throbber
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
`
`_____________________
`
`CASE: IPR2017-00346
`U.S. PATENT NO. 9,197,766
`_____________________
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`
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`DECLARATION OF ANTHONY J. SENN, P.E.
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`DIGITAL CHECK CORP. EXHIBIT 1002
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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. 9,197,766 (which I refer to as the ‘766 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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`
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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 ‘766 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. 9,197,766
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`20. The ‘766 Patent is titled “Digital Microform Imaging Apparatus.”
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`(Ex. 1001). It was filed on September 26, 2014, as a continuation of an application
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`that issued as U.S. Patent No. 9,179,019, which was a continuation of an
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`application that issued as U.S. Patent No. 8,537,279, which was a continuation of
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`an application that issued as U.S. Patent No. 8,269,890. I have been asked to
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`assume (and I have assumed) for purposes of my analysis that the ‘766 Patent has
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`an 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 38) as of May 15, 2007.
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`21. The
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`‘766 Patent discloses microform
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`imaging apparatuses.
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`Microform readers were well known long before the ‘766 Patent. The ‘766 Patent
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`acknowledges that the principle features of microform readers–a chassis/support
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`structure, a mirror, a lens, an image sensor, a film carrier, and an adjuster–were
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`well known many years before May 15, 2007. (Ex. 1001 at 1: 39-42, 2:25-38, and
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`2:51-52). The ‘766 Patent further recognizes that the digital aspects incorporated
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`into the claimed invention were not novel. (Ex. 1001 at 2:30-33 and 2:51-52).
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`Rather, digitization of microfilm was a natural result of the prevalence of
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`computers and the digital age. (Ex. 1001 at 1:63-2:3).
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`22. The ‘766 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 ‘766 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 ‘766 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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`‘766 Patent. The ‘766 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 1:48-50, 2:2-3, 2:25-27, 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. The various configurations discussed above can be used to
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`move the lens and image sensor through ranges of motion.
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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 1:63-2:3).
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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 Wally disclose microform imaging apparatuses that
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`include a chassis/support structure, a fold mirror, an image sensor, a lens, and film
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`carriers. Additionally, Fujinawa and Wally disclose an area sensor that is movable
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`within a first range of movement. Additionally, Fujinawa and Wally disclose a
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`lens that is movable within a second range of movement. The first range of
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`movement and the second range of movement in Wally and Fujinawa overlap.
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`Fujinawa also discloses a film carrier (e.g., microform media support structure)
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`and supply and take-up film roll attachments. Additionally, Minolta discloses a
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`film carrier with supply and take-up film roll attachments specifically designed to
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`be used with microform imaging apparatuses. Minolta’s film carrier is capable of
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`moving in longitudinal (e.g., front to back) and transverse (e.g., side to side)
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`directions.
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`28. At a high level, the features disclosed in the ‘766 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. Support structures and frames including a chassis and or a housing,
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`have been used in microform readers since their inception to support and/or
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`enclose the different components of the microform reader. For example, the
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`support structure is used to support lenses, mirrors, image sensors, etc. As
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`illustrated above, the support structure may include a frame and/or an enclosure to
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`support the light source, film carrier, fold mirror, lens, sensor, etc. For example,
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`the 5100 Fiche ScanStation includes a support structure that supports the other
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`components of the microform reader. (Ex. 1007 at Fig. 2.1b). Several other
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`example microform readers also include a support structure. (Ex. 1004 at ¶ 0033,
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`Figs. 3-6); (Ex. 1005 at 8:52-54, Figs. 1, 2, 4, and 6-8); (Ex. 1006 at 5:9-13, Fig.
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`1); (Ex. 1011 at 5:34-37, 5:20-45, Figs. 1 and 4).
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`30. Light sources have been used with image reading devices and in
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`microform readers to transmit light through the film and passed through optics,
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`such as a lens, and captured by an image sensor. For example, the 5100 Fiche
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`Scanstation includes a light source. (Ex. 1007 at pp. 8, 16, 18, Fig. 2.2a, Fig.
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`2.2b). It was well known in the prior art for the light source to direct light through
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`film along an optical axis of the device. (Ex. 1004 at ¶¶0039, 0055, 0058, 0059,
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`Figs. 3-6; Ex. 1005 at 8:59-66, Figs. 17 and 18; Ex. 1006 at 5:20-24, 6:54-57, Figs.
