Certain Liquid Crystal Display Devices, Including Monitors, Televisions, Modules, and Components Thereof; Notice of Commission Determination To Review-In-Part a Final Determination; Schedule for Filing Written Submissions, 20048-20050 [2012-7628]
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20048
Federal Register / Vol. 77, No. 64 / Tuesday, April 3, 2012 / Notices
Corporation of Japan; Shuttle Inc. of
Taiwan; and Systemax Inc. of NY.
Proposed respondents, other
interested parties, and members of the
public are invited to file comments, not
to exceed five (5) pages in length,
inclusive of attachments, on any public
interest issues raised by the complaint
or section 210.8(b) filing. Comments
should address whether issuance of the
relief specifically requested by the
complainant in this investigation would
affect the public health and welfare in
the United States, competitive
conditions in the United States
economy, the production of like or
directly competitive articles in the
United States, or United States
consumers.
In particular, the Commission is
interested in comments that:
(i) Explain how the articles
potentially subject to the requested
remedial orders are used in the United
States;
(ii) identify any public health, safety,
or welfare concerns in the United States
relating to the requested remedial
orders;
(iii) identify like or directly
competitive articles that complainant,
its licensees, or third parties make in the
United States which could replace the
subject articles if they were to be
excluded;
(iv) indicate whether complainant,
complainant’s licensees, and/or third
party suppliers have the capacity to
replace the volume of articles
potentially subject to the requested
exclusion order and/or a cease and
desist order within a commercially
reasonable time; and
(v) explain how the requested
remedial orders would impact United
States consumers.
Written submissions must be filed no
later than by close of business, eight
calendar days after the date of
publication of this notice in the Federal
Register. There will be further
opportunities for comment on the
public interest after the issuance of any
final initial determination in this
investigation.
Persons filing written submissions
must file the original document
electronically on or before the deadlines
stated above and submit 8 true paper
copies to the Office of the Secretary by
noon the next day pursuant to section
210.4(f) of the Commission’s Rules of
Practice and Procedure (19 CFR
210.4(f)). Submissions should refer to
the docket number (‘‘Docket No. 2889’’)
in a prominent place on the cover page
and/or the first page. (See Handbook for
Electronic Filing Procedures, https://
www.usitc.gov/secretary/
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fed_reg_notices/rules/
handbook_on_electronic_filing.pdf).
Persons with questions regarding filing
should contact the Secretary (202–205–
2000).
Any person desiring to submit a
document to the Commission in
confidence must request confidential
treatment. All such requests should be
directed to the Secretary to the
Commission and must include a full
statement of the reasons why the
Commission should grant such
treatment. See 19 CFR 201.6. Documents
for which confidential treatment by the
Commission is properly sought will be
treated accordingly. All nonconfidential
written submissions will be available for
public inspection at the Office of the
Secretary and on EDIS.
This action is taken under the
authority of section 337 of the Tariff Act
of 1930, as amended (19 U.S.C. 1337),
and of sections 201.10 and 210.8(c) of
the Commission’s Rules of Practice and
Procedure (19 CFR 201.10, 210.8(c)).
Issued: March 29, 2012.
By order of the Commission.
James R. Holbein,
Secretary to the Commission.
[FR Doc. 2012–7936 Filed 4–2–12; 8:45 am]
BILLING CODE 7020–02–P
INTERNATIONAL TRADE
COMMISSION
[Investigation No. 337–TA–741/749]
Certain Liquid Crystal Display Devices,
Including Monitors, Televisions,
Modules, and Components Thereof;
Notice of Commission Determination
To Review-In-Part a Final
Determination; Schedule for Filing
Written Submissions
U.S. International Trade
Commission.
ACTION: Notice.
AGENCY:
Notice is hereby given that
the U.S. International Trade
Commission has determined to review
certain portions of the final initial
determination (‘‘ID’’) issued by the
presiding administrative law judge
(‘‘ALJ’’) on January 12, 2012 in the
above-captioned investigation.
FOR FURTHER INFORMATION CONTACT: Jia
Chen, Office of the General Counsel,
U.S. International Trade Commission,
500 E Street SW., Washington, DC
20436, telephone (202) 708–4737.
Copies of non-confidential documents
filed in connection with this
investigation are or will be available for
inspection during official business
hours (8:45 a.m. to 5:15 p.m.) in the
SUMMARY:
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Office of the Secretary, U.S.
International Trade Commission, 500 E
Street SW., Washington, DC 20436,
telephone (202) 205–2000. General
information concerning the Commission
may also be obtained by accessing its
Internet server at https://www.usitc.gov.
The public record for this investigation
may be viewed on the Commission’s
electronic docket (EDIS) at https://
edis.usitc.gov. Hearing-impaired
persons are advised that information on
this matter can be obtained by
contacting the Commission’s TDD
terminal on (202) 205–1810.
