Harrison Geron, Esq.
`Elaine Ke, Esq.
`Orrick, Herrington & Sutcliffe LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Tel: (650) 614-7400
`Fax: (650) 614-7401
`Email: BOE-1351-Service@orrick.com
`
`David R. Medina, Esq.
`Orrick, Herrington & Sutcliffe LLP
`355 South Grand Avenue, Suite 2700
`Los Angeles, CA 90071
`Tel: (213) 612-2385
`Fax: (213) 612-2499
`Email: BOE-1351-Service@orrick.com
`
`Don Daybell, Esq.
`Johannes Hsu, Esq.
`Orrick, Herrington & Sutcliffe LLP
`2050 Main Street, Suite 1100
`Irvine, CA 92614-8255
`Tel: (949) 567-6700
`Fax: (949) 567-6710
`Email: BOE-1351-Service@orrick.com
`
`Attorneys for Respondent Mianyang BOE Optoelectronics
`Technology Co., Ltd.
`
`11
`
`

`

`
`
`EXHIBIT 1
`EXHIBIT 1
`
`ENTIRE EXHIBIT HAS BEEN REDACTED
`ENTIRE EXHIBIT HAS BEEN REDACTED
`
`

`

`EXHIBIT 2
`EXHIBIT 2
`
`ENTIRE EXHIBIT HAS BEEN REDACTED
`ENTIRE EXHIBIT HAS BEEN REDACTED
`
`

`

`
`
`EXHIBIT 3
`EXHIBIT 3
`
`ENTIRE EXHIBIT HAS BEEN REDACTED
`ENTIRE EXHIBIT HAS BEEN REDACTED
`
`

`

`EXHIBIT 4
`EXHIBIT 4
`
`

`

`UNITED STATES DEPARTMENT
`
`COMMERCE
`
`°
`
`THAT ANNEXED HERETO
`
`TRUE COPY FROM
`
`TO
`THE RECORDS
`
`PATENT NUMBER
`DATE
`
`I
`
`PU
`
`otmU
`
`U
`
`

`

`No
`
`US
`
`ORGANIC LIGHT EMITTING
`METHOD
`AND
`THEREFOR
`
`FOREIGN PATENT DOCUMENTS
`
`CN
`
`A
`
`Oh
`Kwon
`
`Yang Wan
`
`Moo
`
`Samsung
`
`KR
`KR
`KR
`KR
`KR
`
`KR
`
`USC
`
`No
`
`KR
`
`US
`
`US
`
`US PATENT DOCUMENTS
`
`A
`
`OTHER PUBLICATIONS
`
`No
`
`A
`
`T Ho
`
`LLP
`
`ABSTRACT
`
`same
`
`A
`
`A
`
`A
`
`A
`
`A
`
`A
`
`A
`
`

`

`US
`
`US PATENT DOCUMENTS
`
`FOREIGN PATENT DOCUMENTS
`
`KR
`
`No
`
`OTHER PUBLICATIONS
`
`No
`
`Kwon
`
`A
`
`No
`
`No
`Kwon
`No
`
`No
`
`No
`
`No
`
`No
`
`Aug
`
`

`

`US
`
`US
`
`PRIOR ART
`
`VDATAm
`
`VDD
`
`VSS
`
`PRIOR ART
`
`

`

`US
`
`US
`
`VDD
`
`VDATAm
`
`VSS
`
`1
`
`PROG
`
`FM
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`Aug. 19,2008
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`Sheet 4 of5
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`B2
`US
`US 7,414,599 B2
`
`11
`the electroluminescemt element having the one terminal
`coupled to the drain of the fifth transistor and the other
`terminal grounded; and
`a capacitor in which one terminal of the capacitor is
`coupled to the gate ofthe second transistor and a power
`supply voltage is applied to the other terminal of the
`capacitor.
`16. Thepixel circuit in the organic light emitting device of
`claim 15, further comprising:
`asixth transistor including a gate to which a scan signaljust
`before the current scan signal is applied;
`a source coupled to the one terminal of the capacitor; and
`a drain to which an initialization voltageis applied.
`A
`17, A pixelcircuit in an organic light emitting device hav-
`ing a plurality ofdatalines,a plurality ofscanlines, aplurality
`ofpowerlines, and a plurality ofpixels each connected to one
`associated data line, scan line aud powerline ofthe plurality
`of data lines, scan Hnes and powerlines, each pixel compris-
`ing:
`a first transistor including a gate to which a current scan
`signal to be applied to the associated scan lineis applied,
`and a source to which a data signal voltage fromthe data
`line is applied;
`asecondtransistorwhose sourceis coupled to a drain ofthe
`first transistor;
`
`20
`
`12
`}
`a third transistor whose drain and source are connected
`between a gate and a drain of the second transistor,
`respectively;
`a fourth emitting transistor including a gate to which a
`current
`light-emitting signal
`is applied, a source to
`which a power supply voltage from the powerline is
`applied, and a drain coupled to the source of the second
`transistor;
`a fifth transistor including a gate to which the current
`light-emitting signal is applied, and a source coupled to
`the drain of the second transistor;
`an electroluminescent element
`including one terminal
`coupled to the drain of ihe fifth transistor and the other
`terminal grounded; and
`a capacitor including one terminal coupled to the gate of
`the secondtransistor, aud the other terminal to which the
`power supply voliage from the power line is applied.
`18. The pixel circuit in the organic light emitting device of
`claim 17, further comprising:
`a sixth transistor including a gate to which a scan signal to
`be applied to a scan line just before the associated scan
`ling is applied, a source coupled to the one terminal of
`the capacitor, anda drain to which an initialization volt-
`age is applied.
`
`SDC-1351-00000014
`JX-0001.14
`
`

