IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`PATENT TRIAL AND APPEAL BOARD
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`DIGITAL CHECK CORP. d/b/a ST IMAGING
`Petitioner
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`v.
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`E-IMAGEDATA CORP.
`Patent Owner
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`_____________________
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`CASE: IPR2017-00178
`U.S. PATENT NO. 9,179,019
`_____________________
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`DECLARATION OF ANTHONY J. SENN, P.E.
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 1 of 78
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`PATENT TRIAL AND APPEAL BOARD
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`DIGITAL CHECK CORP. d/b/a ST IMAGING
`Petitioner
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`v.
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`E-IMAGEDATA CORP.
`Patent Owner
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`_____________________
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`CASE: IPR2017-00178
`U.S. PATENT NO. 9,179,019
`_____________________
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`DECLARATION OF ANTHONY J. SENN, P.E.
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 1 of 78
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`1.
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`2.
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`I, Anthony J. Senn, P.E., do hereby declare and say:
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`I am over the age of twenty-one (21) and competent to make this
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`declaration. I am also qualified to give testimony under oath. The facts and
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`opinions listed below are within my personal knowledge.
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`3.
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`I am being compensated for my time in this matter at my typical
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`hourly consulting rate. My compensation in no way depends on the outcome of
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`this proceeding or the content of my opinions.
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`4.
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`I have been asked to review certain documents, including U.S. Patent
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`No. 9,179,019 (which I refer to as the ‘019 Patent) (Ex. 1001), and to provide my
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`opinions on what those documents disclose. The documents I was asked to review
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`include those addressed in more detail in the rest of this declaration. I provide my
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`conclusions regarding the disclosures of these documents below.
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`5.
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`I was also asked to provide my opinion on the technical feasibility of
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`combining certain aspects of certain documents. I have offered my opinion on the
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`feasibility of these combinations in this declaration.
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`6.
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`I am not offering any conclusions as to the ultimate determinations I
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`understand the Board will make in this proceeding. I am simply providing my
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`opinion on the technical aspects of the documents (including, where asked, the
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`application of what I understand Petitioner and/or the Board asserts is the
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`appropriate construction for this proceeding) and on the motivations and
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`combinability of the concepts disclosed in those documents from a technical
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`perspective.
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`BACKGROUND
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`7.
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`I am a mechanical engineer with over 25 years of experience in
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`research and development, product design, project management and field
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`engineering.
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`8. My experience in these areas spans design of mechanical assemblies
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`and machinery, materials and manufacturing methods, and 3-D CAD design from
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`initial concept through final implementation.
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`9.
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`As part of my experience, I have managed products from idea to
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`design to implementation to customer installation, maintenance, and satisfaction. I
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`have also observed and assisted with the electrical design and controls associated
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`with automated machinery. I have extensive experience working with and the
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`design of automated machinery and/or its components consisting of rotary
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`bearings, linear guides or bearings, lead screws, belt drives, sensors, etc. For the
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`last 10 years, I have been a consulting engineer working part time on automated
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`microform scanning equipment.
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`10.
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`I received my Bachelor’s of Science degree
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`in Mechanical
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`Engineering from California State University, Chico in Chico, California in 1991.
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`11. Upon graduating from California State University, Chico, I was hired
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`by NEC Electronics as an Assembly Process Engineer. In this role, I was
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`responsible to maintain and improve high volume, semiconductor manufacturing
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`assembly processes.
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`12.
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`In 1992, I was hired by Healthtek, Inc. as a Senior Engineer. In this
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`role, I was responsible to manage all technical aspects of high volume / low yield,
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`disposable, medical product manufacturing.
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`13.
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`In 1993, I was hired by SCP Global Technologies as a Senior Staff
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`Engineer. In this role, I was a technical team leader of complex automation and
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`mechanical design projects in parallel with solo design work relative to large scale
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`semiconductor equipment manufacturing.
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`I successfully managed and
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`implemented a number of projects, including innovative concept generation,
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`planning, scheduling, vendor evaluation, sub-contractor management, formal
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`presentations, employee supervision and on time deadline completion. In this role
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`over 11 years, I developed a number of technical strengths, including traditional
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`engineering, finite element analysis, reliability engineering, fluids handling,
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`chemical compatibility, airflow management, plastic part design, manufacturing
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`engineering, design for
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`injection molding, specification writing, creative
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`packaging, and basic electrical and software skills.