SUPPLEMENTARY INFORMATION: The
Commission instituted Inv. No. 337–
TA–741 on October 18, 2010, based on
a complaint filed by Thomson Licensing
SAS of France and Thomson Licensing
LLC of Princeton, New Jersey
(collectively ‘‘Thomson’’). 75 FR 63856
(Oct. 18, 2010). The complaint alleged
violations of section 337 of the Tariff
Act of 1930, as amended 19 U.S.C. 1337,
by reason of infringement of various
claims of United States Patent Nos.
6,121,941 (‘‘the ’941 patent’’); 5,978,063
(‘‘the ’063 patent’’); 5,648,674 (‘‘the ’674
patent’’); 5,621,556 (‘‘the ’556 patent’’);
and 5,375,006 (‘‘the ’006 patent’’). The
Commission instituted Inv. No. 337–
TA–749 on November 30, 2010, based
on a complaint filed by Thomson. 75 FR
74080 (Nov. 30, 2010). The complaint
alleged violations of section 337 of the
Tariff Act of 1930 by reason of
infringement of various claims of the
’063, ’556, and ’006 patents. On January
5, 2011, the Commission consolidated
the two investigations. The respondents
are Chimei InnoLux Corporation of
Miaoli County, Taiwan and InnoLux
Corportation of Austin, Texas
(collectively, ‘‘CMI’’); MStar
Semiconductor Inc. of ChuPei, Taiwan
(‘‘MStar’’); Qisda Corporation of
Taoyuan, Taiwan and Qisda America
Corporation of Irvine, California
(collectively, ‘‘Qisda’’); BenQ
Corporation of Taipei, Taiwan, BenQ
America Corporation of Irvine,
California, and BenQ Latin America
Corporation of Miami, Florida
(collectively ‘‘BenQ’’); Realtek
Semicondustor Corp. of Hsinchu,
Taiwan (‘‘Realtek’’); and AU Optronics
Corp. of Hsinchu, Taiwan and AU
Optronics Corp. America of Houston,
Texas (collectively ‘‘AUO’’).
On January 12, 2012, the ALJ issued
the subject ID finding a violation of
Section 337 with respect to the ’674
patent. The ALJ found that the CMI
accused products including the Type 2
Array Circuitry and any Qisda or BenQ
accused products incorporating these
CMI accused products infringe the
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asserted claims of the ’674 patent. The
ALJ found that no other accused
products infringe the ’674 patent. The
ALJ also found that no accused products
infringe the asserted claims of the ’063
patent, the ’006 patent, the ’556 patent,
or the ’941 patent. The ALJ also found
that claims 1, 2, 3, 4, 8, 11, 12, 14, and
18 of the ’063 patent are invalid for
obviousness under 35 U.S.C. 103, and
that claims 4 and 14 of the ’006 patent
are invalid as anticipated under 35
U.S.C. 102. The ALJ further found that
claim 17 of the ’063 patent, claim 7 of
the ’006 patent, and the asserted claims
of the ’556 patent, the ’674 patent, and
the ’941 patent are not invalid. The ALJ
concluded that a domestic industry
exists in the United States that exploits
the asserted patents as required by 19
U.S.C. 1337(a)(2). On January 25, 2011,
Thomson, CMI, MStar, Realtek, and
AUO each filed a petition for review of
the ID. BenQ and Qisda filed a joint
petition for review incorporating the
other respondents’ arguments by
reference.
Having examined the record of this
investigation, including the ALJ’s final
ID and the submissions of the parties,
the Commission has determined to
review (1) claim construction of the
limitation ‘‘layer’’ of the asserted claims
of the ’006 patent; (2) infringement of
the asserted claims of the ’006 patent;
(3) anticipation of claims 4 and 7 of the
’006 patent by Scheuble; (4) the claim
construction of the limitations
‘‘mechanically rubbing’’/‘‘mechanically
rubbed,’’ ‘‘a plurality of spacing
elements,’’ and ‘‘an affixing layer’’ of the
asserted claims of the ’063 patent; (5)
infringement of the asserted claims of
the ’063 patent; (6) obviousness of the
asserted claims of the ’063 patent in
view of Sugata and Tsuboyama; (7)
whether Lowe and Miyazaki are prior
art to the asserted claims of the ’063
patent; (8) anticipation of the asserted
claims of the ’063 patent by Lowe; (9)
anticipation of the asserted claims of the
’063 patent by Miyazaki; (10)
obviousness of the asserted claim of the
’556 patent in view of Takizawa and
Possin; (11) anticipation and
obviousness of the asserted claims of the
’674 patent in view of Fujitsu; (12) claim
construction of the ‘‘second rate’’
‘‘determined by’’ limitation of the
asserted claims of the ’941 patent and
the ‘‘input video signal’’ limitation of
claim 4 of the ’941 patent; (13)
infringement of the asserted claims of
the ’941 patent; (14) anticipation of the
asserted claims of the ’941 patent by
Baba; (15) exclusion of evidence of the
ViewFrame II+2 LCD Panel; and (16)
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economic prong of the domestic
industry requirement.