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`1-4; Ex. 1007 at 8, 16, 18, Fig. 2.2a, Fig. 2.2b; Ex. 1011 at 4:19-23, 5:45-46, 7:20-
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`30, Figs. 5, 9, 12).
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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/support structure and directs
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`light from the light source, through the lens (shown in yellow) to the sensor (shown
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`in purple). For example, the 5100 Fiche ScanStation includes a fold mirror that
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`directs light projected through the lens to the image sensor or CCD. (Ex. 1007 at
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`Figs. 2.2a and 2.2b, p.16). Several other example microform readers also include
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`fold mirrors. (Ex. 1004 at ¶ 0039, Figs. 3-6; Ex. 1005 at 8:61-64, 12:1-33, Figs.
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`17, 18, and 56; Ex. 1006 at 5:24-27, Figs. 1-4 and 6).
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`32. 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 1:63 to 2:3). 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 pp. 7, 14-17, Fig. 2.2b).
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`Several other example microform readers also include image sensors such as area
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`sensors. (Ex. 1004 at ¶¶ 0009, 0039, 0049, 0055, 0059, 0112, Figs. 3-6; Ex. 1005
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`at 8:61-64, 11:63 to 12:6, 2:37-39, Figs. 17, 18, 56; Ex. 1006 at 6:62-65, 7:66-68,
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`10:4-13, Fig. 2; Ex. 1011 at 7:31-40; 8:12-14; 8:34-40, Figs. 5, 6, 9).
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`33. 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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`support structure, such as a chassis, and is positioned between the sensor (shown in
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`purple) and the fold mirror (shown in green). In other examples, the lens (shown
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`in yellow) may be directly coupled to and supported by the support structure or
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`chassis. For example, the 5100 Fiche ScanStation includes a lens that collects and
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`focuses the light projected through the film onto the image sensor. (Ex. 1007 at
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`Figs. 2.2a and 2.2b, pp. 15-17). Several other example microform readers also
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`include lenses. (Ex. 1004 at ¶¶ 0039, 0055, 0059, Figs. 3-6; Ex. 1005 at 8:61-64,
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`2:37-39, 12:1-6, Figs. 17, 18, and 56; Ex. 1006 at 5:22-27, Figs. 1-4 and 6; Ex.
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`1011 at 8:41-51, Figs. 5, 6, 12).
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`34. 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 Fig. 2.2b, pp. 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, Figs. 3-6; Ex. 1005 at 14:8-16, 2:57-64, Figs. 19,
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`51-56; Ex. 1006 at 7:13-22, Figs. 2, 3; Ex. 1008 at pp. 3-5, 7; Ex. 1009; Ex. 1011
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`at 5:45-53, 5:60-63, 6:3-7, Fig. 11).
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`35. Accessory film carriers and universal film carriers (e.g., microform
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`media support structures) were well known for their versatile design, enabling
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`them to work with a wide variety of microform media and multiple models of
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`microform readers, regardless of the mechanics of the readers. Such accessory
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`film carriers (e.g., microform media support structures) could be independently
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`designed and sold separately from microform readers, yet still be entirely
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`compatible with the microform readers. As discussed above, some microform
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`readers included their own microform media support structures. (Ex. 1004 at ¶¶
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`0039, 0045-0048, 0082, 0083, Figs. 3-6; Ex. 1005 at 14:8-16, 2:57-64, Figs. 19,
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`51-56; Ex. 1006 at 7:13-22, Figs. 2, 3; Ex. 1007 at Fig. 2.2b, pp. 8, 16; Ex. 1011 at
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`5:45-53, 5:60-63, 6:3-7, Fig. 11). In other instances, accessory film carriers were
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`separately sold, which were capable of fitting on or into various microform readers
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`to work in conjunction with the reader’s mechanical and optical components. (Ex.
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`1008 at pp. 3, 4, 10; Ex. 1009). For example, the accessory film carrier (e.g.,
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`microform media support structure) could fit above the microform reader’s light
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`source thereby allowing the projected film image to be passed through the optical
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`components (e.g., fold mirror, lens, etc.) to the image sensor. (Ex. 1008 at pp. 3-7;
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`Ex. 1009).