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`14.
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`In 1999, I successfully passed
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`the Idaho State Professional
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`Engineering examination to become a licensed Professional Engineer (PE).
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`15.
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`In 1998, I formed Inventure Engineering, LLC.
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` Inventure
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`Engineering, LLC provides consulting engineering, design, and build services to
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`clients worldwide.
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` We specialize in assisting our client’s new product
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`development programs from initial concept through manufacturing. I continue to
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`consult for clients in my role for Inventure Engineering, LLC. Petitioner is a
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`current client of Inventure Engineering, LLC.
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`16. For the past 10 years I have been an engineering consultant with
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`nextScan, Inc., a manufacturer and innovator of digital film scanning equipment.
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`During this time, I have performed solo mechanical design work and have worked
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`alongside teams of engineers, software programmers, and procurement and
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`manufacturing personnel. This work has involved both roll film scanning as well
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`as microfilm slides and film strips in jackets or aperture cards.
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`17.
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`I have worked on several different designs of microform and roll film
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`scanning equipment in consultation with nextScan. I have become intimately
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`familiar with all aspects of microform and roll film scanning equipment, including
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`the electrical and mechanical considerations that go into designing these devices.
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`18.
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`In my career, I have been awarded 12 U.S. Patents for 5 different
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`companies.
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`19. For these reasons and because of my technical experience and training
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`as outlined in my curriculum vitae (Ex. 1003), I believe I am qualified to offer
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`technical opinions regarding the ‘019 Patent and the other documents I reviewed as
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`part of my work in this matter. I believe I am capable of opining about the state of
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`the art in these areas at various points in time from the early 1990s to the present,
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`as I have been familiar with the academic and commercial work being done by
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`nextScan and others in the industry.
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`U.S. PATENT NO. 8,537,279
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`20. The ‘019 Patent is titled “Digital Microform Imaging Apparatus.”
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`(Ex. 1001). It was filed on August 15, 2013, as a continuation of an application
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`that issued as U.S. Patent No. 8, 537,279, which was a continuation of an
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`application that issued as U.S. Patent No. 8,269,890. I have been asked to assume
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`(and I have assumed) for purposes of my analysis that the ‘019 Patent has an
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`effective filing date of May 15, 2007. I have therefore tried to offer opinions in
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`this declaration through the eyes of one of skill in the art (as defined below in
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`Paragraph 40) as of May 15, 2007.
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`21. The
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`‘019 Patent discloses microform
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`imaging apparatuses.
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`Microform readers were well known long before the ‘019 Patent. The ‘019 Patent
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`acknowledges that the principle features of microform readers–a chassis, a mirror,
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`a lens, an image sensor and an adjuster–were well known many years before May
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`15, 2007. (Ex. 1001 at 2:23-36 and 2:50-51). The ‘019 Patent further recognizes
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`that the digital aspects incorporated into the claimed invention were not novel.
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`(Ex. 1001 at 2:28-31 and 2:50-51). Rather, digitization of microfilm was a natural
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`result of the prevalence of computers and the digital age. (Ex. 1001 at 1:60-67).
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`22. The ‘019 Patent indicates that “[w]hat is needed in the art is a
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`compact and versatile digital microform imaging apparatus which can easily adapt
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`to a broad range of reduction ratios and media types while providing good
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`resolution of the images and ease of use.” (Ex. 1001 at 2:59-62). The asserted
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`claims of the ‘019 Patent do not require that the digital microform imaging
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`apparatus be compact in any way.
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`SUMMARY OF OPINIONS
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`23. As discussed in more detail below, my review of prior art documents
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`in this proceeding demonstrates that the individual components of the ‘019 Patent
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`were well known as of the earliest possible priority date of May 15, 2007.
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`Specifically, microform readers have existed for decades and certainly predate the
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`‘019 Patent. The ‘019 Patent discloses microform reader patents dating back to
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`1973, but these reading devices were well known long before the 1970s. (Ex. 1001
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`at 1:45-47, 1:66-67, 2:23-25, 2:50-51). Microform reading devices have been used
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`for nearly a century to read and view documents stored as microform including
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`Microfilm, Microfiche, Aperture cards, etc. Microform is stored on reel film or as
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`cassettes, which can hold thousands of pages of miniaturized documents for
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`efficient archiving and storage. A user operates a microform reader to access the
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`archived documents through magnification and display. Microform’s ability to
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`store many documents in a small space became increasingly popular in the 1950s
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`when libraries used it for the archival of deteriorating newspaper collections and
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`record preservation.