The Commission has also determined
to review and to take no position on the
claim construction of the terms ‘‘drain
electrodes’’ and ‘‘source electrodes’’ of
the ’556 patent.
The parties should brief their
positions on the issues on review with
reference to the applicable law and the
evidentiary record. In connection with
its review, the Commission is
particularly interested in responses to
the following questions:
Question 1: The ALJ construed the term ‘‘a
plurality of spacing elements’’ of claims 1
and 11 of the ’063 patent as ‘‘two or more
structures, not physically connected to one
another, which structures serve to
substantially uniformly separate two
substrates, said structures formed on one of
said two substrates and contacting the second
substrate.’’ ID at 43. Does the proper
construction require that the ‘‘spacing
elements’’ contact the ‘‘second substrate?’’
Does certain language from claim 1 (‘‘the two
substrates remaining substantially uniformly
separated from each other by said spacing
elements’’) and from claim 11 (‘‘said second
substrate being kept at a substantially
uniform distance from said first substrate by
said spacing elements’’) require that the
spacing elements physically separate the two
substrates? Please cite to evidence in the
record showing the understanding of person
of ordinary skill in the art at the time of the
’063 patent invention.
Question 2: The ALJ construed ‘‘an affixing
layer’’ of claim 1 of the ’063 patent as ‘‘a
stratum of material that attaches the spacing
elements to a substrate, and which is separate
and distinct from said spacing elements.’’ ID
at 34. Is this construction supported by the
intrinsic evidence? In particular, does the
preferred embodiment of the ’063 patent
specification disclose forming spacers
directly from the affixing layer?
Question 3: The ALJ construed the term ‘‘a
plurality of spacing elements separate from
one another’’ as ‘‘two or more structures, not
physically connected to one another, which
structures serve to substantially uniformly
separate two substrates, said structures
formed on one of said two substrates and
contacting the second substrate.’’ ID at 43. Do
the main photospacers in the accused CMI
modules meet the limitation under the ALJ’s
construction? Please cite to the evidence in
the record.
Question 4: With respect to the ’063 patent,
the ALJ stated in the ID that [[
]] ID
at 334. He also stated that [[
Id. Are
these accurate statements? Please provide
citations to the record as support. In
addition, please identify [[
]].
Question 5: At the time of the invention of
the ’063 patent, would it have been obvious
to combine the teachings of Sugata and
Tsuboyama, such that the substrate on which
the spacers are formed in Sugata would be
rubbed after the spacers are formed? Is the
combination of the teachings of Sugata and
Tsuboyama a combination of known
elements that yield predictable results? Are
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20049
there any secondary considerations such as
commercial success that would be probative
of non-obviousness? Please cite evidence in
the record as support.
Question 6: Has Thomson produced
sufficient independent corroborating
evidence showing that the inventions of each
of the asserted claims of the ’063 patent have
been reduced to practice before the filing
dates of Lowe and Miyazaki? In particular,
please discuss whether the evidence shows
that display cells embodying the inventions
have been tested and shown to work for their
intended purposes.
Question 7: Does the intrinsic evidence
support the construction of the term ‘‘plate’’
recited in claim 3 of the ’006 patent to
require a solid and not liquid material? ID at
220. Can the term ‘‘plate’’ include a liquid
compensation layer sealed between two glass
substrates? See CMI Petition at 31. Please cite
to the evidence of the record as support.
Under the proper construction of the term
‘‘plate,’’ does Scheuble anticipate claims 4
and 7 of the ’006 patent?
Question 8: With respect to infringement of
the asserted claims of the ’006 patent, what
is an acceptable range of variance in the
measurement of n2 and n3, given the
probability of errors in any real-world
measurement of the index of refraction? What
are the values and measurement errors of n2
and n3 for the entire layer in the accused
devices? How close does the real-world
measurement of n2 have to be compared to
n3 for the layer to be considered ‘‘uniaxial’’
as construed by the ALJ? How close would
n2 have to be to n3 for the layer to be
equivalent to a ‘‘uniaxial’’ layer under the
ALJ’s construction? Please limit your
response to the evidence in the record.
Question 9: Would a person of ordinary
skill in the art be motivated to modify
Takizawa to use only one mask to form the
plurality of etch stoppers recited in claim 3
of the ’556 patent? Does Takizawa teach away
from using a single mask to form the plurality
of etch stoppers? Please cite to the evidence
in the record. Please discuss any Federal
Circuit case law regarding obviousness of a
patent claim that requires a single structure
or process, in light of prior art that discloses
one or more such structures or processes.
Question 10: What is the proper
construction of the limitation ‘‘a second rate’’
‘‘determined by’’ of the asserted claims of the
’941 patent? Please provide all relevant
intrinsic and extrinsic evidence of record,
including expert testimony.
