ZHOU et al. V. KEAGY et al. - Page 47



                                                                                  Interference No. 104,649            
                                                                                              Page No. 44             
             respect to a normal axis. As such, Keagy alleges that it would have been obvious to one of               
             ordinary skill in the art to reduce the aberration of Zhou by reducing the angle of the light rays       
             coming from the exit surfaces. Keagy states that a second prism sheet could be used to reduce            
             the angles. (Paper No. 30, pages 9-10).                                                                  
                    Zhou disagrees with Keagy's analysis of the prior art and its teachings. At the outset,           
             Zhou argues that none of the prior art references cited by Keagy disclose or suggest the use of          
             two sheet prisms stacked substantially in parallel. Moreover, Zhou argues that Igaki teaches that        
             a trapezoidal distortion problem may be corrected through the use of a "holographic fingerprint          
             sensor." (See Igaki, KX 1002, p. 1794). As such, Zhou argues that one skilled in the art reading         
             Igaki would be guided to a holographic fingerprint sensor rather than the claimed addition of a          
             second-prism type device to bend light to a different location. (Zhou. Opposition 1, Paper No. 33,       
             pages 5-6).                                                                                              
                    Additionally, Zhou states that the brightness enhancement sheets (BEF) cited by Keagy             
             were commonly used for enhancing the brightness in displays. Specifically, Zhou argues that the          
             BEF sheets enhanced brightness by "converting a set of light rays occupying a large range of             
             angles into a set that occupies a smaller set of angles." (Paper No. 33, p. 6).                          
                    In support of its Opposition, Zhou cites a declaration of Prof. Mark A Neifeld.                   
             Specifically, Professor Neifeld testified that:                                                          
                    (6) Based on my experience in the optics field, it is my opinion that the                         
                           invention of Zhou's claim I I would not have been obvious to a person of                   
                           ordinary skill at the time the invention was made, even if such a person                   
                           were presented with the fingerprint system of either claims I or 10 of the                 
                           '858 patent, taken in consideration with the references of Exhibits 1002                   
                           1004.                                                                                      









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