`

`
`
`EXHIBIT 5
`EXHIBIT 5
`
`ENTIRE EXHIBIT HAS BEEN REDACTED
`ENTIRE EXHIBIT HAS BEEN REDACTED
`
`

`

`
`
`EXHIBIT 6
`EXHIBIT 6
`
`ENTIRE EXHIBIT HAS BEEN REDACTED
`ENTIRE EXHIBIT HAS BEEN REDACTED
`
`

`

`
`
`EXHIBIT 7
`EXHIBIT 7
`
`ENTIRE EXHIBIT HAS BEEN REDACTED
`ENTIRE EXHIBIT HAS BEEN REDACTED
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing was served on January 5, 2024 upon the following parties as
`indicated:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Room 112
`Washington, D.C. 20436
`
`Honorable Bryan F. Moore
`Administrative Law Judge
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street SW
`Washington, D.C. 20436
`Email: Moore337@usitc.gov
`
`Michael Maas, Esq.
`Office of Unfair Import Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Suite 401
`Washington, D.C. 20436
`Email: Michael.Maas@usitc.gov
`
`Anne Goalwin, Esq.
`Office of Unfair Import Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Suite 401
`Washington, D.C. 20436
`Email: anne.goalwin@usitc.gov
`
`Counsel for Complainant Samsung Display Co., Ltd.
`
`Jeffrey H. Lerner, Esq.
`COVINGTON & BURLING LLP
`One CityCenter
`850 10th Street, NW
`Washington, D.C. 20001
`Email: SDC-OLED-Cov-337@cov.com
`Email: jlerner@cov.com
`
`" Via First Class Mail
`" Via Overnight Courier
`" Via Hand Delivery
`# Via EDIS Electronic Filing
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`# Via Box
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`# Via Box
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`
`

`

`Counsel for Respondents, Injured Gadgets, LLC, Parts4LCD, Phone
`LCD Parts LLC, and Wholesale Gadget Parts, Inc.
`
`Merritt R. Blakeslee
`THE BLAKESLEE LAW FIRM
`226 Lakeside Drive
`Boothbay Harbor, Maine 04538
`Email: mrb@blakeslee-law.com
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`
`/s/ Karen Johnson
` Karen Johnson
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing was served on January 16, 2024 upon the following parties as
`indicated:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Room 112
`Washington, D.C. 20436
`
`Honorable Bryan F. Moore
`Administrative Law Judge
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street SW
`Washington, D.C. 20436
`Email: Moore337@usitc.gov
`
`Michael Maas, Esq.
`Office of Unfair Import Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Suite 401
`Washington, D.C. 20436
`Email: Michael.Maas@usitc.gov
`
`Anne Goalwin, Esq.
`Office of Unfair Import Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Suite 401
`Washington, D.C. 20436
`Email: anne.goalwin@usitc.gov
`
`Counsel for Complainant Samsung Display Co., Ltd.
`
`Jeffrey H. Lerner, Esq.
`COVINGTON & BURLING LLP
`One CityCenter
`850 10th Street, NW
`Washington, D.C. 20001
`Email: SDC-OLED-Cov-337@cov.com
`Email: jlerner@cov.com
`
`" Via First Class Mail
`" Via Overnight Courier
`" Via Hand Delivery
`# Via EDIS Electronic Filing
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`# Via Box
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`# Via Box
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`
`

`

`Counsel for Respondents, Injured Gadgets, LLC, Parts4LCD,
`Phone LCD Parts LLC, and Wholesale Gadget Parts, Inc.
`
`Merritt R. Blakeslee
`THE BLAKESLEE LAW FIRM
`226 Lakeside Drive
`Boothbay Harbor, Maine 04538
`Email: mrb@blakeslee-law.com
`
`" Via First Class Mail
`" Via Express Mail
`" Via Hand Delivery
`# Via Electronic Mail
`
`/s/ Karen Johnson
` Karen Johnson
`
`