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`24. Due to the increased popularity of microform, microform readers were
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`increasingly developed to enable users to retrieve and view the image information
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`stored on the microform. The basic operation of a microform reader has not
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`changed for decades, i.e., microform readers retrieve image information by
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`projecting a magnified view of microform images to readable proportions. The
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`image can then be viewed, printed, or saved by the user.
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`25. To improve image quality, many prior art microform readers included
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`focus and magnification adjustment functionality, which is typically achieved by
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`moving the lens and/or image sensor. Devices with moving components are not a
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`new concept. Rotating and translating parts have been a part of mechanical
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`reading and imaging devices for the last century. Achieving motion within a
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`microform reading or imaging device has been accomplished much in the same
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`way for decades. The well known and long used configurations to convert motor
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`drive shaft rotational energy into linear motion include lead members, guide rails,
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`and rack and pinion arrangements. A lead member arrangement, such as a
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`threaded lead screw (e.g., worm) and threaded (driven) nut enables linear motion
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`as the threaded nut moves along the rotating lead member (e.g., worm). The motor
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`shaft can be directly connected to the lead member or can be coupled to the lead
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`member through the use of pulleys and belts, gears or other means of rotary motion
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`transmission. Another well known technique includes a guide rail, pulleys, and a
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`drive belt. The drive belt may be coupled to a carriage that slides along the guide
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`rail as the drive shaft rotates a drive pulley. Additionally, a rack and pinion gear
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`arrangement can be used, such that rotation of the motor shaft guides the pinion
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`gear along the rack.
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`26. With the advent of the computer and advances in electronic storage,
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`digital conversions of microform became popular. (Ex. 1001 at 1:60-67).
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`Microform readers were adapted with image sensors such as line sensors and area
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`sensors to capture the image information from the projected film that could be
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`saved and stored electronically. Many microform readers were integrated with
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`computers to save digital copies of the scanned images.
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`27. Fujinawa and Kokubo disclose microform imaging apparatuses that
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`include a chassis, a fold mirror, lead members, carriages, an image sensor, a lens,
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`motors, drive mechanisms, and film carriers. Fujinawa discloses an area sensor
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`supported by the first carriage that is movable to adjust the distance between the
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`area sensor and the fold mirror. Additionally, Fujinawa discloses a lens that is
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`positioned between the area sensor and the fold mirror. Kokubo discloses a
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`carriage that is slidingly coupled to the first lead member. Both Kokubo and
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`Fujinawa disclose motors linked to carriages for moving the carriage along a lead
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`member or members. Additionally, both Kokubo and Fujinawa disclose motors
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`with motor shafts that engage drive mechanisms. Kokubo’s drive mechanism
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`includes a pulley and belt that extends alongside and is spaced apart from a lead
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`member. Fujinawa also discloses supply and take-up film roll attachments.
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`Additionally, Minolta discloses a film carrier with supply and take-up film roll
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`attachments specifically designed to be used with microform imaging apparatuses.
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`Minolta’s film carrier is capable of moving in longitudinal (e.g., front to back) and
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`transverse (e.g., side to side) directions.
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`28. At a high level, the features disclosed in the ‘019 Patent were not new
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`as of May 15, 2007, as further discussed below. My review of the documents
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`referenced in the preceding paragraph comports with my experience that those of
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`skill in the art before 2007 knew of and regularly worked with devices having the
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`features mentioned in the above paragraph. The figure below is a schematic
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`representation of the Fujinawa microform imaging apparatus (e.g., Ex. 1004 at Fig.
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`4) and is representative of the well known features of microform imaging
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`apparatuses.
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`29. Chassis have been used in microform readers since their inception to
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`support the different components of the microform reader. For example, the
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`chassis is used to support lenses, mirrors, motors, etc. As illustrated above, the
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`chassis may be in the form of a frame or other support structure to support the light
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`source, film carrier, fold mirror, lens, sensor, lead member, carriage(s) and/or
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`motor(s). For example, the 5100 Fiche ScanStation includes a chassis that
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`supports the other components of the microform reader. (Ex. 1007 at Fig. 2.1b).