Question 11: Do the respondents’ accused
products infringe claims 1 and 4 of the ’941
patent under Thomson’s construction of
‘‘determined by.’’ Please cite any record
evidence, including expert testimony, to
support your response.
Question 12: Discuss any Federal Circuit
case law relevant to whether or not claim 4
of the ’941 patent requires an input video
signal for a finding of infringement. Please
discuss any basis, other than the language of
the claims, (e.g., prosecution history) that
provides guidance on whether or not claim
4 requires an input video signal.
Question 13: For claims 1 and 4 of the ’941
patent, what is the proper construction of the
term ‘‘za’’ in the ratio ft/za ‘‘required for a
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cathode ray tube.’’ For an interlaced signal
associated with a CRT display, does za refer
to the number of lines updated in a given
field period? Please cite to the intrinsic
evidence of the ’941 patent as support.
Question 14: Is Mr. Vogeley’s testimony
regarding the prior art status of the
ViewFrame II+2 with respect to the ’941
patent sufficiently corroborated under a ‘‘rule
of reason’’ analysis? Assuming that the
ViewFrame II+2 is prior art to the asserted
claims of the ’941 patent, does the
ViewFrame II+2 anticipate each of the
asserted claims? Please cite to the evidence
in the record.
Question 15: With respect to respondents’
arguments that Thomson’s investments in
licensing its LCD patent portfolio cannot be
completely allocated to the asserted patents,
what portion of the investments should be
allocated to the asserted patents? Please
provide the legal and factual basis for such
allocations.
Question 16: Based on the factors outlined
below, please discuss the legal and factual
bases for your position as to whether
Thomson’s investment in licensing for the
asserted patents is substantial. Please
consider at least the following factors: (1) The
industry and size and scope of complainant’s
operations; (2) the existence of other types of
‘‘exploitation’’ of the asserted patents such as
research, development, or engineering; (3)
the existence of license-related ancillary
activities such as ensuring compliance with
the license agreement and providing training
or technical support to its licensees; (4)
whether complainant’s licensing activities
are continuing; (5) whether complainant’s
licensing activities are those referenced
favorably in the legislative history of section
337(1)(3)(C); (6) complainant’s return on
investment; and (7) the extent to which
complainant’s LCD portfolio licenses are
worldwide licenses.
Question 17: What should the Commission
compare complainants’ investments to in
analyzing whether the complainants’
investments are substantial? Please cite any
relevant legal basis and evidence of record to
support your position.
Question 18: Should Thomson’s expenses
related to the acquisition of the Xerox patent
portfolio be [[
]]? Is the purchase of
a patent considered an exploitation of that
patent under section 337(a)(3)(C)? Can
investments in [[
]] for purposes of
establishing domestic industry under section
337(a)(3)(C)? With respect to any argument
that the Commission should [[
]]?
Further, how should the [[
]]?
Please provide legal and factual support for
your position.
Question 19: Should the Commission
consider litigation expenses for the particular
Section 337 investigation at issue? Should
the Commission consider litigation expenses
for parallel district court actions? Should it
matter if the district court actions are stayed
or ongoing?
Question 20: Should the Commission
consider reexamination expenses when
determining if a domestic industry exists and
if so should they be treated in the same
manner as litigation expenses in determining
whether or not the expenses are investments
in licensing?
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In connection with the final
disposition of this investigation, the
Commission may (1) issue an order that
could result in the exclusion of the
subject articles from entry into the
United States, and/or (2) issue one or
more cease and desist orders that could
result in a respondent being required to
cease and desist from engaging in unfair
acts in the importation and sale of such
articles. Accordingly, the Commission is
interested in receiving written
submissions that address the form of
remedy, if any, that should be ordered.
If a party seeks exclusion of an article
from entry into the United States for
purposes other than entry for
consumption, the party should so
indicate and provide information
establishing that activities involving
other types of entry either are adversely
affecting it or likely to do so. For
background, see Certain Devices for
Connecting Computers via Telephone
Lines, Inv. No. 337–TA–360, USITC
Pub. No. 2843, Comm’n Op. at 9
(December 1994).
If the Commission contemplates some
form of remedy, it must consider the
effects of that remedy upon the public
interest. The factors the Commission
will consider include the effect that an
exclusion order and/or cease and desist
orders would have on (1) the public
health and welfare, (2) competitive
conditions in the U.S. economy, (3) U.S.
production of articles that are like or
directly competitive with those that are
subject to investigation, and (4) U.S.
consumers. The Commission is
therefore interested in receiving written
submissions that address the
aforementioned public interest factors
in the context of this investigation.
If the Commission orders some form
of remedy, the United States Trade
Representative, as delegated by the
President, has 60 days to approve or
disapprove the Commission’s action.
See Presidential Memorandum of July
21, 2005, 70 FR 43251 (July 26, 2005).
During this period, the subject articles
would be entitled to enter the United
States under bond, in an amount
determined by the Commission and
prescribed by the Secretary of the
Treasury. The Commission is therefore
interested in receiving submissions
concerning the amount of the bond that
should be imposed if a remedy is
ordered.
