Unified Patents Inc. v. Jakuta Diodes, LLC, IPR2017-00379 (Dec. 7, 2016)

DOCKET NO.
: 2211726-00137
Filed on behalf of Unified Patents Inc.
By: David L. Cavanaugh, Reg. No. 36,476
Daniel V. Williams 45,221
Wilmer Cutler Pickering Hale and Dorr LLP
1875 Pennsylvania Ave., NW
Washington, DC 20006
Tel: (202) 663-6000
Email: David.Cavanaugh@wilmerhale.com
Jonathan Stroud, Reg. No. 72,518
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Washington, DC, 20009
Tel: (202) 805-8931
Email: jonathan@unifiedpatents.com
UNITED STATES PATENT AND TRADEMARK OFFICE
____________________________________________
BEFORE THE PATENT TRIAL AND APPEAL BOARD

____________________________________________
UNIFIED PATENTS INC.

Petitioner
v.
JAKUTA DIODES, LLC
Patent Owner
IPR2017-00379
Patent 6,079,854
PETITION FOR INTER PARTES REVIEW OF
US PATENT NO. 6,079,854
CHALLENGING CLAIMS 3, 4, 7-11, 19 and 27
UNDER 35 U.S.C. 312 AND 37 C.F.R. 42.104
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US Patent No. 6,079,854
TABLE OF CONTENTS
Page
I.
MANDATORY NOTICES ............................................................................. 1

A.
B.
C.
D.
Real Party-in-Interest ............................................................................ 1

Related Matters...................................................................................... 1
Counsel .................................................................................................. 2
Service Information, Email, Hand Delivery and Postal ........................ 2
II.
CERTIFICATION OF GROUNDS FOR STANDING .................................. 2
III.
OVERVIEW OF CHALLENGE AND RELIEF REQUESTED .................... 2

A.
Prior Art Patents and Printed Publications ............................................ 3

1.
B.
US Pat. 5,764,845 (filed on June 24, 1994; issued on June 9,

1998) (Nagatani (EX1002)), which is prior art under 35
U.S.C. 102(e) ........................................................................... 3
Grounds for Challenge .......................................................................... 3
IV.
TECHNOLOGY BACKGROUND................................................................. 3
V.
OVERVIEW OF THE 854 PATENT ............................................................ 7

A.
B.
C.
VI.
Summary of the Alleged Invention ....................................................... 7

Level of Ordinary Skill in the Art ....................................................... 12
Prosecution History ............................................................................. 13
CLAIM CONSTRUCTION .......................................................................... 18

A.
Diffusing Light .................................................................................... 19
VII. SPECIFIC GROUNDS FOR PETITION ...................................................... 20

A.
Ground I: Claims 3, 4, 7-11, 19 and 27 are rendered obvious by

Nagatani............................................................................................... 21
1.
2.
3.
4.
Overview of Nagatani ............................................................... 21

Claim 3 is obvious in view of Nagatani ................................... 32
Claim 4 is obvious in view of Nagatani .................................... 41
i
5.
6.
7.
8.
9.
10.
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Claim 8 is obvious in view of Nagatani. ................................... 44
Claim 10 is obvious in view of Nagatani .................................. 47
VIII. CONCLUSION.............................................................................................. 66
ii
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I.
MANDATORY NOTICES
A.
Real Party-in-Interest
Pursuant to 37 C.F.R. 42.8(b)(1), Unified Patents Inc. (Unified or

Petitioner) certifies that Unified is the real party-in-interest, and further certifies
that no other party exercised control or could exercise control over Unifieds
participation in this proceeding, the filing of this petition, or the conduct of any
ensuing trial. In this regard, Unified has submitted voluntary discovery. See
EX1016 (Petitioners Voluntary Interrogatory Responses).
B.
Related Matters
US Pat. No. 6,079,854 (854 patent Patent (EX1001)) is owned by Jakuta

Diodes, LLC (Jakuta Diodes or Patent Owner).
The 854 patent is the subject of the following district court proceedings
Jakuta Diodes, LLC v. Acuity Brands, Inc., 6:16-cv-01175-RWS (E.D.
Tex.); Jakuta Diodes, LLC v. Ford Motor Company, 6:16-cv-01177-RWS (E.D.
Tex.); Jakuta Diodes, LLC v. American Honda Motor Co Inc, 6:16-cv-01178-RWS
(E.D. Tex.); Jakuta Diodes, LLC v. Soraa, Inc., 6:16-cv-01179-RWS (E.D. Tex.);
Jakuta Diodes, LLC v. General Motors Company, 6:16-cv-01180-RWS (E.D.
Tex.); and Jakuta Diodes, LLC v. Ledengin, Inc., 6:16-cv-01181-RWS (E.D. Tex.).
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C.
Counsel
David L. Cavanaugh (Reg. No. 36,476) will act as lead counsel; Jonathan
Stroud (Reg. No. 72,518), and Daniel Williams (Reg. No. 45,221) will act as backup counsel.
D.
Service Information, Email, Hand Delivery and Postal
Unified consents to electronic service at david.cavanaugh@wilmerhale.com

and jonathan@unifiedpatents.com. Petitioner can be reached at Wilmer Cutler
Pickering Hale and Dorr, LLP, 1875 Pennsylvania Ave., NW, Washington, DC
20006, Tel: (202) 663-6000, Fax: (202) 663-6363, and Unified Patents Inc., 1875
Connecticut Ave. NW, Floor 10, Washington, DC 20009, (650) 999-0899.
II.
CERTIFICATION OF GROUNDS FOR STANDING

Petitioner certifies pursuant to Rule 42.104(a) that the patent for which
review is sought is available for inter partes review and that Petitioner is not
barred or estopped from requesting an inter partes review challenging the patent
claims on the grounds identified in this Petition.
III.
OVERVIEW OF CHALLENGE AND RELIEF REQUESTED

Pursuant to Rules 42.22(a)(1) and 42.104(b)(1)(2), Petitioner challenges
claims 3, 4, 7-11, 19 and 27 of the 854 Patent.
A.
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Prior Art Patents and Printed Publications
The following references are pertinent to the grounds of unpatentability

explained below:1
1.
US Pat. 5,764,845 (filed on June 24, 1994; issued on June 9,

1998) (Nagatani (EX1002)), which is prior art under 35
U.S.C. 102(e)
B.
Grounds for Challenge
This Petition, supported by the declaration of Donald B. Carlin (Carlin

Declaration or Carlin (EX1003)), requests cancellation of challenged claims 3,
4, 7-11, 19 and 27 as unpatentable under 35 U.S.C. 103. See 35 U.S.C. 314(a).
IV.
TECHNOLOGY BACKGROUND
As used in the 854 patent, a diffuser is a device that spreads out light or
causes light rays to diverge. A lens can act as a diffuser by dispersing light
through refraction. Lenses are often described by the curvature of their surfaces.
Each surface can be convex, concave, or planar. A lens with two concave surfaces
is biconcave or often just called concave. If one of the surfaces is flat and the other
concave, the lens is typically called plano-concave. Such a lens will cause incident
rays to diverge at a greater angle than their angle of incidence. Such lenses may
also be termed negative or diverging lenses. If one of the surfaces is flat and the
1
The 854 Patent issued from a patent application filed prior to enactment of the
America Invents Act (AIA). Accordingly, pre-AIA statutory framework applies.
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other convex, the lens is typically called plano-convex. A lens that is either
biconvex (often simply referred to as convex) or plano-convex will cause incident
light rays to converge. These may also be termed positive or converging lenses.
(Carlin 22 (EX1003)).
Light pipes or related optical channels (e.g., optical fibers) can also be used
as components in optical systems that spread light. In fact, well before the
February 1998 filing date of the 854 patent, it was known to provide light fixtures
with channels for spreading light. For example, JPH01-079204, published on May
29, 1989, discloses a lighting device, shown below, that includes a plurality of light
channels 4 that disperse light to a lens 3, which then provides additional dispersion,
as shown below in reproduced Figures 1, 2 and 5. (Carlin 23 (EX1003)).
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(JPH01-079204, Figure 1, 2 and 5 (EX1004) (annotations added)).

Further, JPH04-133832, published on May 7, 1992, discloses a lighting
device that comprises multiple lenses 29a-29g that spread light, as shown below in
reproduced Figure 1. (Carlin 24 (EX1003)).
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(JPH04-133832, Figure 29 (EX1005)).