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`Several other example microform readers also include a chassis. (Ex. 1004 at ¶
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`0033, Figures 3-6); (Ex. 1005 at 8:52-54, Figures 1, 2, 4, and 6-8); (Ex. 1006 at
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`5:9-13, Figure 1).
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`30. Lead members are one of the many ways, described above, that
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`microform readers move components within the device. For example, a lead
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`member may be used with a belt and a motor to move a lens, an image sensor,
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`and/or a film housing to ensure that the image is properly magnified and focused.
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`As illustrated above, the lead members (shown in blue) are supported by the
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`chassis and enable the carriage(s) (shown in red) to slide along the respective lead
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`members. In the illustration, both the sensor (shown in purple) and the lens
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`(shown in yellow) are supported by carriages (shown in red) such that both can be
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`moved along the respective lead member (shown in blue). Similarly, the 5100
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`Fiche ScanStation includes several different lead members that are used to support
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`components to slide along. (Ex. 1007 at Figure 2.1b, p. 17). Several other
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`example microform readers also include lead members. (Ex. 1004 at ¶ 0059,
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`Figures 3-6); (Ex. 1005 at 8:52-59, Figures 1-4, 10, and 12); (Ex. 1006 at 6:62-65,
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`Figure 2).
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`31. Mirrors have been used in microform readers to change the direction
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`of the light path within the device. Even the earliest of projector systems and
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`microform readers used mirrors to project images illuminated by a light source
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`onto a projector screen. In the same sense, fold mirrors are used in digital systems
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`to direct light towards the image sensor, which enables the optical components to
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`be positioned on different axes than the light source. As illustrated above, the fold
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`mirror (shown in green) is supported by the chassis and directs light from the light
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`source, through the lens (shown in yellow) to the sensor (shown in purple). For
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`example, the 5100 Fiche ScanStation includes a fold mirror that directs light
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`projected through the lens to the image sensor or CCD. (Ex. 1007 at Figures 2.2a
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`and 2.2b, p.16). Several other example microform readers also include fold
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`mirrors. (Ex. 1004 at ¶ 0039, Figures 3-6); (Ex. 1005 at 8:61-64, 12:1-33, Figures
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`17, 18, and 56); (Ex. 1006 at 5:24-27, Figures 1-4 and 6).
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`32. Drive mechanisms have been used in microform readers and other
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`devices to move components within the microform device. The drive mechanism
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`may link (e.g., couple or support) the carriage (shown in red) to the chassis via any
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`conventional technique such as a drive belt and pulley for moving the carriage
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`along the lead member. For example, the 5100 Fiche ScanStation includes several
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`drive mechanisms that use different belts, pulleys, and guide rails to move
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`components within the device. (Ex. 1007 at p. 15-18, 27). Several other example
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`microform readers also include drive mechanisms. (Ex. 1004 at ¶ 0059, Figures 3-
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`6); (Ex. 1005 at 9:11-18, Figures 1, 2, and 4); (Ex. 1006 at 6:62 to 7:3, Figure 2).
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`33. Carriages have been used in microform readers and other devices to
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`support components, especially components that move within the microform
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`device. For example, lenses and image sensors may be attached to carriages to
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`provide additional support and to position the components within the device. As
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`illustrated above, carriages (shown in red) couple the optical components (e.g., lens
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`and sensor) to the lead member (shown in blue) such that they can slide along the
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`lead member. The 5100 Fiche ScanStation includes several cards, or carriages,
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`that support different components within the device. For example, a camera card
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`provides a mount for the CCD and is adjustable along the optical axis to provide
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`fine focus adjustment. (Ex. 1007 at p. 16). Additionally, the camera card is
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`mounted on a series of brackets that provide rigidity and at the same time
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`adjustment of the CCD in three axes such that the whole card plus the CCD can be
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`moved along the optical axis by a small amount to obtain the optimum focus. (Ex.
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`1007 at p. 17). Several other example microform readers also include carriages.
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`(Ex. 1004 at ¶ 0059, Figures 3-6); (Ex. 1005 at 8:52-64, 9:11-17, Figures 1-3); (Ex.
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`1006 at 6:62 to 7:3, Figure 2).
