United States Patent and Trademark Office
`Before the Patent Trial and Appeal Board
`
`LG ELECTRONICS, INC. and
`LG ELECTRONICS U.S.A., INC.,
`Petitioner,
`
`v.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION,
`Patent Owner.
`
`Case IPR2015-01644
`Patent 6,785,065
`
`Petitioner’s Demonstrative Exhibits for October 6, 2016 Oral Argument
`
`0
`
`
`Before the Patent Trial and Appeal Board
`
`LG ELECTRONICS, INC. and
`LG ELECTRONICS U.S.A., INC.,
`Petitioner,
`
`v.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION,
`Patent Owner.
`
`Case IPR2015-01644
`Patent 6,785,065
`
`Petitioner’s Demonstrative Exhibits for October 6, 2016 Oral Argument
`
`0
`
`
`
`Instituted Grounds
`
`Institution Decision at 27-28.
`
`1
`
`
`
`U.S. Patent No. 6,785,065 (“the ’065 Patent”)
`Title: Optical Pickup Actuator Driving Method
`and Apparatus Therefor
`
`’065 patent at 1:15-24.
`
`2
`
`
`
`Overview of the ’065 Patent
`
`Overview of the ’065 Patent
`
`FIG. 1 (PRIOR ART)
`
`FIG. 2A (PRIOR ART)
`
`
`
`3
`
`
`
`Overview of the ’065 Patent
`
`Purported Shortcomings of Conventional Actuator
`
`’065 patent at 2:57-64.
`
`4
`
`
`
`Overview of the ’065 Patent
`
`Purported Shortcomings of Conventional Actuator
`
`’065 patent at 2:65-3:7.
`
`5
`
`
`
`Overview of the ’065 Patent
`
`Overview of the ’065 Patent
`
`FIG. 3
`
`30 15
`
`FIG. 4
`
`99095
`
`6
`
`
`
`
`Overview of the ’065 Patent
`
`’065 patent at Fig. 3.
`
`7
`
`
`
`Overview of the ’065 Patent
`
`Purported Solution of the ’065 Patent
`
`’065 patent at 3:9-17.
`
`8
`
`
`
`Overview of the ’065 Patent
`
`Purported Solution of the ’065 Patent
`
`’065 patent at 8:21-30.
`
`9
`
`
`
`Independent Claim 1 of the ’065 Patent
`
`An optical recording and/or reproducing apparatus for use with transferring
`1.
`information with respect to a recording medium, comprising:
`a spindle motor rotating the recording medium;
`an optical pickup including an objective lens and an actuator which actuates
`the objective lens so as to transfer the information with respect to the recording
`medium; and
`a control unit driving the spindle motor and the optical pickup to transfer the
`information with respect to the recording medium and controlling the actuator of the
`optical pickup in the radial, track, tilt and focusing directions,
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the actuator;
`at least one focus and tilt coil which drives the bobbin in the focus
`and the tilt directions and at least one track coil which drives the bobbin in
`the track direction arranged on each of opposite side surfaces of the bobbin;
`support members which move the bobbin and are provided to the
`other side surfaces of the bobbin, wherein the focus and tilt coils and
`the track coils are not arranged on the other side surfaces of the bobbin; and
`magnets arranged to face corresponding sides of the opposite
`side surfaces of the bobbin.
`
`10
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`a spindle motor rotating
`the recording medium;
`
`’065 patent at 3:3-7 (background).
`
`11
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`an optical pickup including an objective lens
`and an actuator which actuates the objective lens so
`as to transfer the information with respect to the
`recording medium; and
`a control unit driving the spindle motor and the
`optical pickup to transfer the information with respect
`to the recording medium and controlling the actuator
`of the optical pickup in the radial, track, tilt and
`focusing directions,
`
`12
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`13
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`14
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`15
`
`
`
`Independent Claim 1 of the ’065 Patent
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`16
`
`
`
`Independent Claim 1 of the ’065 Patent
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`17
`
`
`
`Independent Claim 1 of the ’065 Patent
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`18
`
`
`
`Independent Claim 1 of the ’065 Patent
`wherein the actuator comprises: …
`support members which move the bobbin and
`are provided to the other side surfaces of the
`bobbin, wherein the focus and tilt coils and
`the
`track coils are not arranged on the other side
`surfaces of the bobbin;
`
`19
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`wherein the actuator comprises: …
`magnets arranged to face corresponding sides
`of the opposite side surfaces of the bobbin.