It was also known to form light channels with various shapes to affect how
light is dispersed. For example, US Pat. No. 5,839,823 (Hou), filed on March
26, 1996, published on Nov. 24, 1998, discloses a lighting device comprising a
plurality of channels 22 in the form of microprisms that are tapered outwardly.
(Hou, 3:14-25, Figure 2 (EX1006)). The channels may be formed in various
shapes, as shown in Figures 6-12. (Id. at 3:26-34, Figures 6-12 (EX1006)). Hou
also discloses that dimensions of the channels can be changed to affect how the
light is dispersed. (Id. at 3:44-48 (EX1006) (the output angular distribution can
be increased by increasing the surface area of the input surface 132, along with
reducing the height of the sidewall 136 and increasing the size of the obtuse tilt
angles .)). (Carlin 25 (EX1003)).
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Thus, the above-noted references reveal that it was well known in the art to
diffuse light using lenses and light channels. (Id. 26 (EX1003)).
V.
OVERVIEW OF THE 854 PATENT

A.
Summary of the Alleged Invention
The 854 patent relates to directing light. (854 patent at 1:6-8 (EX1001)).
Figure 1 of the 854 patent is reproduced below to show light assembly 10. (Id. at
3:26-38 (EX1001)).
The assembly 10 includes a housing 12, a reflecting surface 14, and a lens
cover 16. (Id. at 3:58-60 (EX1001)). A luminous body 18, such as a light bulb,
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extends through a rear wall of the housing 12 to provide a primary light beam
indicated generally by arrows 20. (Id. at 3:60-64 (EX1001)). A concave lens 22 is
disposed in the housing 12 between the reflector 14 and the lens cover 16. (Id. at
3:65-67 (EX1001)). The 854 patent states that the concave lens 22 is a first
diffuser means. (Id. (EX1001)). The 854 patent discloses that primary light
beam 20 passes through the concave lens 22 to be diffused further into the
secondary chamber 26 as a secondary light beam indicated generally by arrows
32. (Id. at 4:13-16 (EX1001)). As shown by Figure 1, the diffusion by concave
lens 22 provides secondary light beams 32 that are more spread-out relative to
primary light beams 20.
(Id. at Figure 1 (EX1001)); (Carlin 28 (EX1003)).
The secondary light beams 32 are further diffused in secondary chamber 26

by a second light diffuser means 34 shown in Figure 2, which is reproduced
below. (854 patent at 4:17-19 (EX1001)); (Carlin 29 (EX1003)).
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Light diffuser 34 is constructed from a plurality of cells 36. (854 patent at

4:20-22 (EX1001)). The cells 36 are nested along their respective sidewalls 38, so
that preferably, none of the secondary light 32 is permitted to pass between the
abutting sidewalls of the respective cells 36. (Id. at 4:34-38 (EX1001)). The 854
patent discloses that the cells 36 can be manufactured of substantially any
material, provided the material is heat resistant to the effects of light emitted from
the bulb 18. (Id. at 4:41-43 (EX1001)). The 854 patent further discloses that the
material to construct the cells 36 is preferably substantially opaque, but can be
translucent. (Id. at 4:43-45 (EX1001)); (Carlin 30 (EX1003)).
The cells 36 have a tapered diameter such that the widest portion of each
one of the cells 36 faces the lens cover 16, with each one of the cells tapering to a
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reduced diameter as it extends toward the bulb 16 of the headlamp 10. (854
patent at 4:25-29 (EX1001)). The narrowest end of each one of the cells 36
collectively forms a light receiving region 37. (Id. at 4:29-31 (EX1001)). The
widest end of each one of the cells 36 collectively forms a light transmitting region
39. (Id. at 4:31-33 (EX1001)). The 854 patent discloses that the individual
construction of each cell 36 and the ganged arrangement 34 of a plurality of the
cells 36 is to provide a radiating honeycomb to diffuse light rays 20, 32. (Id. at
4:46-48 (EX1001)). Therefore, cells 36 radiate light in a spread out manner. (Id.
at Figure 1 (EX1001)); (Carlin 31 (EX1003)).
The 854 patent discloses that the cells of Figure 2 act to disperse light.
(854 patent at 5:13-15 (EX1001)). Thus, since the light diffuser 34 of Figure 2 is
described as dispersing the light, one of ordinary skill in the art would have
understood that the inventors intended to equate diffusing with dispersing. (Carlin
32 (EX1003)). One of ordinary skill in the art would have also understood that
diffusing or dispersing light corresponds to spreading out or widening light. (Id. at
32 (EX1003)). This is because the light that is output by concave lens 22 (which
is disclosed as being a first diffuser means) is spread out relative to primary light
beams 20, and the light that is output by second light diffuser means 34 is also
projected in a spread out manner. (Id. at 32 (EX1003)).
10
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The 854 patents correlation between the diffusing means and light that is
spread-out or widened is consistent with the widened light beams 54 and 56 shown
in Figure 4. Figure 4 is reproduced below to show diffused or spread out light
produced by the embodiment of Figure 2 in comparison to a conventional light.
(854 patent at 3:36-39, 4:63-65 (EX1001)). Figure 4 shows low and high beams
54, 56 produced by the light diffuser of Figure 2, and high and low beams 48, 50
produced by a conventional design. (Id. at 4:66-5:5 (EX1001)); (Carlin 33
(EX1003)).
As shown by annotated Figure 4, light beam 56 is more spread out relative to

light beam 50. Similarly, light beam 54 is more spread out relative to light beam
11
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48. Therefore, Figure 4 further shows how diffusing or dispersing light, as
discussed in the 854 patent, corresponds to spreading out or widening light. (Id.
34 (EX1003)).
The challenged claims do not limit their application to a particular type of
light related implementation. Claims 3, 4, and 7-11 are broadly directed to [a]
light fixture; claim 19 is directed to [a] device for diffusing light from a
luminous body; and claim 27 is directed to [a] method of diffusing light.
In additional to vehicle headlamps, the 854 patent discusses US Pat. No.
5,032,955 to Jurgens that discloses a mud flap mounted lighting system. (854
patent at 1:51-55 (EX1001)). The face of the 854 patent also deviates from vehicle
headlamps by citing US Pat. No. 5,191,264 directed to a large table mounted
lighting system, US Pat. No. 5,122,940 directed to providing backlighting for
photography, US Pat. No. 4,112,483 directed to lighting for streets and parking
lots, and US Pat. No. 5,810,469 that discloses a lighting structure for LCD display
screens.
B.
Level of Ordinary Skill in the Art
A person of ordinary skill in the art for the 854 patent would have been an
optical engineer having the equivalent of a bachelors degree or equivalent
knowledge obtained through work experience, including several years of
experience in the design of optical systems. (Carlin 47 (EX1003)).
12
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C.
Prosecution History
The 854 patent issued from US Pat. Appl. No. 09/023,528, which was filed
on February 13, 1998 (File History, Application (2/13/1998) (EX1007)). A nonfinal Office Action was mailed on May 27, 2009, rejecting claims 1-30. (File
History, Office Action (5/27/2009) (EX1008)). Independent application claims 3,
21 and 30 issued respectively as challenged claims 3, 19 and 27. Hereinafter the
independent application claims will be referenced by their issued claim numbers,
i.e., 3, 19 and 27.
Claim 3 was rejected under 35 U.S.C. 103(a) as unpatentable over US Pat.
No. 5,122,940 (Wiegand) in view of US Pat. No. 4,112,483 (Small). (File
History, Office Action at pp. 4-5 (EX1008)). Wiegand is generally directed to
providing banklighting for photography (Wiegand at 1:6-10 (EX1009)) and Small
is generally directed to lighting for streets and parking lots (Small at 1:9-15
(EX1010)).
Claim 19 was rejected under 35 U.S.C. 103(a) as unpatentable over US
Pat. No. 5,810,469 (Weinriech) in view of Wiegand. (File History, Office
Action at pp. 5-6 (EX1008)). Weinriech is generally directed to a lighting
structure for computer display screens. (Weinriech at 1:7-17 (EX1011)).
Claim 27 was rejected under 35 U.S.C. 103(a) as unpatentable over US
Pat. No. 5,810,469 (Weinriech) in view of Wiegand and US Pat. No. 5,113,321
13
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(Suzuki). (File History, Office Action pp. 6-7 (EX1008)). Suzuki is generally
directed to a vehicle lamp. (Suzuki at 1:6-9 (EX1012)).
Applicant filed a Response dated October 26, 1999 amending claims 3, 19
and 27:
3. (Amended) A light fixture, comprising:
a housing having an interior region extending to an
opening for the housing;
means for illuminating the housing operatively associated
with the interior region of the housing; and
means for diffusing light emitted from the illuminating
means, the diffusing means disposed at the interior region of the
housing between the illuminating means and the opening to
collect light from the illuminating means and transmit the light to
be radiated in a diffused pattern to the opening of the housing
comprising:
a body portion having:
a first end for receiving light from the illuminating means,
a second end opposite to the first end and facing the
opening of the housing for radiating light to the opening, and
a plurality of channels tapering outward toward the second
end, and extending between the first end and the second end for
diffusing light transmitted therethrouqh from the first end to the
second end,
wherein the light radiated from the second end is in the
diffused pattern to exit the opening of the housing.
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(File History, Response at 4-5 (10/26/1999) (EX1013)).
19.
(Amended) A device for diffusing light from a
luminous body, the device comprising:

a truncated body having:
a first truncated region at a first side of the truncated body
for receiving light from the luminous body;
a second truncated region at a second side of the truncated
body substantially opposite to the first side and adapted for
emitting light; and
a central region interconnecting the first and second
truncated regions, the central region increasing in diameter from
the first truncated region to the second truncated region and
adapted for diffusing the light transmitted along the central
region for providing a diffused pattern of light emitted from the
second truncated region.
(Id. at 8 (EX1013)).
27. (Amended) A method of diffusing light, comprising the steps of:

providing a light source from which light radiates;
interrupting the light with a substantially transparent member;
segregating a substantial portion of the light to a plurality of channels
within the member;
[diffusing] dispersing the light transmitted in a widening ray along the
plurality of channels; and
15
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radiating a diffused pattern of light emitted from the plurality of
channels.
(Id. at 10 (EX1013)).
Applicant argued that the prior art failed to disclose or suggest the plurality
of channels tapering outward toward the second end., recited in claim 3. (Id. at
13-14 (EX1013)). With respect to claim 19, Applicant argued that the prior art
does not suggest the recited central region increasing in diameter from the first
truncated region to the second truncated region. (Id. at 15-16 (EX1013)). For
claim 27, Applicant argued that prior art does not suggest the claimed dispersing
the light transmitted in a widening ray. (Id. at 16 (EX1013)).
Without further rejection, a Notice of Allowability was mailed on January
27, 2000 allowing the pending claims. (File History, Notice of Allowability
(1/27/2000) (EX1014)). The Examiner newly cited US Pat. No. 4,743,082
(Mori) in the statement of reasons for allowance. (Id. at 2 (EX1014)). The
Examiner asserted that Mori discloses channels for transmitting light, but the light
is not diffused. (Id. (EX1014)).
Mori discloses a light conducting member for guiding sunlight or the like
incident on one end thereof to a desired location and, more particularly, to a bundle
of light conducting cables which constitutes the light conducting member and are
integrated at one end thereof to form the light incidence end. (Mori at 1:9-15
(EX1015)). Figure 7 of Mori is reproduced below to shown a cable assembly 20
16
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2
and conducting rod 60. (Id. at 3:14-18 (EX1015)). Element 32 is described as
bonding the cable assembly 20 to the conducting rod. (Id. at 14-16 (EX1015)).
(Id. at Figure 7 (EX1015)). In use, light is supplied to the conducting rod and
distributed to the cable assembly 20. (Id. at 3:44-49; 4:6-12 (EX1015)).
Mori
discloses that optical energy radiated from the rod [] (in practice, sunlight having
a high energy density converged by a lens (not shown)) is introduced into the
cables in the assembly 20 through the light receiving surface 22 in accordance with
the present invention. (Id. at 3:44-49 (EX1015)).
The conducting rod is referenced in the specification as element 30, not
element 60 as shown in Figure 6. (Id. (EX1015)).
17
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Thus, Mori discloses channels for transmitting light, as acknowledged by
the Examiner, but does not provide details of the light being emitted by the
respective channels, and therefore arguably does not disclose radiating light that is
diffused. For example, Mori does not explicitly describe whether the cables are
tapered outwardly or whether the output light has a spread pattern.
However, as discussed herein, it was known to provide a plurality of
channels that taper outwardly and include a central region that increases in
diameter so as to disperse light in a widening ray and therefore radiate a diffused
pattern of light. Unfortunately, this prior art was not made of record in the 854
patent.
VI.
CLAIM CONSTRUCTION
Claim terms of an unexpired patent in inter partes review are given the
broadest reasonable construction in light of the specification.
37 C.F.R.
42.100(b); In re Cuozzo Speed Techs., LLC 778 F.3d 1271, 127981 (Fed. Cir.
2015). Any claim term that lacks a definition in the specification is therefore given
a broad interpretation.3 In re ICON Health & Fitness, Inc., 496 F.3d 1374, 1379
3
Petitioner applies the broadest reasonable construction standard as required by
the governing regulations. 37 C.F.R. 42.100(b). Petitioner reserves the right to

pursue different constructions in a district court, where a different standard is
applicable.
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(Fed. Cir. 2007). Under the broadest reasonable interpretation standard, claim
terms are given their ordinary and customary meaning, as they would be
understood by one of ordinary skill in the art, in the context of the disclosure. In re
Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007).
Any special
definition for a claim term must be set forth in the specification with reasonable
clarity, deliberateness, and precision. In re Paulsen, 30 F.3d 1475, 1480 (Fed.
Cir. 1994).
The following proposes a construction and offers support for that
construction.
Any claim terms not included should be given their broadest
reasonable interpretation in light of the specification, as commonly understood by

those of ordinary skill in the art. Should the Patent Owner, to avoid the prior art,
contend that a claim term has a construction different from its broadest reasonable
interpretation, the appropriate course is for the Patent Owner to seek to amend the
claim to expressly correspond to its contentions in this proceeding. See 77 Fed.
Reg. 48764 (Aug. 14, 2012).
A.
Diffusing Light
The term diffusing light/diffusing the light, as recited in challenged

claims 3, 19 and 27, should be interpreted to mean spreading out light rays. The
854 patent does not define the term diffusing, but it does show the concave lens
22, i.e., the first diffuser means, as receiving a primary light beam indicated by
19
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arrows 20, and spreading out the light beam to produce light rays indicated by
arrows 32.
(854 patent at 4:13-16 (EX1001)).
Similarly, the second light
diffuser means 34 is described as providing further dispersion to produce the

spread out rays 42 shown in Figure 1. (Id. at 4:50-57 (EX 1001)). Indeed, the 854
patent discloses that the cells 36 of element 34 act to disperse the light. (Id. at
5:13-15 (EX1001) (disperses the light.)). A person of ordinary skill in the art
would have understood that dispersing the light means to spread out light rays.
(Carlin 55 (EX1003)).
Thus, the proposed construction is consistent with the specification of the
854 patent and with the ordinary use of the term diffusing light/diffusing the
light. Its noted that the 854 patent does not require or describe that every single
light ray needs to be spread out. Moreover, its possible that various light rays,
such as certain angled rays 32 shown in Figure 1 of the 854 patent, would reflect
off the inside of the housing 12 and be projected toward the axial direction of the
light device and/or overlap with other light rays. (Id. 56 (EX1003)).
VII. SPECIFIC GROUNDS FOR PETITION
Pursuant to Rule 42.104(b)(4)(5), the following sections (as confirmed in
the Carlin Declaration 58127 (EX1003)) detail the grounds of unpatentability,
the limitations of the challenged claims of the 854 Patent, and how these claims
were therefore obvious in view of the prior art.
20
A.
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Ground I: Claims 3, 4, 7-11, 19 and 27 are rendered obvious by
Nagatani
1.
Overview of Nagatani
Nagatani is not of record in the 854 patent. Nagatani discloses an

assortment of light guide devices, some of which may be used in a liquid crystal
display. (Nagatani at 1:6-11 (EX1002)). Nagatanis disclosure is not limited to
one type of lighting implementation and discusses aspects of general lighting and
image forming optical systems. (Id. at 1:6-19; 1:37-42 (EX1002)).
Figure 1A is a perspective view of a light guide according to an embodiment
disclosed in Nagatani. (Id. at 7:50-51 (EX1002)). Figure 1B is a sectional view of
the light guide of Figure 1A. (Id. at 7:52-53 (EX1002)). Figures 1A and 1B are
reproduced below.
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As shown in Figure 1B, diffused light 16 from a light source enters the light
guide device 10 (light guide) at an incident end surface 12 and leaves at an exit
end surface 14. (Id. at 7:63-67, 8:10-14 (EX1002)). Nagatani discloses that since
the light guide 10 is a cylindrical transparent body, the light entering the guide 10
is condensed within a critical angle of the transparent body to be totally reflected.
(Id. at 8:1-6 (EX1002)). Total internal reflection is a well-known phenomenon that
occurs due to a refractive index discontinuity at a boundary between two optical
materials, which forms the basis for light guiding in optical fibers, optical
waveguides, and light pipes. Light is guided through an inner optical material
having a refractive index ni that is surrounded by an outer optical material having a
refractive index no, where ni >no. This is governed by Snells Law of refraction,
which is: ni sini = nosino. Angles i and o are the angles of incidence and
refraction, respectively, with respect to the normal at the interface between the
inner and outer materials. Light that is totally internally reflected will reflect
multiple times and propagate down the optical fiber or light pipe. (Carlin 60
(EX1003)).
The diameter of the light guide 10 of Nagatani increases from the incident
end surface 12 to the exit end surface 14, as shown for example in Figures 1A and
1B. (Nagatani at Figures 1A and 1B (EX1002)). Nagatani discloses that
[b]ecause the light guide 10 is gradually diverged from the incident end surface
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12 toward the exit end surface 14, this reflection is repeated, whereby the reflected
light gradually changes into light rays vertical to the incident end surface 12 or the
exit end surface 14. (Id. at 8:10-14 (EX1002)). Light rays leaving the guide body
have a 10 of directivity. (Id. at 8:14-16 (EX1002)); (Carlin 61 (EX1003)).
A person of ordinary skill in the art would have understood that the light
rays near the exit end surface 14 would occupy a wider dimension compared to the
dimension occupied by rays at the incident surface 12. (Carlin 62 (EX1003)).
Further, Nagatani discloses that the light guide 10 is not limited to the shapes
shown in Figures 1A and 1B and may use other shapes to maximum efficiency,
including the rectangular and hexagonal configurations shown respectively in
Figures 2A and 2B. (Nagatani at 8:26-39 (EX1002)); (Carlin 62 (EX1003)).
Figures 5A and 5B, reproduced below, are schematic sectional views of a
lighting device that uses light guides of Nagatani. (Nagatani at 6:44-46
(EX1002)). Figure 5A is a sectional front view and Figure 5B is a sectional side
view. (Id. at 9:28-31 (EX1002)).
23
IPR2017-00379
The lighting device includes a light source 20 disposed within a reflection

box 22. (Id. at 9:39-41 (EX1002)). The reflection box 22 has an opening 26 in the
form of a slit. (Id. (EX1002)). The opening 26 has a width equal to a size of the
incident end surface of each light guide device 10 and a length some times the
size. (Id. at 9:41-43 (EX1002)). Further, the lighting device of Figures 5A and
5B has a truncated body. For example, Nagatani discloses that the plurality of
light guide devices 10 are disposed adjacent to each other in a fan-shape .... (Id.
at 9:44-47 (EX1002)).
In use, light emitted from source 20 travels through the opening 26 and
enters the light guides 10. (Id. at 9:51-55 (EX1002)). The light is then radiated
from the light guides 10 with a directivity of 10. (Id. at 9:61-64 (EX1002)).
This light will be radiated at all angles with the extrema defined as directivity,
24
IPR2017-00379
10 in this case. The directivity is determined by the geometry and refractive
index of the trapezoidal-shaped cell 10 and can be larger or smaller depending on
these factors. (Carlin 65 (EX1003)).
An annotated version of Figure 5B is provided below to illustrate exemplary
light rays being radiated from light guides 10. While Figure 5B shows exemplary
light rays with directivity of 10 radiating from central positions of exit end
surface 14 of each light guide 10, one of ordinary skill in the art would have
understood that the light rays will radiate from a multitude of different directions.
(Id. 66 (EX1003)).
Light radiated from

each light guide 10 is
spread out by plus and
minus 10 degrees
Nagatani discloses that [a] plurality of the light guide devices are
interconnected to each other in a line of the light guide devices. Accordingly nonlight emitting parts are absent, and groups of the light guide devices having a
25
IPR2017-00379
uniform luminance on the surface can be formed. (Nagatani at 4:61-65
(EX1002)). As one of ordinary skill in the art will appreciate, light rays emitted
from the interconnected cells 10 in Figure 5B will overlap, so as to provide a more
uniform light pattern. (Carlin 67 (EX1003)).
Figure 6, reproduced below, is a schematic sectional view of a lighting
device according to another embodiment. (Nagatani at 10:8-10 (EX1002)). As
disclosed by Nagatani, in regard to Figure 6, [c]ommon members of the light
source device according to the fourth embodiment with that of Figure 5 have
common reference numerals. (Id. at 10:11-13 (EX1002)). The device of Figure 6
includes a reflection box 28 containing a light source 20 and a plurality of light
guides 10 arranged adjacent to each other in a fan-shape.
(Id. at 10:17-20
(EX1002)). The light guides of Figure 6 form a truncated body. (Carlin 68

