UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner.
`____________
`
`Case IPR2021-00471
`Patent 10, 259,021
`___________________________
`
`DECLARATION OF HAMID TOLIYAT, PH.D. REGARDING APPLE’S
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 10,259,021
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`Apple v. GUI Global Products
`IPR2021-00471
`GUI Ex. 2022
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`Table of Contents
`INTRODUCTION ............................................................................................... 1
`I.
`II. QUALIFICATIONS ......................................................................................... 2
`III. MATERIALS CONSIDERED ......................................................................... 4
`IV. SUMMARY OF CONCLUSIONS .................................................................. 8
`V. LEGAL PRINCIPLES ......................................................................................... 8
`VI. PERSON OF ORDINARY SKILL IN THE ART .........................................12
`VII. CLAIM CONSTRUCTION ...........................................................................14
`VIII. OVERVIEW OF THE ‘021 PATENT ........................................................14
`IX. GROUND 1A—Claims 1, 4-7, 10, 14-16 and 19 are not obvious in view of
`Gundlach and Lee. ...................................................................................................20
`A. Overview of Gundlach ...................................................................................20
`B. Overview of Lee .............................................................................................30
`C. Dr. Cooperstock’s reasons for combining Gundlach and Lee are, to a
`POSITA, unfounded and unpersuasive, and heavily outweighed by the
`inefficiencies of such a system. ............................................................................34
`D. A POSITA would not have been motivated to replace Gundlach’s efficient
`conductive charging with far less efficient inductive charging. Any alleged
`benefits from wireless charging would have been greatly outweighed by the
`inefficiencies and addition cost, size and weight from needing a larger battery in
`the clamshell case. Further a POSITA would have been even less motivated to
`use Lee’s even more inefficient dual purpose transducer coil design. .................53
`E. A POSITA would not have understood Lee’s charging pad to be applicable
`to its dual purpose wireless charging solution. .....................................................73
`F. A POSITA would not be motivated to make the proposed Gundlach-Lee
`combination because it would drain the clamshell case battery, resulting in a
`highly undesirable charging system. .....................................................................75
`G. Analysis of Claims 1, 4-7, 10, 14-16, and 19 ..............................................77
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`1. Claim 1 ........................................................................................................78
`2. Claim 4 ........................................................................................................90
`3. Claim 5 ........................................................................................................90
`4. Claim 6 ........................................................................................................93
`5. Claim 7 ........................................................................................................93
`6. Claim 10 ......................................................................................................94
`7. Claim 14 ......................................................................................................96
`8. Claim 15 ......................................................................................................96
`9. Claim 16 ......................................................................................................97
`10. Claim 19 ...................................................................................................97
`A. Overview of Nishikawa ..................................................................................98
`B. The Alleged Gundlach-Lee-Nishikawa Combination .................................98
`C. Analysis of Claims 4 and 14 ...........................................................................99
`1. Claim 4 ........................................................................................................99
`2. Claim 14 ......................................................................................................99
`XI. GROUND 1C: Claim 10 is not obvious in view of Gundlach, Lee, and
`Rosener ...................................................................................................................100
`A. Overview of Rosener ....................................................................................100
`B. The Alleged Gundlach-Lee-Rosener Combination ......................................100
`C. Analysis of Claim 10 ....................................................................................100
`XII. GROUND 1D: Claims 2 and 12 are not obvious in view of Gundlach, Lee,
`and Brown. .............................................................................................................101
`A. Overview of Brown ......................................................................................101
`B. The Alleged Gundlach-Lee-Brown Combination ........................................102
`C. Analysis of Claims 2 and 12 .........................................................................103
`XIII. GROUND 1E: Claims 8, 9, and 17 are not obvious in view of Gundlach,
`Lee, and Mak-Fan. .................................................................................................104
`A. Overview of Mak-Fan ..................................................................................104
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`B. The Alleged Gundlach-Lee-Mak-Fan Combination ....................................105
`C. Analysis of Claims 4, 5, 10, 12, and 13 ........................................................107
`1. Claim 8 ......................................................................................................107
`2. Claim 9 ......................................................................................................109
`3. Claim 17 ....................................................................................................111
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`I, Hamid Toliyat, of College Station, Texas, declare as follows:
`
`I.