`
`20
`
`
`
`Independent Claim 1 of the ’065 Patent
`
`An optical recording and/or reproducing apparatus for use with transferring
`1.
`information with respect to a recording medium, comprising:
`a spindle motor rotating the recording medium;
`an optical pickup including an objective lens and an actuator which actuates
`the objective lens so as to transfer the information with respect to the recording
`medium; and
`a control unit driving the spindle motor and the optical pickup to transfer the
`information with respect to the recording medium and controlling the actuator of the
`optical pickup in the radial, track, tilt and focusing directions,
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the actuator;
`at least one focus and tilt coil which drives the bobbin in the focus
`and the tilt directions and at least one track coil which drives the bobbin in
`the track direction arranged on each of opposite side surfaces of the bobbin;
`support members which move the bobbin and are provided to the
`other side surfaces of the bobbin, wherein the focus and tilt coils and
`the track coils are not arranged on the other side surfaces of the bobbin; and
`magnets arranged to face corresponding sides of the opposite
`side surfaces of the bobbin.
`
`21
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`
`’065 Patent
`
`Akanuma
`
`22
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`
`Claim 1
`a spindle motor rotating
`the recording medium;
`
`Akanuma
`
`Akanuma at 7:39-41.
`
`23
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`a spindle motor rotating
`the recording medium;
`
`Mansuripur Decl. (Ex. 1011) at ¶ 79.
`
`24
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`a spindle motor rotating
`the recording medium;
`
`Mansuripur Decl. (Ex. 1011) at ¶ 79.
`
`25
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`an optical pickup including an objective lens
`and an actuator which actuates the objective lens so
`as to transfer the information with respect to the
`recording medium; and
`
`Akanuma at 6:41-43.
`
`26
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`a control unit driving the spindle motor and the
`optical pickup to transfer the information with respect
`to the recording medium and controlling the actuator
`of the optical pickup in the radial, track, tilt and
`focusing directions,
`
`Akanuma at 7:42-53
`
`27
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`28
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`29
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`Akanuma
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`30
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`31
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`32
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`wherein the actuator comprises: …
`at least one focus and tilt coil which drives the
`bobbin in the focus and the tilt directions and at
`least one track coil which drives the bobbin in the
`track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`Akanuma
`
`33
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`wherein the actuator comprises: …
`support members which move the bobbin and
`are provided to the other side surfaces of the
`bobbin, wherein the focus and tilt coils and
`the
`track coils are not arranged on the other side
`surfaces of the bobbin;
`
`34
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`Claim 1
`wherein the actuator comprises: …
`magnets arranged to face corresponding sides
`of the opposite side surfaces of the bobbin.
`
`35
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Akanuma
`
`An optical recording and/or reproducing apparatus for use with
`1.
`transferring information with respect to a recording medium, comprising:
`a spindle motor rotating the recording medium;
`an optical pickup including an objective lens and an actuator which
`actuates the objective lens so as to transfer the information with respect to the
`recording medium; and
`a control unit driving the spindle motor and the optical pickup to transfer
`the information with respect to the recording medium and controlling the
`actuator of the optical pickup in the radial, track, tilt and focusing directions,
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the actuator;
`at least one focus and tilt coil which drives the bobbin in the
`focus and the tilt directions and at least one track coil which drives the
`bobbin in the track direction arranged on each of opposite side
`surfaces of the bobbin;
`support members which move the bobbin and are provided to the
`other side surfaces of the bobbin, wherein the focus and tilt coils and the
`track coils are not arranged on the other side surfaces of the bobbin; and
`magnets arranged to face corresponding sides of the opposite
`side surfaces of the bobbin.
`
`36
`
`
`
`Independent Claim 1 of the ’065 Patent
`Claim 1
`a spindle motor rotating
`the recording medium;
`
`APA
`
`’065 patent at 3:3-7 (APA).
`
`37
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`a control unit driving the spindle motor and the
`optical pickup to transfer the information with respect
`to the recording medium and controlling the actuator
`of the optical pickup in the radial, track, tilt and
`focusing directions,
`
`APA
`
`’065 patent at 2:13-18 (APA).