(EX1003)).
26
IPR2017-00379
An opening in the form of a slit is formed in a surface of the reflection box

28. (Nagatani at 10:17-18 (EX1002)). A reflecting mirror 30 is extended beyond
the exit end surfaces 14 of the light guides 10. (Id. at 10:20-23 (EX1002)).
In use, light emitted from the source 20 enters the incident end surfaces 12
(shown in Figures 1A and 1B) of the light guides 10. (Id. at 10:26-29 (EX1002)).
The light then exits at the end surfaces 14 (shown in Figures 1A and 1B) as highly
directive rays respectively of about 10. (Id. at 10:29-31 (EX1002)). The exit
rays are disclosed as having high directivity but are very divergent in the direction
of propagation of their principal rays. (Id. at 10:31-33 (EX1002)). The principal
ray is in the case of light guide 10 is the ray that passes directly (i.e., with no
27
IPR2017-00379
reflections from the walls) through the exact centers of the entrance face 12 and
exit face 14. Thus, a bundle of rays are formed within the directivity of about
10, in this case as measured from that principal ray. (Carlin 70 (EX1003)).
Some of the exit light rays that are very divergent in the direction of
propagation of the principal rays are reflected on the reflecting mirror 30 into
substantially parallel rays 31. (Nagatani at 10:34-39 (EX1002)). Nagatani
discloses that this configuration produces substantially parallel rays 31 of high
directivity that can be emitted with high efficiency. (Id. at 10:47-48 (EX1002)).
However, only those rays that are very divergent are reflected by the mirror. (Id.
at 10:34-36 (EX1002)). Based on the teachings of Figure 6, a person of ordinary
skill in the art would have understood that many of the rays will not be reflected by
the mirror and will instead bypass the mirror, as shown below in an annotated
version of Figure 6. (Carlin 71 (EX1003)). The annotated version of Figure 6
below illustrates exemplary light rays being radiated from the light guides 10. (Id.
at 71 (EX1003)). While Figure 6 shows exemplary light rays with directivity of
10 radiating from central positions of exit end surface 14 of each light guide 10,
one of ordinary skill in the art would have understood that the light rays will
radiate from a multitude of different directions. (Id. at 71 (EX1003)). Further,
similar to Figure 5B, light rays emitted from the interconnected cells 10 in Figure 6
will overlap to provide a more uniform light pattern. (Id. at 71 (EX1003)).
28
IPR2017-00379
-10 degrees from

principal light ray
Principal light ray
+10 degrees from
principal light ray
For light rays that are less divergent, Nagatani discloses that assistant
members 32 in the form of prisms, as shown in Figure 7, may be used in place of
the reflecting mirror 30, on the forward ends of the exit end surfaces 14. (Nagatani
at 10:56-62 (EX1002)). While Figure 7 discloses an embodiment that redirects
less divergent light rays, it does not detract from the teachings of Figure 6 with
respect to teaching that many of the light rays will continue past the reflecting
mirror 30 in a widening manner, as shown above in annotated Figure 6. (Carlin
72 (EX1003)).
29
IPR2017-00379
Nagatani discloses a diffuser sheet 92 in regard to a separate embodiment
shown in Figure 26. (Nagatani at 20:51-54, Figure 26 (EX1002)). The
embodiments of Figures 5B and 6 in Nagatani are not disclosed as needing a
diffuser sheet to spread out light. One of ordinary skill in the art will realize that
this is due, at least in part, to the light guides 10 of Figures 5B and 6 being
arranged in a fan-shape to spread out the light. (Id. at 9:44-46, 10:17-20, Figures
5B and 6 (EX1002)); (Carlin 73 (EX1003)).
Reproduced below are Figures 5B and 6 of Nagatani in comparison to
Figure 1 of the 854 patent. As shown, the depicted lighting devices share the
common feature of providing a widened beam of light. One of ordinary skill in the
art would have understood that the light leaving the different devices of Figures 5B
and 6 is diffused in the same manner that the 854 patent discloses to diffuse light.
(Id. 74 (EX1003)).
30
IPR2017-00379
Figure 1 of the 854

Patent
Figure 5B of Nagatani
(arrows added)
Figure 6 of Nagatani
(arrows added)
31
2.
IPR2017-00379
Claim 3 is obvious in view of Nagatani
a)
A light fixture
Nagatani discloses a light fixture. Nagatani discloses a light source device

that emits light from a plurality of exit end surfaces 14. (Nagatani at 10:26-30,
Figures 1B and 6 (EX1002). One of ordinary skill in the art would have
understood that Nagatanis light source device is fixed at a location, and is
therefore a light fixture.4 (Carlin 75 (EX1003)).
b)
a housing having an interior region extending to an

opening for the housing
Nagatani discloses a housing having an interior region extending to an

opening for the housing. Nagatani discloses a reflection box 28 and reflecting
mirror 30 that form an interior region. (Nagatani at 10:17-20, Figure 6 (EX1002)).
As shown by Figure 6, the interior region extends to an opening surrounded by
reflecting mirror 30 where light output from exit end surfaces 14 is transmitted.
(Id. at Figure 6 (EX1002)). Figure 6 also shows that the interior region houses a
plurality of light guides 10 arranged adjacent to each other in a fan-shape. (Id. at
10:17-23, Figure 6 (EX1002)). Therefore, the reflection box 28 and reflecting
While Nagatani discloses a light fixture, this preamble limitation is not
referenced by the body of claim 3 and should not be read as imparting any
additional limitations beyond what the claim body recites.
32
IPR2017-00379
mirror 30 form a housing for the plurality of light guides 10 that has an interior
region extending to an opening of the housing. (Carlin 76 (EX1003)).
c)
means for illuminating the housing operatively

associated with the interior region of the housing
Nagatani discloses a means for illuminating the housing operatively

associated with the interior region of the housing. Nagatani discloses that
reflection box 28 contains a substantial point light source 20. (Nagatani at 10:1819, Figure 6 (EX1002)). Light emitted from light source 20 is directed through a
slit to enter incident end surfaces 12 of the plural light guide devices 10. (Id. at
10:26-29, Figure 6 (EX1002)). Incident end surfaces 12 are located in an interior
region surrounded by reflector box 28 and reflecting mirror 30. (Id. at Figure 6
(EX1002)). One of ordinary skill in the art would have understood that light
source 20 operatively associates with incident end surfaces 12 because light from
light source 20 enters incident end surfaces 12. (Carlin 77 (EX1003)).
d)
means for diffusing light emitted from the

illuminating means, the diffusing means comprising
Nagatani teaches a means for diffusing light emitted from the illuminating
means. Nagatani discloses light emitted from light source 20 is directed through a
slit to enter incident end surfaces 12 of the plural light guide devices 10. (Nagatani
at 10:26-29, Figure 6 (EX1002)). Light exits the plural light guide devices 10 at
exit end surface 14 as highly directive rays respectively of about 10. (Id. at
33
IPR2017-00379
10:29-31 (EX1002)). The exit rays are disclosed as having high directivity but
are very divergent in the direction of propagation of their principal rays. (Id. at
10:31-33 (EX1002)); (Carlin 78 (EX1003)).
Some of the exit light rays that are very divergent in the direction of
propagation of the principal rays are reflected on the reflecting mirror 30 into
substantially parallel rays 31. (Nagatani at 10:34-39 (EX1002)). Only those
rays that are very divergent are reflected by the mirror. (Id. at 10:34-36
(EX1002)). Based on the teachings of Figure 6, a person of ordinary skill in the art
would have understood that many of the rays will not be reflected by the mirror
and will instead bypass the mirror, as shown below in an annotated version of
Figure 6. (Carlin 79 (EX1003)).
34
IPR2017-00379
-10 degrees from