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`36. The combinations I was asked to consider in the instant proceeding
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`(i.e., (1) Fujinawa combined with Minolta and (2) Fujinawa combined with
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`Minolta and Wally) could and would have been made by a person of ordinary skill
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`in the art as of May 15, 2007. I was asked to perform that task without using
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`“hindsight” reasoning. Instead, I was asked to consider the feasibility and
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`combinability of references through the eyes of a person of skill in the art as of
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`May 15, 2007.
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`37. 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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`38.
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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 ‘766 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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`39. 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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`40. 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).
`
`41. 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.”
`
`42. 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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`43. The image reading apparatus of Fujinawa includes a support structure.
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`Figure 1 of Fujinawa illustrates “an image reading apparatus 1 including a cover 2
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`on an upper surface thereof.” (Ex. 1004 at ¶ 0033). In my opinion, it is apparent
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`that the cover and structural components of Fujinawa create a support structure that
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`gives sufficient structural integrity to the device. Additionally, in my opinion, one
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`of skill in the art would understand a support structure and an assembly support
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`structure to be equivalent structures.
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`18
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 18 of 61
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`44. Fujinawa further discloses that the support structure forms first and
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`second cavities, the first and second cavities spaced apart to form a substantially
`
`horizontal gap there between. 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 [and] is used for inserting the strip
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`film 4 and slide-mounted film 5.” (Ex. 1004 at ¶¶ 0039, 0033). Fujinawa also
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`discloses that the “film detection sensor 35 and opposing rollers 36 are provided in
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`insertion opening 6,” and that the “opposing rollers 37 convey 35 mm film,
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`delivered from insertion opening 6 by the opposing rollers 36, to the opposing
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`rollers 38.” (Ex. 1004 at ¶¶ 0044, 0047). Thus, the region within the opening 6
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`between the rollers forms a substantially horizontal gap. Additionally, as
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`illustrated below in Figure 4, the region above the gap is the second cavity and the
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`region below the gap is the first cavity. Furthermore, Figure 4 of Fujinawa
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`illustrates that the second cavity is formed above the gap. Thus, Fujinawa also
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`discloses that the second cavity is located above the microform media support
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`structure as further illustrated below. For example, Figure 4 of Fujinawa depicts
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`that the second cavity is located above the microform media support structure. As
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`discussed in more detail below, the combination of Fujinawa and Minolta also
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`discloses a support structure that forms first and second cavities spaced apart by a
`
`gap.
`
`19
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 19 of 61
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`(Ex. 1004 at Fig. 4).
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`45. Fujinawa further discloses a microform media support structure.
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`Specifically, Fujinawa discloses that “[w]hen the leading end of the film original
`
`arrives at the reading position between the opposing rollers 38 and 39, the
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`projected light of the light source 31 is blocked by the film original. It can also be
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`transmitted through the film original.” (Ex. 1004 at ¶ 0083). Additionally,
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`Fujinawa discloses that “[l]ight source 31 illuminates one surface of the film. The
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`light source 31 is controlled by the light source drive circuit 18. The light
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`transmitted through the film is introduced to the line sensor 28 via the lens 29.”
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`20
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 20 of 61
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`(Ex. 1004 at ¶ 0055). Fujinawa further discloses that “CPU 11 controls the
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`opposing roller drive circuit 20, which receives the detection signal from film
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`detection sensor 35. The opposing roller drive circuit 20 controls rotation of the
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`opposing rollers 36. The opposing roller drive circuit 20 receives instructions from
`
`CPU 11. As a result, the strip film 4 and slide-mounted film 5 are provided to the
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`conveyor path (see FIGS. 5-6). Along the conveyor path are opposing rollers 37, a
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`magnetic head 33, an optical sensor 34, opposing rollers 38, opposing rollers 39, a
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`magnetic head 32, opposing rollers 40, and a take-up chamber 41. The light source
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`31 is provided between opposing rollers 38 and 39.” (Ex. 1004 at ¶¶ 0045-0046).
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`Additionally, Fujinawa states that the “opposing rollers 37, 38, 39 and 40 are
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`driven separately by the opposing roller drive circuit 20. The opposing rollers 37
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`convey roll film 7, delivered from loading chamber 22, to the opposing rollers 38.
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`The opposing rollers 37 convey 35 mm film, delivered from the insertion opening
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`6 by the opposing rollers 36, to the opposing rollers 38.” (Ex. 1004 at ¶ 0047).
