Interference No. 104,649
Page No. 45
(7) The reasons in support of my opinion include the fact that none of these
references describe or even remotely suggest the use of first and second
sheet prisms stacked substantially in parallel. To my knowledge, such a
structure had not existed prior to the Zhou invention. Additionally, there is
nothing in these references that would have motivated a skilled
practitioner to modify the sensing system defined by Zhou's claim I or 10
to add a second sheet prism in parallel to the first prism, As I explained
above, the conventional use of a BEF film at the time, and the use
described in Exhibits 1003 and 1004, is to enhance brightness by taking a
large range of angles and folding them into a smaller range. To add a
second BEF sheet prism to the system of claims I or 10 would not have
been obvious to a person of ordinary skill in the optical imaging field
because the invention of claim I I uses the BEF film for a purpose other
than enhancing brightness; namely, to redirect a small angular cone of
light in another direction. In my opinion, a skilled person working in the
field at the time of the Zhou invention would have lacked motivation to
use a BEF film in such an unconventional manner. To state it differently,
at the time of the Zhou invention, in my opinion it would not have been
obvious to a person of ordinary skill to take a device that was
conventionally used to increase the efficiency of backlighting in displays
and utilize it as a second sheet prism to correct for trapezoidal distortion.
(Zhou's Second Declaration of Prof Mark A. Neifeld, ZX 2015, % 6-7). Zhou concludes that
the prior art at the time of Zhou's invention would not have suggested the addition of a second
prism sheet, which was normally used for increasing the efficiency of backlighting in displays,
and utilize it as a second sheet in the fingerprint sensing system of Zhou claim 10.
Keagy has demonstrated that the problem of trapezoidal distortion in fingerprint systems
was well known in the art at the time of Zhou's invention. Yet, Keagy has not sufficiently
demonstrated that-one skilled in the art would have looked towards the use of a brightness
enhancement film to correct such a problem. Specifically, on the facts presented, Keagy has
failed to demonstrate that the prior art would have taught or suggested the addition of a second
prism sheet stacked in substantial parallel with Zhou's prism sheet of Zhou claim 10. Lacking a
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