principal light ray
Principal light ray
+10 degrees from
principal light ray
Therefore, rays that bypass the mirror are spread out diffused light rays
produced by the plurality of light guide devices. In addition, the divergent rays
emanating from each cell 10 that reflect from the mirror 30 will also contribute to
the spread out diffused light. (Nagatani at 9:61-65 (EX1002)). Thus, one of
ordinary skill in the art would have understood that Nagatani teaches a means for
diffusing light and therefore teaches the claimed means for diffusing light emitted
from the illuminating means. (Carlin 80 (EX1003)).
35
e)
IPR2017-00379
a body portion having: a first end for receiving light
from the illuminating means,
Nagatani discloses a body portion having a first end for receiving light from
the illuminating means. Nagatani discloses that a plurality of light guides 10 are
arranged adjacent to each other in a fan-shape. (Nagatani at 10:19-20, Figure 6
(EX1002)). One of ordinary skill in the art would have understood that the
plurality of light guides 10 arranged adjacent to each other in a fan-shape form a
light guide body portion. (Carlin 81 (EX1003)).
Light emitted from light source 20 is directed through a slit to enter incident
end surfaces 12 of the plural light guides 10 that are arranged adjacent to each
other. (Nagatani at 10:26-29, Figure 6 (EX1002)). Therefore, the incident end
surfaces 12 form a first end of the plurality of light guides 10 arranged adjacent to
each other, and receive light from light source 20. (Carlin 82 (EX1003)).
f)
[a body portion having:] a second end opposite to the

first end and facing the opening of the housing for
radiating light to the opening
Nagatani discloses a body portion having a second end opposite to the first
end and facing the opening of the housing for radiating light to the opening. As
discussed above, Nagatani discloses light emitted from light source 20 is directed
through a slit to enter incident end surfaces 12 of the plural light guides 10 that are
arranged adjacent to each other. (Nagatani at 10:26-29, Figure 6 (EX1002)).
36
IPR2017-00379
Nagatani discloses that light exits the plural light guides 10 at exit end surfaces 14
of each light guide 10. (Id. at 10:29-30, Figure 6 (EX1002)). Therefore, each of
the exit end surfaces 14 form a second end of the plurality of light guides 10
arranged adjacent to each other. The second end is opposite to the first end formed
by incident end surfaces 12. (Carlin 83 (EX1003)).
Exit end surfaces 14 output light from light guides 10. (Nagatani at 10:2930, Figure 6 (EX1002)). The exit surfaces 14 face the opening of the housing
formed by reflection box 28 and reflector 30. (Id. at Figures 1B and 6 (EX1002)).
Therefore, the second end formed by exit surfaces 14 radiate light to the opening of
the housing formed by reflection box 28 and reflector 30. (Carlin 84 (EX1003)).
g)
[a body portion having:] a plurality of channels

tapering outward toward the second end, and extending
between the first end and the second end for diffusing
light transmitted therethrough from the first end to the
second end
Nagatani discloses a body portion having a plurality of channels tapering

outward toward the second end, and extending between the first end and the
second end for diffusing light transmitted therethrough from the first end to the
second end. As discussed above, Nagatani discloses that a plurality of light guides
10 are arranged adjacent to each other in a fan-shape and form a body portion.
(Nagatani at 10:19-20, Figure 6 (EX1002)); (Carlin 85 (EX1003)).
37
IPR2017-00379
Nagatani discloses that the plurality of light guides 10 each form a channel
within the fan-shaped form that allows the transmission of light. (Nagatani at
10:19-20, Figures 1B, 6 (EX1002)). Each channel begins at incident end surface
12 and terminates at exit end surface 14. (Id. at 10:28-30, Figures 1B, 6
(EX1002)). Incident end surfaces 12 and exit end surfaces 14 may have different
areas. (Id. at 7:56-60, Figures 1B, 6 (EX1002)). For example, Nagatani discloses
that an incident end surface may have a smaller area relative to an exit end
surfaces. (Id. at 7:56-60, Figures 1B, 6 (EX1002)). The diameter of each light
guide 10 increases from the incident end surface 12 to the exit end surface 14, as
shown for example in Figures 1A, 1B, and 6. (Id. at 7:55-60 (EX1002)).
Accordingly, one of ordinary skill in the art would have understood that the
plurality of channels provided by the plurality of light guides 10 each taper
outward from the first end formed by incident end surfaces 12 toward the second
end formed by exit end surfaces 14. (Carlin 86 (EX1003)).
As discussed above, a person of ordinary skill in the art would have
understood that many of the rays that travel through each light guide 10 will not be
reflected by the mirror and will instead bypass the mirror, as shown below in an
annotated version of Figure 6. (Carlin 87 (EX1003)). The rays that bypass the
mirror are spread out diffused light rays produced by the channels of the plurality
of light guides 10. In addition, the divergent rays emanating from each cell 10 that
38
IPR2017-00379
reflect from the mirror 30 will also contribute to the spread out diffused light. (Id.
at 87 (EX1003)).
h)
wherein the light radiated from the second end is in

the diffused pattern to exit the opening of the housing.
Nagatani teaches wherein the light radiated from the second end is in the
diffused pattern to exit the opening of the housing. As discussed above, Nagatani
discloses that light exits the plural light guide 10 at exit end surface 14 as highly
directive rays respectively of about 10. (Nagatani at 10:29-33 (EX1002)).
Only those rays that are very divergent are reflected by the mirror. (Id. at 10:3436 (EX1002)). Based on the teachings of Figure 6, a person of ordinary skill in the
art would have understood that many of the rays will not be reflected by the mirror
39
IPR2017-00379
-10 degrees from

principal light ray
Principal light ray
+10 degrees from
principal light ray
Therefore, rays that bypass the mirror are spread out light rays produced by
the plurality of light guides 10 that are radiated from exit end surfaces 14, and are
therefore a diffused pattern of light, as disclosed in the 854 patent. Thus, such a
diffused pattern of light exits the opening of the housing formed by reflection box
28 and reflector 30. In addition, the divergent rays emanating from each cell 10
that reflect from the mirror 30 will also contribute to the spread out diffused light.
(Id. 89 (EX1003)).
40
IPR2017-00379
3.
a)
The light fixture according to claim 3, further

comprising: a reflector disposed at the interior region of
the housing and in operative association with the
illuminating means for reflecting light at the interior
region toward the diffusing means.
Nagatani discloses the light fixture according to claim 3, further comprising:

a reflector disposed at the interior region of the housing and in operative
association with the illuminating means for reflecting light at the interior region
toward the diffusing means. Nagatani discloses that reflection box 28 contains a
substantial point light source 20. (Nagatani at 10:18-19, Figure 6 (EX1002)).
Light source 20 is therefore located in an interior region of the housing formed by
reflection box 28 and reflector 30.
Similar to reflection box 28, Nagatani discloses another light source device
embodiment in Figure 5 that includes a reflection box 22. (Id. at 9:39-40, Figure 5
(EX1002)). Reflection box 22 contains the substantial point light source 20. (Id.
at 9:41, Figure 5 (EX1002)). Similar to the embodiment of Figure 6, light emitted
from substantial point light source 20 exits through a slit and enters incident end
surfaces 12 of a plurality of light guides 10. (Id. at 9:51-55, Figure 5 (EX1002)).
Reflection box 22 has a silver reflection surface on its inside surface. (Id. at 9:5253, Figure 5 (EX1002)). Light from light source 20 repeats reflection on the silver
41
IPR2017-00379
reflection surface and exits through the slit. (Id. at 9:51-55, Figure 5 (EX1002));
(Carlin 91 (EX1003)).
A person of ordinary skill in the art would have understood that the silver
reflection surface of reflection box 22 can be implemented in reflection box 28 of
Figure 6. (Id. 92 (EX1003)). One of ordinary skill in the art would have been
motivated to implement the silver reflection surface in reflection box 28 because it
would redirect stray light generated by light source 20 toward the plurality of light
guides 10, and increase the amount of light output by light guides 10 relative to
when reflection box 28 does not include a reflection surface within it. (Id. 92
(EX1003)).
Therefore, Nagatani teaches that the silver reflection surface is a reflector
disposed at the interior region of the housing as claimed. Nagatani also teaches
that the silver reflection surface is in operative association with light source 20 for
reflecting light at the interior region toward the diffusing means. This teaching is
provided by Nagatani because the silver reflection surface repeats reflection of
light from light source 20 toward a slit for output into the plurality of light guides
10. Nagatani therefore discloses the elements of claim 4. (Id. 93 (EX1003)).
4.
42
a)
IPR2017-00379
The light fixture according to claim 3, wherein each
one of the plurality of channels extends along a
respective one of the hollow cells which are nested
together along their respective sidewalls.
Nagatani discloses that a plurality of light guides 10 are arranged adjacent to

each other in a fan-shape and form a body portion. (Nagatani at 10:19-20, Figure 6
(EX1002)). As discussed above, the plurality of light guides 10 each form a
channel within the fan-shaped form that allows the transmission of light. (Id. at
10:19-20, Figures 1B, 6 (EX1002)). Each channel begins at incident end surface
12 and terminates at exit end surface 14. (Id. at 10:28-30, Figures 1B, 6
(EX1002)). As shown in Figure 6, in the fan-shaped structure each channel
formed by a light guide 10 extends along another channel formed by another light
guide 10. (Id. at 10:19-20, Figure 6 (EX1002)). Also shown in Figure 6, within
the fan-shaped structure, each light guide 10 has a sidewall that is nested together
along a sidewall of another light guide 10. (Id.).
Claim 7 lacks antecedent basis for the recitation of the hollow cells. It is
not clear what specifically the claim is referring to with respect to the hollow
cells. To the extent the claim is interpreted to require that the channels are
hollow, this feature is taught or suggested by Nagatani. For example, Nagatani
discloses that variations of the light guide device 10 can be proposed, and an
optimum shape may be selected so that maximum incidence efficiency can be
provided in optical coupling when the light guide device is combined with other
43
IPR2017-00379
optical systems to constitute a light source device. (Id. at 8:35-39 (emphasis
added) (EX1002)). One of ordinary skill in the art would appreciate that a
variation of the light guide 10 would be to provide hollow guides. (Carlin 95
(EX1003)). As an example, a hollow light guide can be devised having either its
exterior or interior surface coated to reflect light. (Id. at 95 (EX1003)). Such
configurations would also guide light from the entrance of a cell to the exit of that
cell. (Id. at 95 (EX1003)). Thus, Nagatani teaches or suggests the elements of
claim 7. (Id. at 95 (EX1003)).
5.
Claim 8 is obvious in view of Nagatani.
a)
The light fixture according to claim 7, wherein each