`
`38
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`APA
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`39
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`APA
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`40
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Ikegame
`Claim 1
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`41
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`Claim 1
`Ikegame
`wherein the actuator comprises:
`a bobbin movably arranged on a base of the
`actuator;
`
`42
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`
`Akanuma
`
`Claim 1
`at least one focus and tilt coil
`which drives the bobbin in the focus
`and the tilt directions ….
`
`Akanuma at 7:42-52.
`
`43
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`
`Claim 1
`at least one focus and tilt coil
`which drives the bobbin in the focus
`and the tilt directions ….
`
`Petition at 29.
`Mansuripur Decl. (Exhibit 1011) at ¶ 95.
`
`44
`
`
`
`Obviousness: Claim 1 of the ’065 Patent
`
`Claim 1
`… at least one track coil which
`drives the bobbin in the track
`direction …
`
`Akanuma
`
`Akanuma at 7:42-47.
`
`45
`
`
`
`Claim Interpretation: “on”
`
`Claim 1 of the ’065 patent recites “at least one focus and tilt coil … and at
`least one track coil … arranged on each of opposite side surfaces of the
`bobbin.”
`
`TSST-K argued that “on” in the recitation “arranged on each of opposite side
`surfaces” should be interpreted to mean “over and in contact with.” POR at
`p. 3.
`
`46
`
`
`
`The Coils of Akanuma are
`Arranged On Each of
`Opposite Side Surfaces
`
`47
`
`
`
`Claim Interpretation: “on”
`
`The Board squarely rejected a similar
`argument that the claims require a side-
`by-side coil configuration in the
`Institution Decision. Institution Decision
`at p. 14-15. See also Reply at p. 2.
`
`48
`
`
`
`Claim Interpretation: “on”
`
`TSST-K’s claim construction arguments improperly apply Philips rather than
`the broadest reasonable interpretation.
`Reply at 1, 9 (citing In re Cuozzo Speed Technologies v. Lee, 2016 U.S. Lexis 3927 (U.S. June, 20, 2016)).
`
`POR at 1.
`
`49
`
`
`
`Claim Interpretation: “on”
`
`Claim 1 of the ’065 Patent
`a bobbin movably arranged on a base of the actuator;
`at least one focus and tilt coil which drives the bobbin in the
`focus and the tilt directions and at least one track coil which
`drives the bobbin in the track direction arranged on each of
`opposite side surfaces of the bobbin;
`
`Claims Do Not Require Coils in Contact with Side Surfaces
`• Claims do not include the word “contact.” Reply at 3.
`
`• Claims include no explicit requirement that coils are in contact
`with each of opposite side surfaces of the bobbin. Reply at 3.
`
`• Claims use “arranged on” to describe the non-contacting
`positional relationship between the bobbin and the base.
`Reply at 3-4.
`
`50
`
`
`
`Claim Interpretation: “on”
`
`Deposition Transcript of David B. Bogy at 109:18-110:1.
`
`Id. at 110:20-22.
`
`51
`
`
`
`Claim Interpretation: “on”
`
`Claim 1 of the ’065 Patent
`at least one focus and tilt coil which drives the bobbin in the
`focus and the tilt directions and at least one track coil which drives
`the bobbin in the track direction arranged on each of opposite side
`surfaces of the bobbin;
`
`Claims Do Not Require Coils in Contact with Side Surfaces
`• Specification does not teach that the focusing and tilt coils FC1-
`FC4 and the tracking coils TC1-TC2 must be “in contact with”
`the opposite side surfaces 15a of the bobbin 15. Reply at 3.
`
`• Specification uses the terms “on” and “at” interchangeably.
`Reply at 4-5.
`
`• Specification describes coils located at only two opposite side
`surfaces as addressing shortcomings of coils located on all four
`sides of the conventional bobbin. Reply at 6-7.
`
`52
`
`
`
`Claim Interpretation: “on”
`The specification uses the terms “on” and “at” interchangeably:
`
`’065 patent at 5:16-32.
`
`53
`
`
`
`Claim Interpretation: “on”
`The optical pickup actuator works regardless of whether coils
`are in contact with the side surfaces:
`
`Deposition Transcript of David B. Bogy at 86:21-87:4.
`See also Reply at 7.
`
`54
`
`
`
`Claim Interpretation: “on”
`The specification describes importance of coils located at only
`2 sides (not at all four sides):
`
`Deposition Transcript of David B. Bogy at 95:3-13. See also Reply at 7-8.
