`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`DIGITAL CHECK CORP. d/b/a ST IMAGING,
`Petitioner,
`
`v.
`
`E-IMAGEDATA CORP.
`Patent Owner.
`____________
`
`Case IPR2017-00178
`Patent 9,179,019 B2
`____________
`
`DECLARATION OF JONATHAN D. ELLIS
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P. O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
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`e-IMAGEDATA CORP. EXHIBIT 2005
`e-ImageData v. Digital Check
`IPR2017-00178
`Page 1 of 20
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`I.
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`INTRODUCTION
`1. My name is Jonathan D. Ellis. I have been retained by counsel as an
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`expert for Patent Owner e-ImageData Corp. in inter partes review proceeding
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`IPR2017-00178 before the Patent Trial and Appeal Board.
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`2.
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`I understand that the patent at issue in this proceeding is U.S. Patent
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`No. 9,179,019.
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`3. My Curriculum Vitae has been filed as Exhibit 2006, which includes a
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`description of my employment and educational background. I have summarized
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`below some aspects of my experience that have specific importance to the opinions
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`that I am providing in this case.
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`4.
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`All three degrees I have obtained have been in mechanical
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`engineering, and while I am trained as any normal mechanical engineer is trained
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`through accredited programs in mechanical engineering, my specializations are
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`precision engineering, metrology, and optomechanics. Precision engineering is a
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`multidisciplinary approach to building state of the art systems and instrumentation
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`with an emphasis on error budgeting and achieving tight performance
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`specifications. Often, precision engineering combines mechanics, electronics,
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`optics, controls, and/or software. Metrology is the study of measurements, with an
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`emphasis on traceability and error tolerancing. In essence, I am trained to design,
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`build, and qualify precise instruments, often for metrology purposes.
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`5.
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`I currently have an appointment as a tenured associate professor in the
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`Department of Mechanical Engineering with a secondary appointment in The
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`Institute of Optics at the University of Rochester. Much of my work is focused on
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`training students, either through coursework or through research. In my research, I
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`routinely tackle problems associated with mechanical systems interfacing with
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`optical imaging systems that need real-time signal processing and controls. This is
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`the essence of the systems described in the ’019 Patent: a mechanical system for
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`precisely and repeatably positioning an imaging system and sensor to image an
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`object on to the sensor with real-time readout and control.
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`6.
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`Below are examples of projects that I have worked on or that I am
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`currently working on that utilize similar technology to that needed in this case:
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`a. Developing an imaging system for measuring attributes of <20 nm
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`linewidth structures employing precise control and synchronization
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`between microscope components, laser sources, positioning stages,
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`and cameras.
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`b. Developing a high-speed, high numerical aperture scanning system
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`for ophthalmic applications. This involved building a high numerical
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`aperture microscope that can scan over large fields (>7 mm diameter)
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`with <50 nm accuracy and scan speeds >800 mm/s. Having a large
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`scanning field and a high numerical aperture are two attributes that are
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`IPR2017-00178
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`odds with one another, requiring a complex design and optimization
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`to maximize the performance of both the optical components and the
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`mechanical components. One patent has been filed on the scanning
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`system and a several provisional patents are in preparation. This IP is
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`currently licensed to Clerio Vision, Inc.
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`c. Developing an optical probe for freeform optics metrology with real-
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`time signal processing of optical interference signals. Here, we are
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`interested in ways to measure rotationally non-symmetric surfaces,
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`which are current a challenge for the field with no clear solution. One
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`patent has been filed.
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`d. Developed high-speed signal processing algorithms that have been
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`implemented on a field programmable gate array for real time
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`phasemeter signal processing. This allows complex algorithms to be
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`computed at high speeds, enabling high speed measurement and
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`control with no post-processing operations required.
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`e. Have devised methods for building fiber optic delivered
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`interferometry systems. One patent has been granted (from when I
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`was studying in the Netherlands) and one patent has been filed with
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`the technology currently licensed to a company.
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`f. Have devised and developed a novel method for stabilizing Helium
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`Neon gas lasers, with one patent granted (also from the Netherlands).
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`g. Have devised and developed a novel method for nanoindentation with
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`removing the frame stiffness dependency (US Patent #7568381 B2).
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`7.
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`At the University of Rochester, I run a research group that works on
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`research projects relating to the same fundamental principles used to design and
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`build microfilm readers and scanners. As on example, we designed systems that
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`scanned for defects in semiconductor chips. Our systems delivered light to a
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`sample in a specific pattern and scanned the sample to determine whether any
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`defects existed. These systems were able to scan and detect defects in very small
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`features.