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`34. Motors have been used in microform readers for various tasks. For
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`example, motors have been used in microform readers to advance and rewind film.
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`Similarly, motors have been used to move other components of the microform
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`reader such as the lens and/or the area sensor. For example, the 5100 Fiche
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`ScanStation includes a motorized lens to provide accurate focusing of the optical
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`system. (Ex. 1007 at p. 16). Additionally, the 5100 Fiche ScanStation includes
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`several motors that use different belts, pulleys, and guide rails to move components
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`within the device. (Ex. 1007 at p. 15-18, 27). Several other example microform
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`readers also include motors. (Ex. 1004 at ¶¶ 0039, 0041-0043, 0051, 0059, 0060,
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`Figures 3-6); (Ex. 1005 at 9:10-17, Figures 1, 2, and 4); (Ex. 1006 at 6:57-58, 6:65
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`to 7:3, 7:11-13, Figures 2-4).
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`35. As discussed above, with the advent of the computer and the
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`continuing advances in electronic storage, digital conversions of microform
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`became popular. (Ex. 1001 at 1:60-67). Microform readers were adapted with
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`image sensors such as line sensors and area sensors to capture the image
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`information from the projected film. As illustrated above, the sensor (shown in
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`purple), such as an area sensor, is supported by the carriage (shown in red) and is
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`used to capture image data of the microform. The carriage (shown in red) supports
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`the area sensor (shown in purple) for movement to adjust the distance between the
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`optical components (e.g., lens and fold mirror) to control the focus and the zoom of
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`the microform imaging apparatus. For example, the 5100 Fiche ScanStation
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`includes a CCD to digitize the film image. (Ex. 1007 at p. 7, p. 14-17). Several
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`other example microform readers also include image sensors such as area sensors.
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`(Ex. 1004 at ¶¶ 0009, 0039, 0049, 0055, 0059, 0112, Figures 3-6); (Ex. 1005 at
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`8:61-64, 11:63 to 12:6, 2:37-39, Figures 17, 18, 56); (Ex. 1006 at 6:62-65, 7:66-68,
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`10:4-13, Figure 2).
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`36. Lenses are used to magnify and/or focus the image on the film such
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`that the film is readable. As illustrated above, the lens (shown in yellow) is
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`supported by a carriage (shown in red), which is ultimately supported by the
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`chassis, and is positioned between the sensor (shown in purple) and the fold mirror
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`(shown in green). In other examples, the lens (shown in yellow) may be directly
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`coupled to and supported by the chassis. For example, the 5100 Fiche ScanStation
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`includes a lens that collects and focuses the light projected through the film onto
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`the image sensor. (Ex. 1007 at Figures 2.2a and 2.2b, p. 15-17). Several other
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`example microform readers also include lenses. (Ex. 1004 at ¶¶ 0039, 0055, 0059,
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`Figures 3-6); (Ex. 1005 at 8:61-64, 2:37-39, 12:1-6, Figures 17, 18, and 56); (Ex.
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`1006 at 5:22-27, Figures 1-4 and 6).
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`37. Film carriers or microform media support structures are used to
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`position and support the film within the device. As illustrated above, the film
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`carrier (shown in gray) is supported by the chassis, and is positioned above the
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`light source, which enables light to pass through the film to the other optical
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`components of the device. In other examples, the film carrier may be movable
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`such that the film can be moved in a transverse or longitudinal direction. For
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`example, the 5100 Fiche ScanStation includes a film loading area and film
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`cartridges that support film (e.g., fiche film). (Ex. 1007 at Figure 2.2b, p. 8, 16).
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`Several other example microform readers also include film carriers. (Ex. 1004 at
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`¶¶ 0039, 0045-0048, 0082, 0083, Figures 3-6); (Ex. 1005 at 14:8-16, 2:57-64,
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`Figures 19, 51-56); (Ex. 1006 at 7:13-22, Figures 2, 3); (Ex. 1008 at p. 1-5); (Ex.
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`1009).
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`38. The combinations I was asked to consider in the instant proceeding
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`(i.e., (1) Fujinawa combined with Kokubo, (2) Fujinawa combined with Minolta,
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`and (3) Fujinawa combined with Kokubo and Minolta) could and would have been
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`made by a person of ordinary skill in the art as of May 15, 2007. I was asked to
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`perform that task without using “hindsight” reasoning. Instead, I was asked to
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`consider the feasibility and combinability of references through the eyes of a
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`person of skill in the art as of May 15, 2007.