Written Submissions: The parties to
the investigation are requested to file
written submissions on the issues
identified in this notice. Parties to the
investigation, interested government
agencies, and any other interested
parties are encouraged to file written
submissions on the issues of remedy,
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the public interest, and bonding. Such
submissions should address the
recommended determination by the ALJ
on remedy and bonding. Complainant is
also requested to submit proposed
remedial orders for the Commission’s
consideration. Complainant is also
requested to state the date that the
patent expires and the HTSUS
subheadings under which the accused
products are imported. The written
submissions and proposed remedial
orders must be filed no later than close
of business on Monday, April 9, 2012.
Reply submissions must be filed no later
than the close of business on Monday,
April 16, 2012. The written submissions
must be no longer than 75 pages and the
reply submissions must be no longer
than 35 pages. No further submissions
on these issues will be permitted unless
otherwise ordered by the Commission.
Persons filing written submissions
must do so in accordance with
Commission rule 210.4(f), 19 CFR
210.4(f), which requires electronic
filing. The original document and 8 true
copies thereof must also be filed on or
before the deadlines stated above with
the Office of the Secretary. Any person
desiring to submit a document to the
Commission in confidence must request
confidential treatment unless the
information has already been granted
such treatment during the proceedings.
All such requests should be directed to
the Secretary of the Commission and
must include a full statement of the
reasons why the Commission should
grant such treatment. See 19 CFR 210.6.
Documents for which confidential
treatment by the Commission is sought
will be treated accordingly. All nonconfidential written submissions will be
available for public inspection at the
Office of the Secretary and on EDIS.
The authority for the Commission’s
determination is contained in section
337 of the Tariff Act of 1930, as
amended (19 U.S.C. 1337), and in
sections 210.42–46 and 210.50 of the
Commission’s Rules of Practice and
Procedure (19 CFR 210.42–46 and
210.50).
By order of the Commission.
Issued: March 26, 2012.
James R. Holbein,
Secretary to the Commission.
[FR Doc. 2012–7628 Filed 4–2–12; 8:45 am]
BILLING CODE P
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Agencies
[Federal Register Volume 77, Number 64 (Tuesday, April 3, 2012)]
[Notices]
[Pages 20048-20050]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-7628]
-----------------------------------------------------------------------
INTERNATIONAL TRADE COMMISSION
[Investigation No. 337-TA-741/749]
Certain Liquid Crystal Display Devices, Including Monitors,
Televisions, Modules, and Components Thereof; Notice of Commission
Determination To Review-In-Part a Final Determination; Schedule for
Filing Written Submissions
AGENCY: U.S. International Trade Commission.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: Notice is hereby given that the U.S. International Trade
Commission has determined to review certain portions of the final
initial determination (``ID'') issued by the presiding administrative
law judge (``ALJ'') on January 12, 2012 in the above-captioned
investigation.
FOR FURTHER INFORMATION CONTACT: Jia Chen, Office of the General
Counsel, U.S. International Trade Commission, 500 E Street SW.,
Washington, DC 20436, telephone (202) 708-4737. Copies of non-
confidential documents filed in connection with this investigation are
or will be available for inspection during official business hours
(8:45 a.m. to 5:15 p.m.) in the Office of the Secretary, U.S.
International Trade Commission, 500 E Street SW., Washington, DC 20436,
telephone (202) 205-2000. General information concerning the Commission
may also be obtained by accessing its Internet server at https://www.usitc.gov. The public record for this investigation may be viewed
on the Commission's electronic docket (EDIS) at https://edis.usitc.gov.
Hearing-impaired persons are advised that information on this matter
can be obtained by contacting the Commission's TDD terminal on (202)
205-1810.
SUPPLEMENTARY INFORMATION: The Commission instituted Inv. No. 337-TA-
741 on October 18, 2010, based on a complaint filed by Thomson
Licensing SAS of France and Thomson Licensing LLC of Princeton, New
Jersey (collectively ``Thomson''). 75 FR 63856 (Oct. 18, 2010). The
complaint alleged violations of section 337 of the Tariff Act of 1930,
as amended 19 U.S.C. 1337, by reason of infringement of various claims
of United States Patent Nos. 6,121,941 (``the '941 patent''); 5,978,063
(``the '063 patent''); 5,648,674 (``the '674 patent''); 5,621,556
(``the '556 patent''); and 5,375,006 (``the '006 patent''). The
Commission instituted Inv. No. 337-TA-749 on November 30, 2010, based
on a complaint filed by Thomson. 75 FR 74080 (Nov. 30, 2010). The
complaint alleged violations of section 337 of the Tariff Act of 1930
by reason of infringement of various claims of the '063, '556, and '006
patents. On January 5, 2011, the Commission consolidated the two
investigations. The respondents are Chimei InnoLux Corporation of
Miaoli County, Taiwan and InnoLux Corportation of Austin, Texas
(collectively, ``CMI''); MStar Semiconductor Inc. of ChuPei, Taiwan
(``MStar''); Qisda Corporation of Taoyuan, Taiwan and Qisda America
Corporation of Irvine, California (collectively, ``Qisda''); BenQ
Corporation of Taipei, Taiwan, BenQ America Corporation of Irvine,
California, and BenQ Latin America Corporation of Miami, Florida
(collectively ``BenQ''); Realtek Semicondustor Corp. of Hsinchu, Taiwan
(``Realtek''); and AU Optronics Corp. of Hsinchu, Taiwan and AU
Optronics Corp. America of Houston, Texas (collectively ``AUO'').