`
`1.
`
`INTRODUCTION
`
`I have been retained by Beck Redden LLP on behalf of Patent Owner Gwee
`
`Global Products, Inc. (“Gwee”) as an independent expert in the above referenced
`
`Inter Partes Review proceeding.
`
`2.
`
`I have been asked by counsel for Gwee to address the issues raised in the
`
`IPR Petition, including issues raised in its Exhibit 1003, the Declaration of Dr.
`
`Jeremy Cooperstock, including whether the references relied upon by Dr.
`
`Cooperstock teach or suggest the claim limitations of Claims 1, 2, 4-10, 12, 14-17
`
`and 19 of the challenged patent, U.S. Patent No. 10,259,021 (the “‘021 patent”).
`
`3. My opinions, which are based upon my education, experience and review
`
`the materials filed in this proceeding and otherwise cited herein, and the bases for
`
`those opinions are set forth herein.
`
`4.
`
`In writing this Declaration, I have considered matters including my own
`
`knowledge and experience, including my teaching and work experience. Although
`
`my qualifications exceed those of a POSITA for the challenged ‘021 patent, my
`
`statements and opinions expressed herein are so expressed from the perspective of
`
`a POSITA.
`
`5.
`
`I have no financial interest in either party or in the outcome of this
`
`proceeding. I am being compensated for my time spent on this matter on an hourly
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`basis. My compensation is not dependent on the outcome of these proceedings or
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`the content of my opinions.
`
`II. QUALIFICATIONS
`
`6. My background and qualifications are set forth in my curriculum vitae
`
`attached as Exhibit 2023. In summary,
`
`7.
`
`I have over 35 years of experience in the field of power electronics,
`
`microcontrollers, electric motors, motor control, and wireless power transfer.
`
`8.
`
`I received my B.S. from Sharif University of Technology in 1982, M.S.
`
`degree from West Virginia University in 1986, and Ph.D. degree from the
`
`University of Wisconsin-Madison in 1991, all in electrical engineering.
`
`9.
`
`In March 1994 I joined the Department of Electrical and Computer
`
`Engineering at Texas A&M University. I am currently the Raytheon endowed
`
`professor of electrical engineering.
`
`10.
`
`I received the Nikola Tesla Field Award for “outstanding contributions to
`
`the design, analysis and control of fault-tolerant multiphase electric machines”
`
`from IEEE in 2014, the Cyril Veinott Award in Electromechanical Energy
`
`Conversion from the IEEE Power Engineering Society in 2004, Patent and
`
`Innovation Award from Texas A&M University System Office of Technology
`
`Commercialization’s in 2020, 2016 and 2007, TEES Faculty Fellow Award in
`
`2006, Distinguished Teaching Award in 2003, E.D. Brockett Professorship Award
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`in 2002, Eugene Webb Faculty Fellow Award in 2000, and Texas A&M Select
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`Young Investigator Award in 1999. I also received the Space Act Award from
`
`NASA in 1999, and the Schlumberger Foundation Technical Awards in 2001 and
`
`2000.
`
`11.
`
`I was an Editor of IEEE Transactions on Energy Conversion. I also was
`
`Chair of the IEEE-IAS Industrial Power Conversion Systems Department of IEEE-
`
`IAS, and am a member of Sigma Xi. I am a fellow of the IEEE, the recipient of
`
`the 2008 Industrial Electronics Society Electric Machines Committee Second Best
`
`Paper Award as well as the recipient of the IEEE Power Engineering Society Prize
`
`Paper Awards in 1996 and 2006, and IEEE Industry Applications Society
`
`Transactions Third Prize Paper Award and Second Prize Paper Award in 2006 and
`
`2016, respectively. I was the General Chair of the 2005 IEEE International
`
`Electric Machines and Drives Conference in San Antonio, Texas.