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`39. As I describe below, the individual references are all in the digital
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`microform imaging space and contain mechanical elements that could be combined
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`in a predictable manner.
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`LEVEL OF SKILL IN THE ART
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`40.
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`I was asked to provide my opinion about the experience and
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`background a person of ordinary skill in the art of the ‘019 Patent would have had
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`as of May 15, 2007. In my opinion, such a person of skill in the art would have
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`had at least a bachelor’s of science degree in either electrical engineering or
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`mechanical engineering with at least 3 years’ experience designing electro-
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`mechanical products including experience designing imaging equipment such as
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`copiers, scanners, and/or microform scanners and readers. Such a person would
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`understand the optical considerations and the mechanical constraints within these
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`devices.
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`41. Under my definition, I believe that I was a person of ordinary skill in
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`the art as of May 15, 2007. Furthermore, I believe that I can opine today about
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`what those of skill in the art would have known and understood as of May 15,
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`2007.
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`THE FUJINAWA PUBLICATION
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`42. As part of my work in this proceeding, I was asked to review U.S.
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`Patent Publication No. 2004/0012827 (“Fujinawa”) (Ex. 1004).
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`43. Fujinawa is entitled “Image Reading Apparatus” and is generally
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`directed an image reading apparatus for reading film images, in particular, an
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`image reading apparatus that can handle films having different sizes. (Ex. 1004 at
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`¶ 0003). Figures 1 and 3 to 6 of Fujinawa illustrate an “image reading apparatus.”
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`44. Fujinawa discloses a digital microform imaging apparatus. Fujinawa
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`describes that the “image signal processing circuit 15 amplifies, signal processes
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`and digitizes the signals from line sensor 28. The image signal processing circuit
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`also supplies the digitized signals to CPU 11.” (Ex. 1004 at ¶ 0064). Figure 4 of
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`Fujinawa is annotated and reproduced below as an example of a digital microform
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`imaging apparatus.
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`18
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 18 of 78
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`45. The image reading apparatus of Fujinawa includes a chassis. Figure 1
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`of Fujinawa illustrates “an image reading apparatus 1 including a cover 2 on an
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`upper surface thereof.” (Ex. 1004 at ¶ 0033). In my opinion, it is apparent that the
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`cover and other structural components are supported by a frame (e.g., chassis) that
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`gives sufficient structural integrity to the device.
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`46. Fujinawa further discloses that the chassis forms a first cavity and a
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`substantially horizontal window. Fujinawa explains “[a]s shown in FIGS. 3-6, the
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`image reading apparatus comprises, an insertion opening 6,” which “is located on
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`the side surface of the image reading apparatus.” (Ex. 1004 at ¶¶ 0039, 0033).
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`19
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`Page 19 of 78
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`Fujinawa also discloses that the “film detection sensor 35 and opposing rollers 36
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`are provided in insertion opening 6,” and that the “opposing rollers 37 convey 35
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`mm film, delivered from insertion opening 6 by the opposing rollers 36, to the
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`opposing rollers 38.” (Ex. 1004 at ¶¶ 0044, 0047). Further, Fujinawa discloses
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`that “[t]he insertion opening 6 is used for inserting the strip film 4 and slide-
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`mounted film 5.” (Ex. 1004 at ¶ 0033). Thus, the region within the opening 6
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`between the rollers forms a substantially horizontal window. Additionally, as
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`illustrated above, the region above the window is a second cavity and the region
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`below the window is a first cavity.
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`47. Fujinawa also discloses a housing cover with a top surface and a
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`bottom edge that forms a second cavity, the cover supported by the chassis with a
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`front portion of the cover positioned above the horizontal window and the second
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`cavity extending rearward from the front portion to a rear portion, the front portion
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`of the housing spaced from the horizontal window by a gap. Figure 1 of Fujinawa
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`“shows an image reading apparatus 1 including a cover 2 on an upper surface
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`thereof. The cover 2 is for opening and closing a cartridge chamber for loading a
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`cartridge 3.” (Ex. 1004 at ¶ 0033). As illustrated above, the front portion of the
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`housing is spaced from the horizontal window by a gap (e.g., the gap created by
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`the opening 6). Since the window is supported within the chassis, spacing the
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`window by a gap also discloses spacing the chassis by a gap.