one of the plurality of cells has a hexagonal-shaped
cross-section.
Nagatani discloses the light fixture according to claim 7, wherein each one
of the plurality of cells has a hexagonal-shaped cross-section. As discussed above,
a plurality of light guides 10 are arranged adjacent to each other in a fan-shape to
form a body portion. (Nagatani at 10:19-20, Figure 6 (EX1002)). Nagatani
discloses that a light guide 10 may have a hexagonal pole. (Id. at 8:31-33, Figure
2B (EX1002)). As shown in Figure 2B, the hexagonal pole causes the channel
provided by light guide 10 to be hexagonally shaped near exit end surface 14. (Id.
at Figure 2B (EX1002)). This is shown in the annotated Figure 2B below.
44
IPR2017-00379
Therefore, a cross-section of the plurality of light guides 10 taken at the

location identified in annotated Figure 2B would result in a hexagonal-shaped
cross section of the plurality of light guides. Nagatani therefore discloses the
elements of claim 8. (Carlin 97 (EX1003)).
45
IPR2017-00379
6.
a)
9. The light fixture according to claim 3, wherein a

diameter of the first end of the body portion facing the
illuminating means is less than a diameter of the second
end of the body portion facing the opening of the
housing.
Nagatani discloses the light fixture according to claim 3, wherein a diameter

of the first end of the body portion facing the illuminating means is less than a
diameter of the second end of the body portion facing the opening of the housing.
As discussed above, a plurality of light guides 10 are arranged adjacent to each
other in a fan-shape to form a body portion. (Nagatani at 10:19-20, Figure 6
(EX1002)). The plurality of light guides 10 each form a channel within the fanshaped form that allows the transmission of light. (Id. at 10:19-20, Figures 1B, 6
(EX1002)). Each channel begins at incident end surface 12 and terminates at exit
end surface 14. (Id. at 10:28-30, Figures 1B, 6 (EX1002)). A first end formed by
incident end surfaces 12 face light source 20, and light emitted from light source
20 is directed through a slit to enter incident end surfaces 12. (Id. at 10:26-29,
Figure 6 (EX1002)). A second end formed by exit surfaces 14 faces the opening of
the housing formed by reflection box 28 and reflector 30, and radiate light toward
the opening. (Id. at Figures 1B and 6 (EX1002)); (Carlin 98 (EX1003)).
46
IPR2017-00379
Nagatani discloses that the incident end surface of the light guide 10 can
have a diameter of 1 millimeter, for example, while the exit end surface of a light
guide 10 can have a larger diameter such as 6.2 millimeters. (Nagatani at 7:56-60,
Figures 1B, 6 (EX1002)). Moreover, as shown by Figure 6, the first end formed by
incident end surfaces 12 of the fan-shaped body of light guides provides a smaller
opening compared to the second end formed by exit end surfaces 14. (Id. at Figure
6 (EX1002)). Thus, the first end has a smaller diameter compared the second end.
Nagatani therefore discloses the elements of claim 9. (Carlin 99 (EX1003)).
7.
a)
The light fixture according to claim 3, wherein the

diffusing means has a hexagonal-shaped cross-section.
Nagatani discloses the light fixture according to claim 3, wherein the

diffusing means has a hexagonal-shaped cross-section. As discussed above, a
plurality of light guides 10 that are arranged adjacent to each other in a fan-shape
form a body portion, and are diffusing means. (Nagatani at 10:19-20, Figure 6
(EX1002)). A light guide 10 may have a hexagonal pole. (Id. at 8:31-33, Figure
2B (EX1002)). As shown in Figure 2B, the hexagonal pole causes the channel
provided by light guide 10 to be hexagonally shaped near exit end surface 14. (Id.
at Figure 2B (EX1002)). This is shown in the annotated Figure 2B below.
47
IPR2017-00379
Therefore, a cross-section of the light guides 10 forming the diffusing means

that is taken at the location of each light guide identified in annotated Figure 2B
would result in a hexagonal-shaped cross section of the diffusing means. Nagatani
therefore discloses the elements of claim 10. (Carlin 101 (EX1003)).
48
8.
IPR2017-00379
a)
The light fixture according to claim 7, wherein a

diameter of each one of the cells increases from the
respective first end through to the respective second end
of the cell.
Nagatani discloses the light fixture according to claim 7, wherein a diameter

of each one of the cells increases from the respective first end through to the
respective second end of the cell. As discussed above, a plurality of light guides
10 are arranged adjacent to each other in a fan-shape to form a body portion.
(Nagatani at 10:19-20, Figure 6 (EX1002)). The plurality of light guides 10 each
form a channel within the fan-shaped form that allows the transmission of light.
(Id. at 10:19-20, Figures 1B, 6 (EX1002)). Each channel begins at incident end
surface 12 and terminates at exit end surface 14. (Id. at 10:28-30, Figures 1B, 6
(EX1002)). A first end formed by incident end surfaces 12 face light source 20,
and light emitted from light source 20 is directed through a slit to enter incident
end surfaces 12. (Id. at 10:26-29, Figure 6 (EX1002)). A second end formed by
exit surface 14 faces the opening of the housing formed by reflection box 28 and
reflector 30, and radiates light toward the opening. (Id. at Figures 1B and 6
(EX1002)); (Carlin 102 (EX1003)).
Nagatani discloses that the incident end surface of a light guide 10 can have
a diameter of 1 millimeter, for example, while the exit end surface of a light guide
49
IPR2017-00379
10 can have a larger diameter such as 6.2 millimeters. (Nagatani at 7:56-60,
Figures 1B, 6 (EX1002)). The diameter of each light guide 10 increases from the
incident end surface 12 to the exit end surface 14, as shown for example in Figures
1A, 1B, and 6. (Id. at Figures 1A, 1B, and 6 (EX1002)). Therefore, the Nagatani
discloses the elements of claim 11. (Carlin 103 (EX1003)).
9.
a)
A device for diffusing light from a luminous body, [the

device comprising]
Nagatani teaches a device for diffusing light from a luminous body.

Nagatani discloses a light source device in Figure 5B. (Nagatani at 9:29-31, Figure
5B (EX1002)). Nagatani discloses a light source 20 that is a luminous body. (Id. at
9:51, Figure 5B (EX1002)). Light emitted from a light source 20 is directed
through a slit to enter incident end surfaces 12 of the plural light guide devices 10.
(Id. at 9:51-61, Figure 5B (EX1002)). Light exits the plural light guides 10 at the
plural exit end surfaces 14 as directive light rays respectively of high directivity
of about 10. (Id. at 9:61-64 (EX1002)). As shown by annotated Figure 5B
below, all of the light radiated from the plural exit end surfaces 14 is spread out
because it is radiated at different angles with directivity of plus 10 degrees and
minus 10 degrees. (Carlin 104 (EX1003)).
50
IPR2017-00379
Light radiated from

minus 10 degrees
Therefore, light from light source 20 is diffused by the light source device of
Figure 5B. Nagatani therefore teaches a device for diffusing light from a luminous
body. (Carlin 105 (EX1003)).
b)
[a truncated body having:] a first truncated region at a

first side of the truncated body for receiving light from
the luminous body
Nagatani discloses a truncated body having a first truncated region at a first

side of the truncated body for receiving light from the luminous body. Nagatani
discloses that a plurality of light guides 10 are disposed adjacent to each other in a
fan-shape. (Nagatani at 9:44-46, Figure 5B (EX1002)). The plurality of light
guides 10 each form a channel within the fan-shape that allows the transmission of
light through each channel. (Id. at 9:61-64, Figures 1B, 5B (EX1002)). For
51
IPR2017-00379
example, each channel begins at incident end surface 12 and terminates at exit end
surface 14. (Id. at 9:59-64, Figures 1B, 5B (EX1002)). Thus, the plurality of light
guides 10 form a truncated body that begins at incident end surfaces 12 and
terminates at the exit end surfaces 14. The incident end surfaces 12 are a first
truncated region at a first side of the truncated body formed by the plurality of light
guides 10. (Id. at 9:59-64, Figures 1B, 5B (EX1002)); (Carlin 106 (EX1003)).
Light source 20 radiates light through a slit to enter incident end surfaces 12
of the plural light guide devices 10. (Nagatani at 9:54-61, Figures 1B, 5B
(EX1002)).
Therefore, Nagatani discloses that a first truncated region at a first
side of the truncated body for receiving light from the luminous body. (Carlin
107 (EX1003)).
c)
[a truncated body having:] a second truncated region

at a second side of the truncated body substantially
opposite to the first side and adapted for emitting light,
and
As discussed above, each channel of light guide 10 in the fan-shaped

structure begins at incident end surface 12 and terminates at exit end surface 14.
(Nagatani at 9:59-64, Figures 1B, 5B (EX1002)). The incident end surfaces 12 are
a first truncated region at a first side of the truncated body formed by the plurality
of light guides 10. (Id. at 9:59-64, Figures 1B, 5B (EX1002)). The exit end
surfaces 14 are a second truncated region at a second side of the truncated body
52
IPR2017-00379
formed by the plurality of light guides 10. (Id. at 9:59-64, Figures 1B, 5B
(EX1002)). As shown by Figure 5B, exit end surfaces 14 are situated substantially
opposite to incident end surfaces 12. (Id. at 9:59-64, Figures 1B, 5B (EX1002)).
Light is emitted from the plural light guide devices 10 at the plural exit end
surfaces 14. (Id. at 9:61-64 (EX1002)); (Carlin 108 (EX1003)).
d)
[a
truncated
body
having:]
central
region
interconnecting the first and second truncated regions,