`
`12. My main research interests and experience include power electronics,
`
`microcontrollers, analysis and design of electrical machines, variable speed drives
`
`for traction and propulsion applications, fault diagnosis of electric machinery, and
`
`sensorless variable speed drives.
`
`13.
`
`I have supervised more than 120 graduate students, post docs, and research
`
`engineers. I have published over 520 technical papers, presented more than 99
`
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`invited lectures all over the world, and has 34 issued and pending U.S. patents. My
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`publications are highly cited by colleagues -- more than 27,000 times.
`
`14.
`
`I have purposely taught courses in two different areas within my department:
`
`power electronics, and electric machinery. I have developed and taught three new
`
`courses in the area of electromechanical motion devices. These are:
`
`• ECEN 611 General Theory of Electromechanical Motion Devices, 3 credits
`
`• ECEN 612 Computer Aided Design of Electromechanical Motion Devices, 4
`
`credits
`
`• ECEN 442/742 DSP-Based Electromechanical Motion Control, 3 credits
`
`15.
`
`I am also a Professional Engineer in the State of Texas.
`
`III. MATERIALS CONSIDERED
`
`16.
`
`In writing this Declaration, I have considered matters including my own
`
`knowledge and experience, including my teaching and work experience, which
`
`includes overseeing POSITAs and persons studying to become POSITAs. I have
`
`reviewed Petitioner Apple’s IPR Petition and the substantive Exhibits thereto,
`
`namely Exhibits APPLE-1001 – APPLE 1003; APPLE-1005 – APPLE-1068; as
`
`well as Gwee’s Preliminary Response to Apple’s IPR Petition and the substantive
`
`Exhibits thereto, namely GUI EXHIBIT 2001 and GUI EXHIBIT 2003 – GUI
`
`EXHIBIT 2017, and also the PTAB’s Institution Decision. I have also reviewed
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`the declaration of Dr. Mark Horenstein submitted in the IPR proceeding involving
`
`Samsung’s challenge to this patent. I have also reviewed the transcript from Dr.
`
`Cooperstock’s deposition. I have also reviewed the Board’s institution decision
`
`relative to the challenged patent. I have also had conversations with Mr. Walter
`
`Mayfield. one of the named inventors of the challenged patent. I have also
`
`considered other materials noted herein, namely:
`
`Exhibit 2024
`
`YouTube video of Powermat bearing a date of December 28,
`
`2020 and accessible at
`
`https://www.youtube.com/watch?v=_SyU_eKd3pE.
`
`Exhibit 2025
`
` YouTube video of Powermat bearing a date of November 29,
`
`2010 and accessible at
`
`https://www.youtube.com/watch?v=aLOYN6SgbFQ.
`
`Exhibit 2026
`
` YouTube video of Palm Touchstone bearing a date of July 11,
`
`2011 and accessible at
`
`https://www.youtube.com/watch?v=wCyyJTszxH8.
`
`Exhibit 2027
`
`Wireless Power Consortium site on the Wayback Machine at
`
`https://web.archive.org/web/20110715210021/http://www.wireles
`
`spowerconsortium.com/technology/coupling-factor.html
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`Exhibit 2028
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`Li and Mi, WPT for EV Applications, IEEE Journal of Emerging
`
`and Selected Topics in Power Electronics, Vol. 3, No. 1.
`
`Exhibit 2029
`
`Wireless Power Consortium site on the Wayback Machine at
`
`https://web.archive.org/web/20110729035955/http://www.wireles
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`spowerconsortium.com/member-list.