On January 12, 2012, the ALJ issued the subject ID finding a
violation of Section 337 with respect to the '674 patent. The ALJ found
that the CMI accused products including the Type 2 Array Circuitry and
any Qisda or BenQ accused products incorporating these CMI accused
products infringe the
[[Page 20049]]
asserted claims of the '674 patent. The ALJ found that no other accused
products infringe the '674 patent. The ALJ also found that no accused
products infringe the asserted claims of the '063 patent, the '006
patent, the '556 patent, or the '941 patent. The ALJ also found that
claims 1, 2, 3, 4, 8, 11, 12, 14, and 18 of the '063 patent are invalid
for obviousness under 35 U.S.C. 103, and that claims 4 and 14 of the
'006 patent are invalid as anticipated under 35 U.S.C. 102. The ALJ
further found that claim 17 of the '063 patent, claim 7 of the '006
patent, and the asserted claims of the '556 patent, the '674 patent,
and the '941 patent are not invalid. The ALJ concluded that a domestic
industry exists in the United States that exploits the asserted patents
as required by 19 U.S.C. 1337(a)(2). On January 25, 2011, Thomson, CMI,
MStar, Realtek, and AUO each filed a petition for review of the ID.
BenQ and Qisda filed a joint petition for review incorporating the
other respondents' arguments by reference.
Having examined the record of this investigation, including the
ALJ's final ID and the submissions of the parties, the Commission has
determined to review (1) claim construction of the limitation ``layer''
of the asserted claims of the '006 patent; (2) infringement of the
asserted claims of the '006 patent; (3) anticipation of claims 4 and 7
of the '006 patent by Scheuble; (4) the claim construction of the
limitations ``mechanically rubbing''/``mechanically rubbed,'' ``a
plurality of spacing elements,'' and ``an affixing layer'' of the
asserted claims of the '063 patent; (5) infringement of the asserted
claims of the '063 patent; (6) obviousness of the asserted claims of
the '063 patent in view of Sugata and Tsuboyama; (7) whether Lowe and
Miyazaki are prior art to the asserted claims of the '063 patent; (8)
anticipation of the asserted claims of the '063 patent by Lowe; (9)
anticipation of the asserted claims of the '063 patent by Miyazaki;
(10) obviousness of the asserted claim of the '556 patent in view of
Takizawa and Possin; (11) anticipation and obviousness of the asserted
claims of the '674 patent in view of Fujitsu; (12) claim construction
of the ``second rate'' ``determined by'' limitation of the asserted
claims of the '941 patent and the ``input video signal'' limitation of
claim 4 of the '941 patent; (13) infringement of the asserted claims of
the '941 patent; (14) anticipation of the asserted claims of the '941
patent by Baba; (15) exclusion of evidence of the ViewFrame II+2 LCD
Panel; and (16) economic prong of the domestic industry requirement.
The Commission has also determined to review and to take no
position on the claim construction of the terms ``drain electrodes''
and ``source electrodes'' of the '556 patent.
The parties should brief their positions on the issues on review
with reference to the applicable law and the evidentiary record. In
connection with its review, the Commission is particularly interested
in responses to the following questions:
Question 1: The ALJ construed the term ``a plurality of spacing
elements'' of claims 1 and 11 of the '063 patent as ``two or more
structures, not physically connected to one another, which
structures serve to substantially uniformly separate two substrates,
said structures formed on one of said two substrates and contacting
the second substrate.'' ID at 43. Does the proper construction
require that the ``spacing elements'' contact the ``second
substrate?'' Does certain language from claim 1 (``the two
substrates remaining substantially uniformly separated from each
other by said spacing elements'') and from claim 11 (``said second
substrate being kept at a substantially uniform distance from said
first substrate by said spacing elements'') require that the spacing
elements physically separate the two substrates? Please cite to
evidence in the record showing the understanding of person of
ordinary skill in the art at the time of the '063 patent invention.
Question 2: The ALJ construed ``an affixing layer'' of claim 1
of the '063 patent as ``a stratum of material that attaches the
spacing elements to a substrate, and which is separate and distinct
from said spacing elements.'' ID at 34. Is this construction
supported by the intrinsic evidence? In particular, does the
preferred embodiment of the '063 patent specification disclose
forming spacers directly from the affixing layer?