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`Fujinawa also discloses that after the film enters the reading apparatus, “opposing
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`rollers 38 and 39 feed the film original at a constant speed during image reading.
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`The opposing rollers 40 convey the film (roll film 7 and strip film 4), to take-up
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`chamber 41.” (Ex. 1004 at ¶ 0048). Thus, the opposing rollers support the
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`microform media within the digital microform imaging apparatus. As illustrated
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`above in Figure 4 of Fujinawa, the media support structure is located within the
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`21
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 21 of 61
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`gap. In my opinion, one of skill in the art would understand that the media support
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`structure is mounted within the gap.
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`46. While Fujinawa does not explicitly disclose that the microform media
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`support structure is mounted for movement along a substantially horizontal
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`longitudinal direction and a substantially horizontal transverse direction that is
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`substantially perpendicular to the longitudinal direction. In my opinion, it would
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`have been within the knowledge of one of ordinary skill in the art to mount the
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`media support structure within the gap for movement in a longitudinal direction
`
`and transverse direction. Additionally, as discussed in more detail below, in my
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`opinion, the combination of Fujinawa with Minolta fully discloses a microform
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`media support structure mounted within the horizontal gap for movement along a
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`substantially horizontal longitudinal direction and a substantially horizontal
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`transverse direction that is substantially perpendicular to the longitudinal direction.
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`For example, replacing the front-to-back arrangement of film attachments in
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`Fujinawa with the movable side-by-side arrangement of Minolta would result in
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`microform media support structure mounted within the horizontal gap for
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`movement along a substantially horizontal
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`longitudinal direction and a
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`substantially horizontal transverse direction that is substantially perpendicular to
`
`the longitudinal direction.
`
`22
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 22 of 61
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`47. Fujinawa also discloses a housing that forms the second cavity. As
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`illustrated above with respect to Figure 4, Fujinawa includes an enclosure (e.g.,
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`cover subassembly) that forms a space that encloses all the internal components of
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`the reading apparatus (e.g., motors, area sensors, lens, fold mirror, etc.).
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`Specifically, Fujinawa discloses a “reading apparatus 1 including a cover 2 on an
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`upper surface thereof. The cover 2 is for opening and closing a cartridge chamber
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`for loading a cartridge 3.” (Ex. 1004 at ¶ 0033). Additionally, Fujinawa discloses
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`that the apparatus further includes a supply side or source roll film attachment and
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`a take up roll film attachment that are supported by the chassis on opposite lateral
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`sides of the housing. For example, Fujinawa discloses that the supply side roll film
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`arrives from “the cartridge 3 to a conveyor path. When the cartridge motor 23 is
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`driven backward, the roll film 7 is taken up inside cartridge 3 from the conveyor
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`path (See FIG. 4).” (Ex. 1004 at ¶ 0051). Additionally, Fujinawa discloses that
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`after the film enters the reading apparatus, “opposing rollers 38 and 39 feed the
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`film original at a constant speed during image reading. The opposing rollers 40
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`convey the film (roll film 7 and strip film 4), to take-up chamber 41.” (Ex. 1004 at
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`¶ 0048). As discussed above, the components (e.g., supply side roll and take up
`
`side roll film attachments) are supported within the image reading apparatus,
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`which includes a support structure and chassis. Thus, the components, such as the
`
`film attachments, are supported by the support structure and/or chassis. Figure 4 of
`
`23
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`DIGITAL CHECK CORP. EXHIBIT 1002
`Page 23 of 61
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`Fujinawa illustrates a supply side roll film attachment (shaded in blue below) and a
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`take up side roll film attachment (shaded in purple below) supported by the support
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`structure and/or chassis.
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`
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`(Ex. 1004 at Fig. 4).
`
`48. While Fujinawa does not explicitly disclose that the film attachments
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`are supported on opposite lateral sides of the housing, this would have been within
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`the knowledge of one of skill in the art in view of the disclosures of Minolta. One
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`of skill in the art would recognize that Minolta’s side-by-side arrangement of film
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`attachments and support structure could be substituted for Fujinawa’s front-to-back
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`arrangement of film attachments and support structure to achieve the same,
`
`24
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`DIGITAL CHECK CORP. E

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