`
`Exhibit 2030
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`Wireless Power Consortium site on the Wayback Machine at
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`https://web.archive.org/web/20110821093859/http://www.wireles
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`spowerconsortium.com/about/our-vision.html
`
`Exhibit 2031
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`Wireless Power Consortium site on the Wayback Machine at
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`https://web.archive.org/web/20110822142011/http://www.wireles
`
`spowerconsortium.com/technology/total-energy-
`
`consumption.html
`
`Exhibit 2032
`
`An introduction to the Wireless Power Consortium standard and
`
`TI’s compliant solutions” from the 1Q 2011 Texas Instruments
`
`Analog Applications Journal
`
`Exhibit 2033
`
`H. Shen, J. Lee and T. Chang, "Study of contactless inductive
`
`charging platform with core array structure for portable
`
`products," 2011 International Conference on Consumer
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`Electronics, Communications and Networks, 2011
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`2034
`
`Measuring Wireless Charging Efficiency In the Real World”
`
`from
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`https://www.wirelesspowerconsortium.com/data/downloadables/1
`
`/4/8/1/measuring-wireless-charging-efficiency-in-the-real-world-
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`wpc-michigan-sept-2015.pdf
`
`
`
`17. The Cooperstock Declaration notes that the challenged patent was filed on
`
`November 27, 2019 with a priority claim dating back to the August 5, 2011 filing
`
`date of provisional application No. 61/515,752. For purposes of his Declaration,
`
`Dr. Cooperstock uses August 5, 2011 as the priority date for the patent and as the
`
`assumed date of invention. I am thus using August 5, 2011 as the priority date for
`
`the patent and the date of invention as well.
`
`18. As part of my independent analysis, I have considered my personal
`
`knowledge and experience; the knowledge of persons of ordinary skill
`
`(“POSITA”) as of the invention date. My opinions are from the viewpoint of
`
`POSITA. Unless otherwise stated, my testimony herein refers to the knowledge
`
`and capabilities of a POSITA as of this invention date.
`
`19.
`
`In this declaration I only address some of the statements, arguments, and
`
`contentions of Apple and Dr. Cooperstock, and I only address some of the
`
`challenged claim elements. This is being done primarily to focus on what appear
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`to be the main disputed issues. It should not be assumed that I agree with anything
`
`not specifically addressed in this Declaration.
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`IV. SUMMARY OF CONCLUSIONS
`
`20. This Declaration states and explains the opinions/conclusions that I have
`
`formed using my independent analysis. They are summarized as follows:
`
`• Ground 1A: Claims 1, 4-7, 10, 14-16 and 19 are not obvious in view of
`
`Gundlach and Le.
`
`• Ground 1B: Claims 4 and 14 are not obvious in view of Gundlach, Lee, and
`
`Nishikawa.
`
`• Ground 1C: Claim 10 is not obvious in view of Gundlach, Lee, and Rosener.
`
`• Ground 1D: Claims 2 and 12 are not obvious in view of Gundlach, Lee, and
`
`Brown.
`
`• Ground 1E: Claims 8, 9 and 17 are not obvious in view of Gundlach, Lee,
`
`and Mak-Fan.
`
`LEGAL PRINCIPLES
`
`I am not an attorney and have not been asked to offer any opinions on the
`
`V.
`
`21.
`
`law. I understand, however, that I must follow existing law and that I am offering
`
`opinions on the ultimate issue of obviousness. I have been provided with
`
`information about legal principles by counsel for Gwee, specifically as follows:
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`22.
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`I have been informed by counsel and understand that in an Inter Partes
`
`Review proceeding, the party challenging the patent’s validity must prove by a
`
`preponderance of the evidence that the patent claims are unpatentable. I have been
`
`further advised that the first step in assessing validity of a patent claim is to
`
`properly construe the claim at issue.
`
`23.
`
`I have been informed by counsel and understand that Apple’s challenges to
`
`the patentability of the claims of the ‘021 Patent are ultimately based on
`
`obviousness under 35 U.S.C. § 103. To be patentable under this statute, an
`
`invention much be such that it would not have been obvious to a person of ordinary
`
`skill in the art (“POSITA”) at the time the invention was made. That is, the
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`differences between the subject matter sought to be patented and the prior art must
`
`not be such that the claimed subject matter as a whole would have been obvious to
`
`a POSITA at the time the invention was made.
`
`24.
`
`I have been informed by counsel and understand that when determining
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`whether a claimed invention is obvious, one should consider the scope and content
`
`of the prior art, the level of ordinary skill in the relevant art, the differences
`
`between the claimed invention and the prior art, and whether the claimed invention
`
`would have been obvious to one of ordinary skill in the art in light of those
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`differences. I understand that hindsight must not be used when comparing the prior
`
`art to the invention for obviousness.