As discussed above, each channel of light guide 10 in the fan-shaped
structure begins at incident end surface 12 and terminates at exit end surface 14.
(Nagatani at 9:59-64, Figures 1B, 5B (EX1002)). The incident end surfaces 12 are
a first truncated region at a first side of the truncated body formed by the plurality
of light guides 10. (Id. at 9:59-64, Figures 1B, 5B (EX1002)). The exit end
surfaces 14 are a second truncated region at a second side of the truncated body
formed by the plurality of light guides 10. (Id. at 9:59-64, Figures 1B, 5B
(EX1002)). As shown by Figure 5B, each incident end surface 12 is
interconnected to a respective exit end surface 14 by a central region of the channel
in each light guide 10. (Id. at 9:59-64, Figures 1B, 5B (EX1002)); (Carlin 109
(EX1003)).
53
e)
IPR2017-00379
the central region increasing in diameter from the first
truncated region to the second truncated region and
adapted for diffusing the light transmitted along the
central region for providing a diffused pattern of light
emitted from the second truncated region
Nagatani discloses the central region increasing in diameter from the first
truncated region to the second truncated region and adapted for diffusing the light
transmitted along the central region for providing a diffused pattern of light
emitted from the second truncated region. As discussed above, a plurality of light
guides 10 are arranged adjacent to each other in a fan-shape to form a body
portion. (Nagatani at 10:19-20, Figure 6 (EX1002)). The plurality of light guides
10 each form a channel within the fan-shaped form that allows the transmission of
light. (Id. at 10:19-20, Figures 1B, 6 (EX1002)). Each channel begins at incident
end surface 12 and terminates at exit end surface 14. (Id. at 10:28-30, Figures 1B,
6 (EX1002)). Nagatani discloses that the incident end surface of the light guide 10
can have a diameter of 1 millimeter, for example, while the exit end surface of the
light guide 10 can have a larger diameter such as 6.2 millimeters. (Id. at 7:56-60,
Figures 1B, 6 (EX1002)). The diameter of each light guide 10 increases from the
1A, 1B, and 6. (Id. at Figures 1A, 1B, and 6 (EX1002)); (Carlin 110 (EX1003)).
54
IPR2017-00379
Light guides 10, including the central regions connecting incident end
surfaces 12 to the exit end surfaces 14, are adapted for diffusing the light
transmitted along the central region. Nagatani discloses that light emitted from
light source 20 is directed through a slit to enter incident end surfaces 12 of the
plural light guide devices 10. (Nagatani at 9:51-61, Figure 5B (EX1002)). Light
exits the plural light guide devices 10 at the plural exit end surfaces 14 as
directive light rays respectively of high directivity of about 10. (Id. at 9:6164 (EX1002)). As shown by annotated Figure 5B below, the light radiated from
the plural exit end surfaces 14 is spread out because it is radiated at different angles
with directivity of plus 10 degrees and minus 10 degrees. (Carlin 111
(EX1003)).
Light radiated from

spread out by plus
and minus 10 degrees
55
IPR2017-00379
Therefore, since the light output from each light guide channel 10, as well as
the combined outputs of the plural exit end surfaces 14, is spread out, the channels
of light guides 10 diffuse the light that is input into each channel via incident end
surfaces 12. The light radiated from the exit end surface 14 of each channel of
each light guide 10 is a diffused pattern of light because the output light is spread
out and widened in a manner similar to the 854 patents disclosure. (Carlin 112
(EX1003)).
10.
a)
A method of diffusing light, [comprising the steps of]:
Nagatani teaches a method of diffusing light. Nagatani discloses light

emitted from light source 20 is directed through a slit to enter incident end surfaces
12 of the plural light guide devices 10. (Nagatani at 9:51-61, Figure 5B
(EX1002)). Light exits the plural light guide devices 10 at the plural exit end
surfaces 14 as directive light rays respectively of high directivity of about 10.
(Id. at 9:61-64 (EX1002)). As shown by annotated Figure 5B below, the light
radiated from the plural exit end surfaces 14 is spread out because it is radiated at
different angles with directivity of about plus 10 degrees and minus 10 degrees.
Nagatani therefore teaches a method of diffusing light. (Carlin 113 (EX1003)).
56
IPR2017-00379
Light radiated from

spread out by plus
and minus 10 degrees
Nagatani also teaches a method of diffusing light in reference to Figure 6.

Nagatani discloses light emitted from light source 20 is directed through a slit to
enter incident end surfaces 12 of the plural light guide devices 10. (Nagatani at
10:26-29, Figure 6 (EX1002)). Light exits the plural light guide devices 10 at exit
end surface 14 as highly directive rays respectively of about 10. (Id. at 10:2931 (EX1002)). The exit rays are disclosed as having high directivity but are very
divergent in the direction of propagation of their principal rays. (Id. at 10:31-33
(EX1002)); (Carlin 114 (EX1003)).
Based on the teachings of Figure 6, a person of ordinary skill in the art
would have understood that many of the rays will not be reflected by the mirror
57
IPR2017-00379
-10 degrees from

principal light ray
Principal light ray
+10 degrees from
principal light ray
Therefore, rays that bypass the mirror are spread out diffused light rays
produced by the plurality of light guide devices. In addition, the divergent rays
the spread out diffused light. Nagatani therefore also teaches a method of diffusing
light in reference to Figure 6. (Carlin 116 (EX1003)).
b)
providing a light source from which light radiates;
Nagatani discloses providing a light source from which light radiates.

Nagatani discloses that light source 20 is provided in a light source device.
58
IPR2017-00379
(Nagatani at 9:39-41; 10:18-19, Figures 5B and 6 (EX1002)). Light source 20
radiates light through a slit to enter incident end surfaces 12 of the plural light
guide devices 10. (Id. at 9:51-61; 10:18-19, Figures 5B and 6 (EX1002)); (Carlin
117 (EX1003)).
c)
interrupting the light with a substantially transparent

member;
Nagatani discloses interrupting the light with a substantially transparent

member. Nagatani discloses that a plurality of light guides 10 are disposed
adjacent to each other in a fan-shape. (Nagatani at 9:44-46; 10:17-23, Figures 5B,
6 (EX1002)). The plurality of light guides 10 each form a channel within the fanshape that allows the transmission of light through each channel. (Id. at 9:61-64;
10:19-20, Figures 1B, 5B, 6 (EX1002)). For example, each channel begins at
incident end surface 12 and terminates at exit end surface 14. (Id. at 9:59-64;
10:28-30, Figures 1B, 5B, 6 (EX1002)). Light source 20 radiates light through a
slit to enter incident end surfaces 12 of the plural light guide devices 10. (Id. at
9:54-61; 10:26-29, Figures 1B, 5B, 6 (EX1002)). Nagatani also discloses that each
light guide 10 is a transparent body. (Id. at 7:55 (EX1002)). Therefore, Nagatani
discloses that the light radiated from light source 20 is interrupted with a
substantially transparent member. (Carlin 118 (EX1003)).
59
d)
IPR2017-00379
segregating a substantial portion of the light to a
plurality of channels within the member;
Nagatani discloses segregating a substantial portion of the light to a plurality

of channels within the member. The plurality of light guides 10 each form a
channel within the fan-shape that allows the transmission of light through each
channel. (Nagatani at 9:61-64; col 10, lines 19-20, Figures 1B, 5B, 6 (EX1002)).
For example, each channel begins at incident end surface 12 and terminates at exit
end surface 14. (Id. at 9:59-64; 10:28-30, Figures 1B, 5B, 6 (EX1002)). As
discussed, light source 20 radiates light through a slit to enter incident end surfaces
12 of the plural light guide devices 10. (Id. at 9:54-61; 10:26-29, Figures 1B, 5B, 6
(EX1002)). Therefore, the light radiated from light source 20 is segregated to a
plurality of channels formed by the plurality of light guides 10 in the fan-shape.
(Carlin 119 (EX1003)).
e)
dispersing the light transmitted in a widening ray

along the plurality of channels;
Nagatani discloses dispersing the light transmitted in a widening ray along

the plurality of channels. As discussed above, the plurality of light guides 10 each
form a channel within the fan-shape that allows the transmission of light through
each channel. (Nagatani at 9:61-64; 10:19-20, Figures 1B, 5B, 6 (EX1002)). Each
channel begins at incident end surface 12 and terminates at exit end surface 14.
(Id. at 9:59-64; 10:28-30, Figures 1B, 5B, 6 (EX1002)); (Carlin 120 (EX1003)).
60
IPR2017-00379
Nagatani discloses that the incident end surface of a light guide 10 can have
a diameter of 1 millimeter, for example, while the exit end surface of a light guide
10 can have a larger diameter such as 6.2 millimeters. (Nagatani at 7:56-60,
Figures 1B, 5B (EX1002)). The diameter of each light guide 10 increases from the
1A, 1B, 5B and 6. (Id. at Figures 1A, 1B, 5B, 6 (EX1002)). Moreover, Nagatani
discloses that light reflection is repeated within light guide body 10. (Id. at 8:1012, Figures 1B, 6 (EX1002)). Therefore, one of ordinary skill in the art would
have understood that the repeated reflections of light traveling through the channel
of a light guide 10 as the diameter increases form incident end surface 12 to exit
end surface 14 results in a light ray that widens along its respective channel.
(Carlin 121 (EX1003)).
Additionally, light exits the plural light guide devices 10 at the plural exit
end surfaces 14 as directive light rays respectively of high directivity of about
10. (Nagatani at 9:61-64 (EX1002)). As shown by annotated Figure 5B below,
the light radiated from the plural exit end surfaces 14 is spread out and widened
because light is radiated at different angles with directivity of about plus 10
degrees and minus 10 degrees. (Carlin 122 (EX1003)).
61
IPR2017-00379
Light radiated from