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`8.
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`In addition to these projects, I have worked on many others related to
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`precision positioning systems, probing and metrology systems, signal processing
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`circuit design, and optical metrology.
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`9.
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`I have experience with the operation and mechanical configuration of
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`microfilm scanners. I have repeatedly assembled and disassembled several
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`microfilm scanners, analyzed the images produced by microfilm scanners, and
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`have researched the microfilm scanning industry.
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`10. These microfilm scanners include Konica Minolta’s SL 1000, ST
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`Imaging’s ViewScan I, ViewScan II, and ViewScan III, and e-Image’s ScanPro
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`3000 and ScanPro i9300.
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`11. Based on my education, training, knowledge of the literature, and
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`professional experience, I am fully competent to testify regarding the subject
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`matter described and claimed in the ’019 Patent.
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`12. For my work on this matter, I am being compensated at the rate of
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`$400 per hour, and am being reimbursed for my reasonable out-of-pocket
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`expenses. I am being paid for my time, regardless of the facts I know or discover,
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`and regardless of the conclusions or opinions that I reach. I have no financial
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`interest in the outcome of this case.
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`13.
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`I have testified as an expert witness by deposition in e-ImageData
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`Corp. v. Konica Minolta Business Solutions U.S.A., Case No. 3:12-cv-686 (W.D.
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`Wis.) and in e-ImageData Corp. v. Digital Check Corp. d/b/a ST Imaging, Case
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`No. 15-cv-658-LA (E.D. Wis.). I have issued expert reports in e-ImageData Corp.
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`v. Digital Check Corp. d/b/a ST Imaging, Case No. 16-cv-576-WED (E.D. Wis.),
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`e-ImageData Corp. v. Konica Minolta Business Solutions U.S.A., Case No. 3:12-
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`cv-686 (W.D. Wis.), and e-ImageData Corp. v. Digital Check Corp. d/b/a ST
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`Imaging, Case No. 15-cv-658-LA (E.D. Wis.). I have not testified as an expert
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`witness at trial or by deposition in any other case.
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`14. Except as otherwise stated, I have personal knowledge of the facts
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`stated in this Declaration, and I have formed the opinions expressed in this
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`Declaration based on my expertise, experience, and information that I have
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`reviewed.
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`15.
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`I have reviewed and am familiar with the ’019 Patent and its file
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`history.
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`16.
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`I have reviewed ST Imaging’s Petition for inter partes review of the
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`’019 Patent (Paper No. 2) and the exhibits attached thereto, including the
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`Declaration of Anthony J. Senn (Ex. 1002), U.S. Application Publication No.
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`2004/0012827 (Ex. 1004) (“Fujinawa”), and U.S. Patent No. 5,585,937 (Ex. 1005)
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`(“Kokubo”).
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`17.
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`I have also reviewed the Patent Owner Preliminary Response (Paper
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`No. 5), the Board’s Decision (Paper No. 6), and the Deposition Transcript of
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`Anthony J. Senn (Ex. 2007).
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`18.
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`I understand from the Board’s Decision that inter partes review was
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`instituted on one ground: obviousness of claims 1–3, 5–7, 20–28, 31, 41, 43, 44,
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`53, and 63 over Fujinawa and Kokubo. I understand that no review was instituted
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`based on any other grounds of patentability.
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`IPR2017-00178
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`II.
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`SCOPE OF OPINIONS
`19.
`I have been retained to review and analyze the prior art references at
`
`issue in this instituted proceeding and to form opinions about what a person of
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`ordinary skill in the art at the time of the invention would have understood those
`
`references to have disclosed. I have also been asked to review ST Imaging’s
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`proposed combinations and analyze whether a person of ordinary skill at the time
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`of the invention would have been motivated to combine the references as proposed
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`by ST Imaging. I have also been asked to consider the technical feasibility of the
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`combinations proposed by ST Imaging.
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`III. LEVEL OF SKILL IN THE ART
`I understand that I am to view the issue of obviousness from the
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`20.
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`standpoint of the person of ordinary skill in the art. In my opinion, the person of
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`ordinary skill in the art at the time of the invention would have an undergraduate
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`degree in mechanical or optical engineering, and 3 years of experience in working
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`with or designing scanners, camera systems or printers, which involve
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`optomechanical systems similar to that described in the ’019 Patent and the prior
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`art. My conclusion regarding the person of skill in the art is based on my
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`understanding of the sorts of problems encountered in the art, prior art solutions to
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`those problems, including solutions present in the prior art, the pace of innovation
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`in the art area, the sophistication of the technology, and education level of workers
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`who are active in the field. I understand that, although I may be considered a
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`person of greater than ordinary skill in the art, I will render my analysis from the
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`perspective of one of ordinary skill in the art.