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`25.
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`I have been informed by counsel and understand that the scope of the prior
`
`art includes analogous art, and that two separate tests define the scope of analogous
`
`prior art: (1) whether the art is from the same field of endeavor, regardless of the
`
`problem addressed and, (2) if the reference is not within the field of the inventor's
`
`endeavor, whether the reference still is reasonably pertinent to the particular
`
`problem with which the inventor is involved.
`
`26.
`
`I have been informed by counsel and understand that obviousness may be
`
`shown by demonstrating that it would have been obvious to modify what is taught
`
`in a single reference to arrive at the patented invention, and/or by showing that it
`
`would have been obvious to combine the teachings of more than one reference to
`
`arrive at the patented invention. I recognize that in determining whether prior art
`
`references would have been combined with one another and/or with other
`
`information within the knowledge of one of ordinary skill in the art, multiple
`
`approaches and rationales may be considered, including:
`
`• Combining prior art elements according to known methods to yield
`
`predictable results;
`
`• Simple substitution of one known element for another to obtain predictable
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`results;
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`• Use of a known technique to improve similar devices, methods, or products
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`in the same way;
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`• Applying a known technique to a known device, method, or product ready
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`for improvement to yield predictable results;
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`• Applying a technique or approach that would have been “obvious to try”
`
`(choosing from a finite number of identified, predictable solutions, with a
`
`reasonable expectation of success);
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`• Known work in one field of endeavor that may prompt variations of it for
`
`use in either the same field or a different one based on design incentives or
`
`other market forces if the variations would have been predictable to one of
`
`ordinary skill in the art; or
`
`• Some teaching, suggestion, or motivation in the prior art that would have led
`
`one of ordinary skill to modify the prior art reference or to combine prior art
`
`reference teachings to arrive at the claimed invention.
`
`27.
`
`I have been informed by counsel and understand that if an independent claim
`
`is not obvious over a combination of references, then a claim that depends from the
`
`nonobvious independent claim is likewise not obvious in view of those references,
`
`because the dependent claim contains all of the limitations of the independent
`
`claim plus one or more further limitations.
`
`28.
`
`In considering the question of obviousness, I have been informed by counsel
`
`and understand that the POSITA is a hypothetical person who is presumed to be
`
`aware of all of the pertinent prior art. The POSITA is not an automaton and may be
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`able to combine the teachings of multiple patents or references employing ordinary
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`creativity and common sense, and that familiar items may have obvious uses in
`
`another context or beyond their primary purposes. The POSITA faced with a
`
`problem is able to apply his or her experience and ability to solve the problem and
`
`also look to any available prior art to help solve the problem. I also recognize that
`
`it is not necessary to demonstrate a precise teaching directed to the specific subject
`
`matter of the challenged claim, for a fact finder can take account of the inferences
`
`and creative steps that a POSITA would employ. A patent that merely claims
`
`predictable uses of old elements according to their established functions to achieve
`
`predictable results may be found invalid as obvious. Hence, an invention may be
`
`obvious if a POSITA, facing the wide range of needs created by developments in
`
`the field, would have seen an obvious benefit to the solutions tried by the
`
`applicant. And, when there is a design need or market pressure to solve a problem,
`
`and there are a finite number of identified, predictable solutions, it may have been
`
`obvious to a POSITA to try the known options. Also, if a technique has been used
`
`to improve one device, and a POSITA would have recognized that it would
`
`improve similar devices in the same way, using the technique may have been
`
`obvious.
`
`VI. PERSON OF ORDINARY SKILL IN THE ART
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`29. Dr. Cooperstock’s Declaration opines that a POSITA would have had would
`
`have had at least a bachelor’s degree in an academic area emphasizing electrical
`
`engineering, mechanical engineering, or a similar discipline, and at least two years
`
`of experience in the field working with electronic devices. He also opines that
`
`superior education could compensate for a deficiency in work experience, and
`
`vice-versa.
`
`30.