minus 10 degrees
Therefore, one of ordinary skill in the art would have understood that the
spread out and widened light rays that exit each light guide 10 are provided by
light rays that enter each light guide 10 and widen through light guide 10 as the
channel diameter increases from incident end surface 12 to exit end surface 14.
(Carlin 123 (EX1003)). Moreover, the cumulative light leaving the light guides
10 is widened in comparison to light within the end surfaces 12. (Id. at 123
(EX1003)).
Nagatani also discloses dispersing the light transmitted in a widening ray
along the plurality of channels in reference to Figure 6. Nagatani discloses light
emitted from light source 20 is directed through a slit to enter incident end surfaces
12 of the plural light guide devices 10. (Nagatani at 10:26-29, Figure 6 (EX1002)).
62
IPR2017-00379
Light exits the plural light guide devices 10 at exit end surface 14 as highly
directive rays respectively of about 10. (Id. at 10:29-31 (EX1002)). Based on
the teachings of Figure 6, a person of ordinary skill in the art would have
understood that many of the rays will not be reflected by the mirror and will
instead bypass the mirror, as shown below in an annotated version of Figure 6.
(Carlin 124 (EX1003)).
-10 degrees from

principal light ray
Principal light ray
+10 degrees from
principal light ray
Rays that bypass the mirror are spread out diffused light rays produced by
the plurality of light guides 10. Light rays are dispersed into light guides 10 and
widen along the channel of each light guide. Therefore, Nagatani discloses
dispersing light transmitted in a widening ray along the plurality of channels. The
63
IPR2017-00379
rays that bypass the mirror are spread out diffused light rays produced by the
channels of the plurality of light guides 10. In addition, the divergent rays
the spread out diffused light. (Carlin 125 (EX1003)).
f)
radiating a diffused pattern of light emitted from the

plurality of channels.
Nagatani teaches radiating a diffused pattern of light emitted from the

plurality of channels. As discussed above, light exits the plural light guide devices
10 at the plural exit end surfaces 14 as directive light rays respectively of high
directivity of about 10. (Nagatani at 9:61-64; 10:29-31 (EX1002)). As shown
by annotated Figure 5B below, light radiated from the plural exit end surfaces 14 is
spread out by being radiated at different angles with directivity of plus 10 degrees
and minus 10 degrees. Annotated Figure 6, also shown below, similarly shows
that the rays emitted from exit end surfaces 14 that bypass reflecting mirror 30 are
spread out diffused light rays produced by the plurality of light guides 10. (Carlin
126 (EX1003)).
Therefore, one of ordinary skill in the art would have understood that the
light radiated from the exit end surface 14 of each channel of each light guide 10 is
a diffused pattern. (Carlin 127 (EX1003)).
64
IPR2017-00379
Light radiated from

minus 10 degrees
-10 degrees from

principal light ray
Principal light ray
+10 degrees from
principal light ray
65
IPR2017-00379
VIII. CONCLUSION
Based on the foregoing, the challenged claims of the 854 Patent recite
subject matter that is unpatentable. The Petitioner requests institution of an inter
partes review to cancel these claims.
Respectfully Submitted,
/David L. Cavanaugh/
David L. Cavanaugh
Registration No. 36,476
Jonathan Stroud
Daniel V. Williams
66
IPR2017-00379
Table of Exhibits for U.S. Patent 6,079,854 Petition for Inter Partes Review
Exhibit
1001
1002
1003
1004
1005
1006
1007
1008
1009
1010
1011
1012
1013
1014
1015
1016
Description
US Patent 6,079,854
US Patent 5,764,845 (Nagatani) (filed on June 24, 1994;
issued on June 9, 1998)
Declaration of Donald B. Carlin
JP Application No. JPH01-079204, published on May 29,
1989
JP Application No. JPH04-133832, published on May 7, 1992
5,839,823 (Hou) (filed on March 26, 1996; published on
Nov. 24, 1998)
File History, Application (2/13/1998)
File History, Office Action (5/27/1999)
US Pat. No. 5,122,940 (Wiegand)
US Pat. No. 4,112,483 (Small)
US Pat. No. 5,810,469 (Weinreich)
US Pat. No. 5,113,321 (Suzuki)
File History, Amendment (10/26/1999)
File History, Notice of Allowability (1/27/2000)
US Pat. No. 4,743,082 (Mori)
Petitioners Voluntary Interrogatory Responses
IPR2017-00379
WORD COUNT CERTIFICATE OF COMPLIANCE
I hereby certify that the foregoing, Petition for Inter Partes Review, contains
11475 words as measured by the word processing software used to prepare the
document, in compliance with 37 C.F.R. 42.24 (d).
Respectfully submitted,
Dated: December 7, 2016
/Daniel V. Williams/
Daniel V. Williams
Reg. No. 45,221
Wilmer Cutler Pickering Hale and Dorr LLP

1875 Pennsylvania Ave., NW
Washington, DC 20006
Tel: (202) 663-6000
IPR2017-00379
CERTIFICATE OF SERVICE
I hereby certify that on December 7th, I caused a true and correct copy of the
foregoing materials:
Petition for Inter Partes Review of U.S. Patent No. 6,079,854 Under 35
U.S.C. 312 and 37 C.F.R. 42.104
Exhibit List
Exhibits for Petition for Inter Partes Review of U.S. Patent No. 6,079,854
(EX10011016)
Word Count Certificate of Compliance
Fee Authorization
Power of Attorney
to be served via Federal Express on the following correspondent of record as listed
on PAIR:
Fox Rothschild LLP
997 Lenox Drive, Bldg. #3
Lawrenceville NJ 08648
56100
/Daniel V. Williams/
Daniel V. Williams
ii

Unified Patents Inc. v. Jakuta Diodes, LLC, IPR2017-00379 (Dec. 7, 2016)

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DOCKET NO.

BEFORE THE PATENT TRIAL AND APPEAL BOARD

UNIFIED PATENTS INC.

MANDATORY NOTICES ............................................................................. 1

Real Party-in-Interest ............................................................................ 1

CERTIFICATION OF GROUNDS FOR STANDING .................................. 2

OVERVIEW OF CHALLENGE AND RELIEF REQUESTED .................... 2

Prior Art Patents and Printed Publications ............................................ 3

US Pat. 5,764,845 (filed on June 24, 1994; issued on June 9,

Grounds for Challenge .......................................................................... 3

OVERVIEW OF THE 854 PATENT ............................................................ 7

Summary of the Alleged Invention ....................................................... 7

CLAIM CONSTRUCTION .......................................................................... 18

Diffusing Light .................................................................................... 19

VII. SPECIFIC GROUNDS FOR PETITION ...................................................... 20

Ground I: Claims 3, 4, 7-11, 19 and 27 are rendered obvious by

Overview of Nagatani ............................................................... 21

Pursuant to 37 C.F.R. 42.8(b)(1), Unified Patents Inc. (Unified or

US Pat. No. 6,079,854 (854 patent Patent (EX1001)) is owned by Jakuta

Service Information, Email, Hand Delivery and Postal

Unified consents to electronic service at david.cavanaugh@wilmerhale.com

CERTIFICATION OF GROUNDS FOR STANDING

OVERVIEW OF CHALLENGE AND RELIEF REQUESTED

claims 3, 4, 7-11, 19 and 27 of the 854 Patent.

The following references are pertinent to the grounds of unpatentability

US Pat. 5,764,845 (filed on June 24, 1994; issued on June 9,

Grounds for Challenge

This Petition, supported by the declaration of Donald B. Carlin (Carlin

America Invents Act (AIA). Accordingly, pre-AIA statutory framework applies.

(JPH01-079204, Figure 1, 2 and 5 (EX1004) (annotations added)).

(JPH04-133832, Figure 29 (EX1005)).

OVERVIEW OF THE 854 PATENT

Summary of the Alleged Invention

(Id. at Figure 1 (EX1001)); (Carlin 28 (EX1003)).

The secondary light beams 32 are further diffused in secondary chamber 26

Light diffuser 34 is constructed from a plurality of cells 36. (854 patent at

As shown by annotated Figure 4, light beam 56 is more spread out relative to

Level of Ordinary Skill in the Art

(Amended) A device for diffusing light from a

luminous body, the device comprising:

27. (Amended) A method of diffusing light, comprising the steps of:

The conducting rod is referenced in the specification as element 30, not

element 60 as shown in Figure 6. (Id. (EX1015)).

broadest reasonable construction in light of the specification.

Petitioner applies the broadest reasonable construction standard as required by

the governing regulations. 37 C.F.R. 42.100(b). Petitioner reserves the right to

Any claim terms not included should be given their broadest

reasonable interpretation in light of the specification, as commonly understood by

The term diffusing light/diffusing the light, as recited in challenged

(854 patent at 4:13-16 (EX1001)).

Similarly, the second light

diffuser means 34 is described as providing further dispersion to produce the

Nagatani is not of record in the 854 patent. Nagatani discloses an

The lighting device includes a light source 20 disposed within a reflection

Light radiated from

(EX1002)). The light guides of Figure 6 form a truncated body. (Carlin 68

An opening in the form of a slit is formed in a surface of the reflection box

-10 degrees from

Figure 1 of the 854

Nagatani discloses a light fixture. Nagatani discloses a light source device

a housing having an interior region extending to an

Nagatani discloses a housing having an interior region extending to an

While Nagatani discloses a light fixture, this preamble limitation is not

means for illuminating the housing operatively