Question 3: The ALJ construed the term ``a plurality of spacing
elements separate from one another'' as ``two or more structures,
not physically connected to one another, which structures serve to
substantially uniformly separate two substrates, said structures
formed on one of said two substrates and contacting the second
substrate.'' ID at 43. Do the main photospacers in the accused CMI
modules meet the limitation under the ALJ's construction? Please
cite to the evidence in the record.
Question 4: With respect to the '063 patent, the ALJ stated in
the ID that [[ ]] ID at 334. He also stated that [[ Id. Are these
accurate statements? Please provide citations to the record as
support. In addition, please identify [[ ]].
Question 5: At the time of the invention of the '063 patent,
would it have been obvious to combine the teachings of Sugata and
Tsuboyama, such that the substrate on which the spacers are formed
in Sugata would be rubbed after the spacers are formed? Is the
combination of the teachings of Sugata and Tsuboyama a combination
of known elements that yield predictable results? Are there any
secondary considerations such as commercial success that would be
probative of non-obviousness? Please cite evidence in the record as
support.
Question 6: Has Thomson produced sufficient independent
corroborating evidence showing that the inventions of each of the
asserted claims of the '063 patent have been reduced to practice
before the filing dates of Lowe and Miyazaki? In particular, please
discuss whether the evidence shows that display cells embodying the
inventions have been tested and shown to work for their intended
purposes.
Question 7: Does the intrinsic evidence support the construction
of the term ``plate'' recited in claim 3 of the '006 patent to
require a solid and not liquid material? ID at 220. Can the term
``plate'' include a liquid compensation layer sealed between two
glass substrates? See CMI Petition at 31. Please cite to the
evidence of the record as support. Under the proper construction of
the term ``plate,'' does Scheuble anticipate claims 4 and 7 of the
'006 patent?
Question 8: With respect to infringement of the asserted claims
of the '006 patent, what is an acceptable range of variance in the
measurement of n2 and n3, given the probability of errors in any
real-world measurement of the index of refraction? What are the
values and measurement errors of n2 and n3 for the entire layer in
the accused devices? How close does the real-world measurement of n2
have to be compared to n3 for the layer to be considered
``uniaxial'' as construed by the ALJ? How close would n2 have to be
to n3 for the layer to be equivalent to a ``uniaxial'' layer under
the ALJ's construction? Please limit your response to the evidence
in the record.
Question 9: Would a person of ordinary skill in the art be
motivated to modify Takizawa to use only one mask to form the
plurality of etch stoppers recited in claim 3 of the '556 patent?
Does Takizawa teach away from using a single mask to form the
plurality of etch stoppers? Please cite to the evidence in the
record. Please discuss any Federal Circuit case law regarding
obviousness of a patent claim that requires a single structure or
process, in light of prior art that discloses one or more such
structures or processes.
Question 10: What is the proper construction of the limitation
``a second rate'' ``determined by'' of the asserted claims of the
'941 patent? Please provide all relevant intrinsic and extrinsic
evidence of record, including expert testimony.
Question 11: Do the respondents' accused products infringe
claims 1 and 4 of the '941 patent under Thomson's construction of
``determined by.'' Please cite any record evidence, including expert
testimony, to support your response.
Question 12: Discuss any Federal Circuit case law relevant to
whether or not claim 4 of the '941 patent requires an input video
signal for a finding of infringement. Please discuss any basis,
other than the language of the claims, (e.g., prosecution history)
that provides guidance on whether or not claim 4 requires an input
video signal.
Question 13: For claims 1 and 4 of the '941 patent, what is the
proper construction of the term ``za'' in the ratio ft/za ``required
for a
[[Page 20050]]
cathode ray tube.'' For an interlaced signal associated with a CRT
display, does za refer to the number of lines updated in a given
field period? Please cite to the intrinsic evidence of the '941
patent as support.
Question 14: Is Mr. Vogeley's testimony regarding the prior art
status of the ViewFrame II+2 with respect to the '941 patent
sufficiently corroborated under a ``rule of reason'' analysis?
Assuming that the ViewFrame II+2 is prior art to the asserted claims
of the '941 patent, does the ViewFrame II+2 anticipate each of the
asserted claims? Please cite to the evidence in the record.
Question 15: With respect to respondents' arguments that
Thomson's investments in licensing its LCD patent portfolio cannot
be completely allocated to the asserted patents, what portion of the
investments should be allocated to the asserted patents? Please
provide the legal and factual basis for such allocations.
Question 16: Based on the factors outlined below, please discuss
the legal and factual bases for your position as to whether
Thomson's investment in licensing for the asserted patents is
substantial. Please consider at least the following factors: (1) The
industry and size and scope of complainant's operations; (2) the
existence of other types of ``exploitation'' of the asserted patents
such as research, development, or engineering; (3) the existence of
license-related ancillary activities such as ensuring compliance
with the license agreement and providing training or technical
support to its licensees; (4) whether complainant's licensing
activities are continuing; (5) whether complainant's licensing
activities are those referenced favorably in the legislative history
of section 337(1)(3)(C); (6) complainant's return on investment; and
(7) the extent to which complainant's LCD portfolio licenses are
worldwide licenses.