`
`I note that the use of the phrase “at least” in Dr. Cooperstock’s definition of
`
`a POSITA leaves the actual educational and other experience of a POSITA in
`
`doubt because it encompasses someone of greater education, training, and skill
`
`than a POSITA and could even include an expert in the field. As such, Dr.
`
`Cooperstock’s definition of a POSITA is of questionable assistance in
`
`understanding the true qualifications of the POSITA and how such a person would
`
`understand and employ the teachings of the various references cited in the petition.
`
`31.
`
`I concur with and adopt as my own the opinion previously expressed by Dr.
`
`Horenstein (in the declaration noted above) that, for purposes of evaluating claims
`
`of the challenged patent, a POSITA would have been someone having either a
`
`bachelor’s degree in electrical engineering, computer science, or mechanical
`
`engineering with some level of post-baccalaureate electronic device or system
`
`design experience, or someone with an equivalent level of experience and training
`
`through other means.
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`32.
`
`I agree with Dr. Cooperstock that superior education might be able to
`
`compensate for a deficiency in work experience, and vice-versa.
`
`33. Dr. Cooperstock’s definition of a POSITA is somewhat different than mine;
`
`however, my opinions in this declaration would be the same regardless of whether
`
`or not my description or Dr. Cooperstock’s description of a POSITA is used.
`
`VII. CLAIM CONSTRUCTION
`
`34.
`
`I do not see any expressed indication in Dr. Cooperstock’s Declaration of
`
`any constructions for any claim terms. To the extent that Dr. Cooperstock has
`
`implied constructions in his Declaration, they are addressed herein where relevant.
`
`From the point of view of a POSITA, and based upon my review of the materials
`
`noted herein, primarily the challenged patent and its prosecution history, I also
`
`assigned the claim terms their plain and ordinary meanings as a POSITA would
`
`have understood them in the context of the ‘021 patent, unless otherwise noted
`
`herein.
`
`VIII. OVERVIEW OF THE ‘021 PATENT
`
`35. Gwee has already provided a relatively brief and straightforward overview
`
`of the challenged patent in its preliminary response, which I concur with and adopt
`
`as my own, including as follows:
`
`36. The ‘021 Patent is entitled “APPARATUS FOR CLEANING VIEW
`
`SCREENS AND LENSES AND METHOD FOR THE USE THEREOF.” The
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`presumed invention date is noted above, and the patent issued on April 16, 2019.
`
`Independent claim 1 covers the following (with the elements labeled as designated
`
`by Dr. Cooperstock):
`
`[1pre] A system comprising:
`
`[1a] a portable switching device coupled to a portable electronic device;
`
`[1b] wherein: the switching device and the electronic device are configured
`
`to selectively couple to each other employing magnetic force;
`
`[1c]
`
`the switching device comprises a first case;
`
`[1d]
`
`the electronic device comprises a second case and an electronic circuit
`
`that is responsive to the switching device;
`
`[1e] a first magnet is fully disposed within the electronic device;
`
`[1f]
`
`the electronic device comprises at least one element selected from the
`
`group consisting of beveled edges, ridges, recessed areas, grooves, slots,
`
`indented shapes, bumps, raised shapes, and combinations thereof;
`
`configured to correspond to complimentary surface elements on the
`
`switching device;
`
`[1g]
`
`the portable switching device is configured to activate, deactivate, or
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`send into hibernation the portable electronic device; and
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`[1h] when coupled, the first case functions to protect the second case.
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`15
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`IPR2021-00471
`GUI Ex. 2022
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`37. There are exemplary portable magnetic switching devices in FIGs. 1-26 of
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`the ‘021 patent. The disclosed switching devices have functions such as activating,
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`deactivating and hibernating electronic devices such as cell phones, smartphones,
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`tablet computers and laptop computers. For example, the switching device 2401
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`shown in FIGs. 24 and 25, reproduced below, includes magnets 2504 to activate,
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`deactivate, or hibernate a tablet computer 2400. Ex. 1001 at 18:5-9.
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`
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`38. Another example of a switching device is the doll-shaped device shown in
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`FIG. 26, reproduced above, which is disclosed as a switching device for a version
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`of the iPadTM. Id., 5:53-55.