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`IV. THE ’019 PATENT
`21. The ’019 Patent relates to a digital microform imaging apparatus
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`(DMIA) designed for public use. The claimed invention is used primarily by
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`libraries, universities, and researchers to allow microfilm or other images to be
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`quickly converted to electronic images that can be viewed, edited using digital
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`editing techniques, printed, e-mailed, or saved to other media.
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`22. The claimed technology is aimed at reducing the overall size,
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`complexity, and footprint of microform media scanners. Traditional microform
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`media scanners are large instruments with an integrated computer system and
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`screen for viewing, saving, and/or printing of microform media. In traditional
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`systems, the magnification of the system was limited because the system had a
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`fixed lens position that could not move to change magnification. To overcome
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`this, microform media scanners came with different lenses for achieving different
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`magnifications. The different lenses increased the complexity for the user and
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`added an additional variability in image quality because the user could incorrectly
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`replace the lens, damage the lens by dropping it, or blur the image quality by
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`getting dust and fingerprints on it. The ’019 Patent is aimed at directly addressing
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`those two major concerns: the size footprint of the microform media scanner (Ex.
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`1001 at 3:12–20) and the range of the optical magnification (Ex. 1001 at 3:21–26).
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`23. The ’019 patent discloses a DMIA that uses lead members and drive
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`mechanisms to precisely position the lens and sensor along the optical path. (Ex.
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`1001 at 6:1–25.) The lens and sensor are supported by carriages that are coupled
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`to lead members. (Ex. 1001 at 6:1–25.) The drive mechanisms move the carriages
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`to the proper positions along the optical path for the DMIA to achieve the desired
`
`magnification and to focus the image.
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`V.
`
`FUJINAWA
`24. The Fujinawa reference (US 2004/0012827 A1) was published in
`
`2004 and has a priority date of August 9, 1996 from Japanese application JP 08-
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`211525. Fujinawa describes an image reading apparatus for reading film images,
`
`particularly films having different sizes. (Ex. 1004 ¶ 0003.) Fujinawa describes an
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`apparatus that can read both 35 mm film and a new roll film standard which is a
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`different size. (Ex. 1004 ¶ 0010.) Fujinawa also discloses using either a line
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`sensor to record the images, as was common at the time of invention, or an area
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`sensor, which was less common at the time. Using a line sensor requires an
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`auxiliary scan to form digital images with a full two dimensional array of pixels.
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`As shown in Figure 1, Fujinawa’s device includes a light source 31, fold mirror 30,
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`movable lens 29 on a first motor 27, and a sensor 28 on a second motor 26. A
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`person of ordinary skill in the art would have understood that the light source 31
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`shines light through the film to the fold mirror 30, which reflects light to the lens
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`29. The lens 29 images the light onto the sensor 28 to capture the image.
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`Figure 1: Cropped image of Figure 4 in Fujinawa
`showing the core components to the apparatus.
`25. A person of ordinary skill in the art would have understood from the
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`
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`disclosure of Fujinawa that the motor 26 operates to rotate the threaded worm
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`connected to the carriage of the line sensor 28. The motor and threaded worm can
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`move the line sensor bi-directionally along the optical path to precisely position the
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`line sensor. A person of ordinary skill in the art would have understood that the
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`motor 27 operates to rotate the threaded worm connected to the carriage of the lens
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`29. The motor and threaded worm can move the lens bi-directionally along the
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`optical path to precisely position the lens.
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`26. A person of ordinary skill in the art would have understood that, in
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`Fujinawa, the threaded worms do more than merely translate rotational motion to
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`linear motion. The threaded worms precisely position a lens relative to an image
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`sensor along an optical path. Likewise the worms precisely position an image
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`sensor relative to a lens along an optical path. If either the lens or the sensor is out
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`of position, the image will not be in focus.
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`27. A person of ordinary skill in the art would have understood that, in
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`Fujinawa, the opposing rollers 37, 38, 39, and 40 would be used to drive the roll
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`film across the light source 31 (left to right in the image) and synchronize the
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`capture of the image on the line sensor with the motion of the film. A person of
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`ordinary skill in the art would have understood that friction between the opposing
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`rollers can be used to drive the film.