`
`55
`
`
`
`Claim Interpretation: “on”
`Specification does not disclose importance of coils being in
`contact with side surfaces of bobbin:
`
`Deposition Transcript of David B. Bogy at 96:22-97:6.
`See also Reply at 8.
`
`56
`
`
`
`The Coils of Akanuma are
`Arranged On Each of
`Opposite Side Surfaces
`
`57
`
`
`
`The Coils of Akanuma are
`Arranged On Each of
`Opposite Side Surfaces
`
`Akanuma at 6:61-65.
`
`Akanuma at 7:24-27.
`
`58
`
`
`
`Dependent Claim 2 of the ’065 Patent
`’065 Patent
`
`The optical recording and/or reproducing
`2.
`apparatus of claim 1, wherein:
`one side of the opposite side surfaces of the
`bobbin includes first and third focus and tilt coils,
`and
`
`the other one side of the opposite side
`surfaces of the bobbin includes second and fourth
`focus and tilt coils.
`
`59
`
`
`
`Obviousness: Claim 2 of the ’065 Patent
`Akanuma
`
`The optical recording and/or reproducing
`2.
`apparatus of claim 1, wherein:
`one side of the opposite side surfaces of the
`bobbin includes first and third focus and tilt coils,
`and
`
`the other one side of the opposite side
`surfaces of the bobbin includes second and fourth
`focus and tilt coils.
`
`60
`
`
`
`Dependent Claim 3 of
`the ’065 Patent
`3. The optical recording and/or
`reproducing apparatus of claim 2,
`wherein, in order to drive the actuator in
`the focus and tilt directions, a first input
`signal is applied to a first set and a
`second input signal is applied to a
`second set, and the first and second
`sets include corresponding ones of the
`first through fourth focus and tilt coils.
`
`61
`
`
`
`Claim Interpretation: “in order to drive the
`actuator in the focus and tilt directions”
`
`Claim Language
`
`The optical recording and/or reproducing apparatus
`3.
`of claim 2, wherein, in order to drive the actuator in the
`focus and tilt directions, a first input signal is applied to a
`first set and a second input signal is applied to a second
`set, and the first and second sets include corresponding
`ones of the first through fourth focus and tilt coils.
`
`Claim 3 Does Not Require Driving of the Actuator in the
`Focus and Tilt Directions Simultaneously
`
`• Claim 3 does not specify that the actuator be driven in
`the focus and tilt directions simultaneously. Reply at
`10.
`
`62
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`Akanuma discloses driving an actuator in the focus and tilt directions simultaneously by
`providing a current to the focusing coils 27 and additionally separately providing currents
`to each of the focusing coils 27. Reply at 16.
`
`Akanuma at 7:42-52.
`
`63
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`
`The objective lens can be tilted in the
`radial tilt direction simply by driving coils
`27a and 27c in a first direction and
`driving coils 27b and 27d in a second,
`opposite direction. (Petition at 54. See
`also Mansuripur Decl. at ¶¶ 95-96.)
`
`The objective lens can be tilted in the
`tangential tilt direction simply by driving
`coils 27a and 27b in a first direction (and
`27c and 27d in a second, opposite
`direction. (Petition at 55. See also
`Mansuripur Decl. at ¶¶ 95-96.)
`
`Petition at 54.
`Mansuripur Decl. (Exhibit 1011) at ¶ 95.
`
`64
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`Wakabayashi discloses driving an
`actuator in the focus and tilt
`directions simultaneously by
`applying the sum of tilt and focus
`error signals to focusing coils 7a
`and 7c and by applying the
`difference between the tilt and
`focus error signals to focusing coils
`7b and 7d. Reply at 16.
`
`Wakabayashi at 7:16-20.
`
`65
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`The control circuit shown in Fig. 2 of Wakabayashi is extremely similar to the circuit
`diagram shown in Fig. 9 of the ’065 patent. Both combine focus and tilt error signals to
`drive sets of coils. Reply at 20-21.
`Wakabayashi
`
`’065 patents at Fig. 9.
`
`66
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`
`Deposition Transcript of David B. Bogy at 169:4-12.
`See also Reply at 22.
`
`67
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`
`Deposition Transcript of David B. Bogy at 172:12-18.
`See also Reply at 22.
