Interference No. 104,649
Page No. 29
Sibbald's prism strip with Cobb's prism sheet would not further reduce the size of Sibbald's
,'more compact device." Moreover, as apparent from Figure 3 of Sibbald, even with a prism strip
44, Sibbald does not describe or suggest a device where reflected light is emitted from a plurality
of exit surfaces. Accordingly, Sibbald does not motivate one skilled in the art to replace
Sibbald's prism strip 44 with the prism sheet of Cobb to arrive at the Keagy's claimed device
where reflected light is emitted from a plurality of exit surfaces.
Additionally, Zhou has cited several references as supporting an obviousness
determination for certain Keagy's dependent claims. For example, Zhou has cited the teachings
of Usui '797 and Elmes '083, Igaki (ZX 2011) and the 3MTM Brightness Enhancement Film
(BEF) 11 product description (KX 1003). As applied by Zhou, these references do not make up
for the deficiencies of the Sibbald and Cobb references. Specifically, the additional references do
not teach, disclose or suggest the replacement of Sibbald's prism strip with a prism sheet to
further reduce the size of Sibbald's "more compact device."
Zhou has failed to demonstrate that Keagy's corresponding claims are anticipated or
rendered obvious by the prior art. Accordingly, Zhou Preliminary Motion I is denied.
C. Zhou Preliminary Motion 2 Fails to Show that Keagy's Corresponding Claims
Lack Sufficient Description and/or are Indefinite
Zhou Preliminary Motion 2 requests judgment that Keagy's corresponding claims be
found unpatentable for lack of written description under 35 U.S.C. § 112, 1 st paragraph and
unpatentable for lack of definiteness under 35 U.S.C. § 112, 2nd paragraph. (Zhou Preliminary
Motion 2, Paper No. 25, p. 1). Generally, it is Zhou's position that one of ordinary skill in the
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