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`39. Aspects of disclosed embodiments of the invention comprise a switching
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`device selectively coupled to the front of a portable electronic device. Id., 18:7-11
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`16
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`IPR2021-00471
`GUI Ex. 2022
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`(“switching device (2401) is selectively coupled to the front of the portable
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`electronic device 2402 outside of the view screen 2403.”). The switching device
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`may have a magnet element to activate or deactivate a magnetic switch. Id., 3:1-3,
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`and see Figs 1A, 1B (illustrating a round switching device 100 having magnet
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`102); FIGs. 2A-2C (showing a square switching device 200 having magnet 202);
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`FIG. 3 (showing a switching device 303 comprising a magnetic substrate); FIG. 4
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`(showing a switching device 402 with a magnet); and FIGs. 5A, 5B (showing a
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`switching device 503/503a with magnets 506).
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`40. Aspects of disclosed embodiments of the invention further comprise a case
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`for an electronic device having a magnetic switch, and in the area of the case over
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`the magnetic switch, a recessed area functions to facilitate a switching device
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`having a magnet moving past the switch in order to activate or deactivate the
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`switch. Id., 3:15-20. Examples of depicted recesses include indention 302 in FIG.
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`3, and recess 904 in FIG. 9, each reproduced below. Id., 8:58-64; 11:40-51.
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`
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`17
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`IPR2021-00471
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`41.
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`
`
`42. Aspects of disclosed embodiments of the invention further comprise
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`switching devices with beveled edges, id., 8:29-34; 18:63-67, and switching
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`devices that may be received into a groove, slot, or other indented geometrical
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`shape to lower the profile of the switching device to facilitate closing a cover or
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`prevent snagging a cleaning component. Id., 8:51-55; 19:9-16.
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`43. Aspects of disclosed embodiments of the invention further comprise a
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`switching device that includes at least one ferromagnetic or ferrimagnetic material
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`within, it wherein the ferromagnetic or ferrimagnetic material may function to
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`actuate a power switch or sensor that is capable of being actuated using a magnet.
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`Id., 3:54-60; 16:15-20.
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`18
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`IPR2021-00471
`GUI Ex. 2022
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`44. Aspects of disclosed embodiments of the invention further comprise a
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`switching device that activates or deactivates an electronic device by employing a
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`magnet, the switching device having a body surrounding the magnet and at least
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`one surface non-abrasive to the electronic device. Id., 4:8-18.
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`45. Aspects of disclosed embodiments of the invention further comprise
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`methods of conserving power when using a portable electronic device having a
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`view screen and a switch that can activated or de-activated by introducing a
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`magnetic field, wherein the switching device has at least one magnet and at least
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`one surface that is non-abrasive to the surface of the view screen, wherein the
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`method includes using the switching device to turn the portable electronic device
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`off when the portable electronic device is not in actual use and then on when the
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`portable electronic device is needed. Id., 4:4-11.
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`46. Aspects of disclosed embodiments of the invention further comprise a
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`switching device putting a tablet into hibernation mode with a single touch to the
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`switching device as compared to the multiple touches required to do the same thing
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`using the touch pad of the tablet. Id., 4:12-24.
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`47. Aspects of disclosed embodiments of the invention further comprise a case
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`for an electronic device having a magnetic switch, and in the area of the case over
`
`the magnetic switch, a recessed area (see above regarding recesses) that facilitates
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`19
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`Apple v. GUI Global Products
`IPR2021-00471
`GUI Ex. 2022
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`

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`a cleaning component having a magnet moving past the switch in order to activate
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`or deactivate the switch. Id., 3:15-21.
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`48. Aspects of disclosed embodiments of the invention further comprise the case
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`of the switching device functioning to protect an electronic device's primary case.
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`See, e.g., id., 2:42-43; and FIG. 5A, reproduced below.
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`
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`
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`IX. GROUND 1A—Claims 1, 4-7, 10, 14-16 and 19 are not obvious in view
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`of Gundlach and Lee.
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`A. Overview of Gundlach
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`49. Gundlach is a U.S. pate