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`VI. KOKUBO
`28. The Kokubo patent (5,585,937) was granted in 1996 and has a priority
`
`date of April 21, 1993 from Japanese application JP 05-094355. Kokubo generally
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`discloses a flatbed scanner. (Ex. 1005 Fig. 1.) A person of ordinary skill in the art
`
`would have understood that Kokubo describes an image reading apparatus for
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`reading text images with a line sensor, with two key attributes: 1) a mechanism to
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`hold the image reading unit in place during transportation (Ex. 1005 at 1:11–13);
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`and 2) a structure for an optical system for reducing/magnifying the image
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`recorded (Ex. 1005 at 1:16–18).
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`29. As shown in Figure 17 of Kokubo, the reading unit 6 contains a series
`
`of mirrors, a lens tube 40, and a line sensor 42. As shown in Figure 1 of Kokubo,
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`the reading unit 6 is connected to timing belt 10, which is driven using motor 7 and
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`pulleys 8, 9. In the scanning operation, the motor, timing belt, and pulley system
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`drives the reading unit across the device to scan the image. The internal
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`components depicted in Figure 17 move with the reading unit.
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`30. The timing belt and pulleys depicted in Figure 1 of Kokubo are used
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`to translate the reading unit during the mechanical scanning operation. One of
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`ordinary skill in the art would have understood that Kokubo is using a smooth
`
`timing belt because that is what is depicted in the figures and there is no disclosure
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`about a toothed timing belt in Kokubo. The smooth timing belt is suitable for
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`translating the reading unit because the image is already in focus. Translating the
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`reading unit does not require the same type of precision that is required for
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`positioning a lens relative to a sensor.
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`31. A person of ordinary skill in the art would understand that the belt
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`drive system depicted in Figure 1 does not move the lens relative to the sensor.
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`The device that Kokubo uses to move the lens laterally along the optical path is
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`shown in Kokubo’s Figures 14–16. The device in Figures 14–16 moves the lens
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`by rotating the motor 52. The motor 52 rotates the feed screw so that the moving
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`member 58 moves the lens tube 40. The feed screw 57 is being used to control the
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`positioning of the lens tube 40.
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`32. Figures 17 and 18 of Kokubo are reproduced below with the light path
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`and lens overlaid in red and blue, respectively. A person of ordinary skill in the art
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`would have understood that Kokubo is describing how the imaging system adjusts
`
`to achieve to two discrete magnifications. This is done with strategically placed
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`mirrors and a mechanism that moves the lens laterally and rotates a mirror out of
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`the light path. When the belt and pulley drive system moves the reading unit, this
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`whole apparatus translates from A to B as depicted to scan documents.
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`Figure 2: Screen capture of Figures 17 and 18 from
`Kokubo with their light path (red) and lens (blue)
`highlighted. Here, a mechanism translates the lens and
`rotates a lens out of the way between Figure 17 and 18
`to generate two different image magnifications.
`33. Kokubo discloses a prior art device in Figure 49. Kokubo discloses
`
`
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`that the device in Figure 49 is a mechanism used for moving the optical parts that
`
`provide the reading unit with reducing or magnifying function. (Ex. 1005 at 1:64–
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`66.) A person of ordinary skill in the art would have understood this disclosure to
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`mean that the device in Figure 49 is moving the lens tube relative to the line
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`sensor. A person of ordinary skill in the art would have understood that this prior
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`art device uses wire ropes and pulleys to position a lens along the optical path.
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`(Ex. 1005 at 2:48–56.) Kokubo explains that the smooth wire ropes and pulleys in
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`this prior art device can slip and that errors can occur if the diameters of multiple
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`drive pulleys are not exact. These errors lead to distortion of the image.
`
`Figure 3: Figure 49 from Kokubo showing
`errors with prior art concepts in belt drives.
`34. A person of ordinary skill in the art would have understood Kokubo to
`
`
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`teach away from using the system in Figure 49 for positioning a lens because
`
`Kokubo explains that the prior art concept shown in Figure 49 leads to distortion
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`errors. Kokubo encourages use of the device depicted in Figures 14–16 to
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`overcome the error prone device of Figure 49.
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`VII. COMBINATION OF FUJINAWA AND KOKUBO
`35. A person of ordinary skill in the art at the time of the invention would
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`not have been motivated to modify the Fujinawa reference with the teachings of
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`Kokubo as proposed by ST Imaging.
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`36. ST Imaging contends that a person of ordinary skill in the art would
`
`have been motivated to modify Fujinawa’s system for moving the lens by
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`replacing the threaded worms with the belt and pulley system of Kokubo. A
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`person of ordinary skill in the art would not have simply substituted the belt and
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`pulley drive system of Kokubo for the threaded worm of Fujinawa.