Question 17: What should the Commission compare complainants'
investments to in analyzing whether the complainants' investments
are substantial? Please cite any relevant legal basis and evidence
of record to support your position.
Question 18: Should Thomson's expenses related to the
acquisition of the Xerox patent portfolio be [[ ]]? Is the purchase
of a patent considered an exploitation of that patent under section
337(a)(3)(C)? Can investments in [[ ]] for purposes of establishing
domestic industry under section 337(a)(3)(C)? With respect to any
argument that the Commission should [[ ]]? Further, how should the
[[ ]]? Please provide legal and factual support for your position.
Question 19: Should the Commission consider litigation expenses
for the particular Section 337 investigation at issue? Should the
Commission consider litigation expenses for parallel district court
actions? Should it matter if the district court actions are stayed
or ongoing?
Question 20: Should the Commission consider reexamination
expenses when determining if a domestic industry exists and if so
should they be treated in the same manner as litigation expenses in
determining whether or not the expenses are investments in
licensing?
In connection with the final disposition of this investigation, the
Commission may (1) issue an order that could result in the exclusion of
the subject articles from entry into the United States, and/or (2)
issue one or more cease and desist orders that could result in a
respondent being required to cease and desist from engaging in unfair
acts in the importation and sale of such articles. Accordingly, the
Commission is interested in receiving written submissions that address
the form of remedy, if any, that should be ordered. If a party seeks
exclusion of an article from entry into the United States for purposes
other than entry for consumption, the party should so indicate and
provide information establishing that activities involving other types
of entry either are adversely affecting it or likely to do so. For
background, see Certain Devices for Connecting Computers via Telephone
Lines, Inv. No. 337-TA-360, USITC Pub. No. 2843, Comm'n Op. at 9
(December 1994).
If the Commission contemplates some form of remedy, it must
consider the effects of that remedy upon the public interest. The
factors the Commission will consider include the effect that an
exclusion order and/or cease and desist orders would have on (1) the
public health and welfare, (2) competitive conditions in the U.S.
economy, (3) U.S. production of articles that are like or directly
competitive with those that are subject to investigation, and (4) U.S.
consumers. The Commission is therefore interested in receiving written
submissions that address the aforementioned public interest factors in
the context of this investigation.
If the Commission orders some form of remedy, the United States
Trade Representative, as delegated by the President, has 60 days to
approve or disapprove the Commission's action. See Presidential
Memorandum of July 21, 2005, 70 FR 43251 (July 26, 2005). During this
period, the subject articles would be entitled to enter the United
States under bond, in an amount determined by the Commission and
prescribed by the Secretary of the Treasury. The Commission is
therefore interested in receiving submissions concerning the amount of
the bond that should be imposed if a remedy is ordered.
Written Submissions: The parties to the investigation are requested
to file written submissions on the issues identified in this notice.
Parties to the investigation, interested government agencies, and any
other interested parties are encouraged to file written submissions on
the issues of remedy, the public interest, and bonding. Such
submissions should address the recommended determination by the ALJ on
remedy and bonding. Complainant is also requested to submit proposed
remedial orders for the Commission's consideration. Complainant is also
requested to state the date that the patent expires and the HTSUS
subheadings under which the accused products are imported. The written
submissions and proposed remedial orders must be filed no later than
close of business on Monday, April 9, 2012. Reply submissions must be
filed no later than the close of business on Monday, April 16, 2012.
The written submissions must be no longer than 75 pages and the reply
submissions must be no longer than 35 pages. No further submissions on
these issues will be permitted unless otherwise ordered by the
Commission.
Persons filing written submissions must do so in accordance with
Commission rule 210.4(f), 19 CFR 210.4(f), which requires electronic
filing. The original document and 8 true copies thereof must also be
filed on or before the deadlines stated above with the Office of the
Secretary. Any person desiring to submit a document to the Commission
in confidence must request confidential treatment unless the
information has already been granted such treatment during the
proceedings. All such requests should be directed to the Secretary of
the Commission and must include a full statement of the reasons why the
Commission should grant such treatment. See 19 CFR 210.6. Documents for
which confidential treatment by the Commission is sought will be
treated accordingly. All non-confidential written submissions will be
available for public inspection at the Office of the Secretary and on
EDIS.
The authority for the Commission's determination is contained in
section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and
in sections 210.42-46 and 210.50 of the Commission's Rules of Practice
and Procedure (19 CFR 210.42-46 and 210.50).
By order of the Commission.
Issued: March 26, 2012.
James R. Holbein,
Secretary to the Commission.
[FR Doc. 2012-7628 Filed 4-2-12; 8:45 am]
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