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`20
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`Page 20 of 78
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`48. Fujinawa further discloses a first illumination source supported within
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`one of the cavities to direct light along a first optical axis through the horizontal
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`window and the gap and toward the other of the cavities. Additionally, Fujinawa
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`discloses that the first illumination source is controllable to direct light through the
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`microform media supported by the media support structure. The embodiments of
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`Fujinawa depict and describe a first illumination source (e.g., light source 31).
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`Specifically, Fujinawa discloses that the “image reading apparatus comprises… a
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`light source 31…” (Ex. 1004 at ¶ 0033). Additionally, Fujinawa discloses that
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`“[l]ight source 31 illuminates one surface of the film. The light source 31 is
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`controlled by the light source drive circuit 18. The light transmitted through the
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`film is introduced to the line sensor 28 via the lens 29. The light source 31
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`comprises light-emitting diodes (LEDs) of three colors, R (red), G (green) and B
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`(blue). In this case, the light source drive circuit 18 controls switching of lighting
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`and extinguishing of the three colors of LEDs of the light source 31 following
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`instructions from CPU 11.” (Ex. 1004 at ¶¶ 0055-0056). Furthermore, “the
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`projected light of the light source 31 is input directly into the line sensor 28.” (Ex.
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`1004 at ¶ 0082). As illustrated above in Figure 4, the illumination source,
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`supported within the bottom cavity, directs light along a first optical axis (e.g.,
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`vertical axis) through the horizontal window and the gap and toward the top cavity.
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`Fujinawa also discloses an illumination sources controllable to direct light toward a
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`21
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`Page 21 of 78
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`second microform media supported by the media support structure so that the light
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`reflects from the microform media toward the fold mirror. Specifically, Fujinawa
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`discloses that “[w]hile the illustrated embodiment includes an architecture in which
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`light is transmitted through the film, the invention also can be applied to
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`architectures in which the light is reflected from the film.” (Ex. 1004 at ¶ 0058). In
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`my opinion, it would have been within the knowledge of one of ordinary skill in
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`the art to include both illumination sources (e.g., one that transmits light through
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`film and one that reflects light from the film) in the same imaging apparatus.
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`49. Fujinawa also discloses a fold mirror supported by the chassis and
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`including a reflecting surface for directing light from a first optical axis to a second
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`optical axis. Additionally, Fujinawa discloses that the fold mirror is supported
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`within the other of the cavities so that the reflecting surface forms a substantially
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`45 degree angle with the first optical axis. Fujinawa describes that “the image
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`reading apparatus comprises… a reflective mirror 30.” (Ex. 1004 at ¶ 0039; see,
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`e.g., at Figures 3 to 6). Figure 4 of Fujinawa illustrates a fold mirror (e.g.,
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`reflective mirror 30) supported by the chassis, the fold mirror including a reflective
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`surface for directing light from a first optical axis (e.g., the vertical axis) to a
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`second optical axis (e.g., the horizontal axis). As discussed above, the components
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`(e.g., reflective mirror 30) are supported within the image reading apparatus. In
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`my opinion, the components, such as the fold mirror, are supported by a chassis.
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`22
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`Page 22 of 78
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`Additionally Figures 3 to 6 of Fujinawa illustrate that the fold mirror (e.g.,
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`reflective mirror 30) has a top edge and a bottom edge and is supported within the
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`top cavity. The top and bottom edges are at first and second heights and the lens
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`and area sensor are located between the first and second heights. As illustrated in
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`the Figures, the fold mirror (e.g., reflective mirror 30) forms a substantially 45
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`degree angle with the first optical axis and reflects (e.g., directs) light such that an
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`angle between the first optical axis and the second optical axis is substantially 90
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`degrees.
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`50. Figures 3 to 6 of Fujinawa illustrate a first elongated and substantially
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`straight lead member (e.g., worm connected to rotating shaft of motor 26)
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`supported by the chassis and aligned along a substantially horizontal axis, the first
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`lead member including an elongated shaft. Specifically, Fujinawa states that the
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`“sensor 28 is supported by a worm that couples the line sensor to the rotating shaft
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`of the [reading] motor 26 so that the position of the light-receiving surface can be
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`moved in ac
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