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`37. The functionality between the threaded worms (Fujinawa) and
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`belt/pulley (Kokubo) are fundamentally adjusting different components. In
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`Fujinawa, the threaded worms provide precise positioning, which makes them
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`suitable for adjusting focus. In Kokubo, the belt and pulley drive system is being
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`used to translate the reading unit. The belt and pulley drive system is not used to
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`position the lens or sensor for adjusting focus.
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`38. One of ordinary skill in the art would have understood that DMIAs
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`have a recognized need for providing precise positioning in the focusing elements.
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`Errors in positioning on the scale of thousandths of an inch could result in focus
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`errors. For example, Fujinawa and the device in the ’019 patent both use lead
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`screw-type devices. In the ST Imaging ViewScan Products and the Konica
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`Minolta SL1000, the translation is performed with toothed-belts and stepper
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`motors, which prevent slipping. The smooth belt and pulley in Kokubo is prone to
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`slipping. In fact, Kokubo explicitly discusses how these belts can slip. (Ex. 1005
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`at 2:48–51.) Slipping is not a concern in Fujinawa because the worm drive
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`mechanism is threadingly coupled to the line sensor for precise movement.
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`39. A person of ordinary skill in the art would not have relied on Kokubo
`
`to teach that a smooth belt and pulley combination could be used in a precision
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`focusing operation because Kokubo uses a feed screw (threaded element, 57,
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`Figures 14-16 in Kokubo) to change focus. Thus, in the imaging path, Kokubo
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`explicitly uses a threaded worm device (feed screw) for positioning components.
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`If the belt and pulley system would have provided sufficient resolution, one could
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`readily assume that it would be beneficial to use common components for two
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`separate parts of the system to simplify supply chain sources and assembly.
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`Familiarity with one type of component being placed in two separate sections of
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`the apparatus would ease assembly, except in cases where the functionality
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`requirements are different, as is the case between the scanning in Kokubo and
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`focusing in Kokubo/Fujinawa.
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`40. A person of ordinary skill in the art would have recognized that none
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`of the references at issue in this proceeding disclose use of a smooth belt to
`
`position a lens relative to a sensor along the optical path. Both prior art
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`references each use a toothed member when positioning a lens relative to a sensor
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`along the optical path. Fujinawa uses a threaded worm to position both the lens
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`and the sensor. (Ex. 1004 Fig. 4.) Kokubo uses a threaded lead screw to position
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`the lens along the optical path. (Ex. 1005 Figs. 14–16, item 57.)
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`41. Moreover, one of ordinary skill in the art would not have looked to
`
`Kokubo to teach the fundamental design choices for a DMIA. In Kokubo, the
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`predominant design is a flatbed scanner to scan text. The light source is used in a
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`reflecting mode, meaning it is insufficient for transparent media which is the
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`majority of microform media. Moreover, it is used in a line scan configuration. In
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`the fifth embodiment of Kokubo, which is used for imaging film, there is no
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`teaching about changing magnification. Thus, the embodiments discussed by
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`Kokubo and the ’019 Patent have little overlap with the device of Fujinawa.
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`42. One of ordinary skill in the art would understand that when Kokubo
`
`does teach about image magnification, it is in the context of two discrete
`
`magnifications rather than a continuum of magnifications as depicted in the ‘019
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`patent. Similarly, one of ordinary skill in the art would understand that Fujinawa is
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`predominantly designed for imaging two different sized film standards with only a
`
`small magnification difference between the two sizes. Thus, there is little
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`reasoning to apply Fujinawa’s or Kokubo’s teachings to design a DMIA where a
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`range of magnifications is required.
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`e-IMAGEDATA CORP. EXHIBIT 2005
`e-ImageData v. Digital Check
`IPR2017-00178
`Page 19 of 20
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`I understand that willful false statements and the like are punishable by fine
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`or imprisonment, or both (18 U.S.C. § 1001), and may jeopardize the validity of
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`the application or any patent issuing thereon. All statements made herein are of
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`my own knowledge and are true to the best of my personal knowledge, and all
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`statements made on information and belief are believed to be true.
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`Executed this August 1, 2017 at Rochester, New York.
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`_____________________________
`Jonathan D. Ellis
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`19
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`e-IMAGEDATA CORP. EXHIBIT 2005
`e-ImageData v. Digital Check
`IPR2017-00178
`Page 20 of 20
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