`
`68
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`
`Deposition Transcript of David B. Bogy at
`185:11-17.
`See also Reply at 22.
`
`69
`
`
`
`Obviousness: Claim 3 of the ’065 Patent
`
`. . .
`
`Deposition Transcript of David B. Bogy at 185:11-17.
`See also Reply at 22.
`
`70
`
`
`
`The Coils of Akanuma
`are Arranged On Each of
`Opposite Side Surfaces
`
`Akanuma at 13:47-49.
`See also Reply at 13-14.
`
`71
`
`
`
`The Coils of Akanuma
`are Arranged On Each of
`Opposite Side Surfaces
`
`Akanuma at 14:57-61.
`See also Reply at 13-14.
`
`72
`
`
`
`The Coils of Akanuma are Arranged On Each
`of Opposite Side Surfaces
`
`Deposition Transcript of David B. Bogy at 128:6-15.
`See also Reply at 15.
`
`73
`
`
`
`Patent Owner Response
`
`Patent Owner Response
`
`A. “On each of opposite side surfaces ”*’(claim 1)
`
`The phase ‘ton each of opposite side surfaces” in claim | should be
`
`interpreted to mean “over and in contact with each of opposite side surfaces.” Ex.
`
`POR at 3.
`
`2003 at Yq 25-39. A broader definition would be inconsistent with the ‘065 patent
`
`specification. Id.
`
`POR at 3.
`
`74
`
`74
`
`
`
`Patent Owner Response
`
`Patent Owner Response
`
`B. “in order to drive the actuator in the focus andtilt directions, a first
`input signalis applied to a first set and a secondinputsignal is applied
`to a second set... ”(claim 3)
`
`Claim 3 specifies that, inter alia, ‘in order to drive the actuator in the focus
`
`and tilt directions, a first input signal is applied to a first set and a second input
`
`signal is applied to a second set...’ (Ex. 1001 at 9:6-8). This language should be
`
`interpreted to require, inter alia, that the actuator is driven in both the focus
`
`direction and the tilt direction whenthe recited first and second input signals are
`
`applied to the first and second coil sets, respectively. Ex. 2003 at {J 40-43. This
`
`POR at 10-11.
`
`75
`
`POR at 10-11.
`
`75
`
`
`
`Patent Owner Response
`
`Patent Owner Response
`
`One skilled in the art at the time of the invention would not have moved the
`
`focusing coils 27 and the tracking coils 28 next to one another on the side walls 20
`
`side surfaces of the objective lens supporting member 14. Ex. 2003 at J 60. In this
`
`case, the drawings reasonably disclose and suggest to one of ordinary skill in the
`
`art that the arrangement of ‘065 patent claim 1 could not be met. See In re Wright,
`
`569 F.2d 1124, 1126 (CCPA 1977) (the description of the article pictured can be
`
`relied on, in combination with the drawings, for what they would reasonably teach
`
`one of ordinary skill in the art); see also MPEP 2125(II). In this case, one skilled
`
`in the art would conclude that Figs. 5A and 7A of AKkanuma, and their
`
`corresponding textual descriptions, demonstrate that there simply would not have
`
`been enough “real estate”* to accommodate both of the coils next to one another.
`
`POR at 20.
`
`76
`
`Ex. 2003 at J 60.
`
`POR at 20.
`
`76
`
`
`
`Patent Owner Response
`
`Patent Owner Response
`
`tracking coil.” Ex. 2003 at J 62.
`
`It could not have been obviousfor those skilled
`
`in the art to arrange both the focusing coils and the tracking coils to meet the
`
`language of claim |, absent any teaching or suggestion of either arranging different
`
`magnets with various polarizations or arranging coils without being restricted to
`
`the boundary line ‘ta” and “*b”’, as doing so certainly would have changed
`
`POR at 22-23.
`
`Akanuma’s principle of operation. Ex. 2003 at J 63. As noted above, a case of
`
`obviousness cannot exist under these circumstances.
`
`POR at 22-23.
`
`77
`
`77
`
`
`
`Patent Owner Response
`
`Patent Owner Response
`
`A. Akanuma, the APA, and Wakabayashi do not teach the actuator being
`movable in both the focus direction and the tilt direction, simultaneously,
`when a
`ing a first input
`sional and a second input
`sional.
`
`POR at 24.
`
`POR at 24.
`
`78
`
`78
`
`
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