Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`In re Patent of: Walter G. Mayfield, et al.
`U.S. Patent No.:
`10,562,077 Attorney Docket No.: 50095-0030IP1
`Issue Date:
`February 18, 2020
`
`Appl. Serial No.: 16/460,770
`
`Filing Date:
`July 2, 2019
`
`Title:
`SYSTEM COMPRISING A PORTABLE SWITCHING
`DEVICE FOR USE WITH A PORTABLE ELECTRONIC
`DEVICE
`
`
`
`
`
`
`SUPPLEMENTAL DECLARATION OF DR. JEREMY COOPERSTOCK
`
`
`
`
`
`
`APPLE 1089
`Apple v. GUI
`IPR2021-00472
`
`1
`
`
`IPR of U.S. Patent No. 10,562,077
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`In re Patent of: Walter G. Mayfield, et al.
`U.S. Patent No.:
`10,562,077 Attorney Docket No.: 50095-0030IP1
`Issue Date:
`February 18, 2020
`
`Appl. Serial No.: 16/460,770
`
`Filing Date:
`July 2, 2019
`
`Title:
`SYSTEM COMPRISING A PORTABLE SWITCHING
`DEVICE FOR USE WITH A PORTABLE ELECTRONIC
`DEVICE
`
`
`
`
`
`
`SUPPLEMENTAL DECLARATION OF DR. JEREMY COOPERSTOCK
`
`
`
`
`
`
`APPLE 1089
`Apple v. GUI
`IPR2021-00472
`
`1
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`TABLE OF CONTENTS
`
`
`
`I.
`
`INTRODUCTION .......................................................................................... 3
`
`II.
`
`PERSON OF ORDINARY SKILL IN THE ART .......................................... 4
`
`III. TECHNICAL DISCUSSION ......................................................................... 4
`
`A.
`
`B.
`
`Lee’s teachings would have motivated a POSITA to pursue the
`Gundlach-Lee combination................................................................... 5
`
`The technologies of Gundlach and Lee were well known, and the
`result of combining them was predictable to a POSITA. ..................... 7
`
`C.
`
`The benefits of inductive charging were known to a POSITA. .......... 19
`
`D. A POSITA would have viewed Lee’s single, dual-purpose coil
`design as feasible in the context of Gundlach..................................... 23
`
`E.
`
`interoperability
`the
`A POSITA would have appreciated
`advantage of the Gundlach-Lee combination. .................................... 37
`
`IV. CONCLUSION ............................................................................................. 39
`
`
`
`
`
`
`
`2
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`I, Jeremy Cooperstock, of Montreal, Canada, declare that:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Fish & Richardson, P.C., on behalf of Apple
`
`Inc. (“Petitioner”), as an independent expert consultant in this inter partes review
`
`(“IPR”) proceeding before the United States Patent and Trademark Office (“PTO”).
`
`2.
`
`I understand that this declaration will be submitted in support of
`
`Petitioner’s Reply to Patent Owner’s Response to the Petition for inter partes review
`
`of the ’077 Patent (U.S. Patent No. 10,562,077). This declaration supplements, and
`
`is intended to be read in conjunction with, my declaration in support of Apple’s
`
`Petition (APPLE-1003, “my First Declaration”). In my First Declaration, I address
`
`many topics, including (but not limited to) my background and qualifications, the
`
`level of skill in art, an overview of the ’077 Patent, claim construction, certain legal
`
`standards explained to me by Apple’s counsel, and a detailed analysis of the prior
`
`art against the ’077 Patent’s claims. The opinions and explanations expressed in my
`
`First Declaration apply equally here.
`
`3.
`
`In writing this Supplemental Declaration, I have considered the
`
`following: my own knowledge and experience, including my teaching and work
`
`experience in the field; and my experience of working with others involved in the
`
`field.
`
`
`
`
`
`3
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`I have no financial interest in either party or in the outcome of this
`
`4.
`
`proceeding. I am being compensated for my work as an expert on an hourly basis,
`
`for all tasks involved. My compensation is not dependent on the outcome of these
`
`proceedings or on the content of my opinions.
`
`II.
`
`PERSON OF ORDINARY SKILL IN THE ART
`
`5.
`
`Based on my knowledge and experience in the field and my review of
`
`the ’077 Patent and its file history, I believe that 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. Superior education could compensate
`
`for a deficiency in work experience, and vice-versa. I understand that Patent Owner
`
`and its expert, Dr. Toliyat, propose that the POSITA would have post-baccalaureate
`
`electronic device or system design experience. I agree.
`
`III. TECHNICAL DISCUSSION
`
`6.
`
`The analysis and opinions expressed in my First Declaration fully
`
`explain why each and every feature of the’077 Patent’s claims is provided in the
`
`prior art. I understand that Patent Owner and Dr. Toliyat have considered my
`
`opinions and offered their own, some of which are inconsistent with my view. I will
`
`address some of those points below. The fact that I have not addressed all of Patent
`
`Owner and Dr. Toliyat’s opinions should not be interpreted as agreement with them.
`
`
`
`4
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`A. Lee’s teachings would have motivated a POSITA to pursue
`the Gundlach-Lee combination.
`
`7.
`
`As explained in my First Declaration, Lee sought improvements
`
`relating to energy transfer and battery charging for wireless headsets. (Lee, 3:21-
`
`22; see also id., 1:14-29.)
`
`8. With reference to Figure 2, Lee describes an exemplary prior headset
`
`design using a USB power cable to charge a wireless headset conductively. (Lee,
`
`1:39-46.) Lee then reasons that “[a]s improvements of technology become available,
`
`there is an opportunity for further reduction of size and weight of wireless
`
`headphone/headsets” attributed to “the necessity of connectors” like the above-
`
`described USB plugs/sockets. (Id., 1:62-2:2.) Likewise, Lee recognized that such
`
`conductive connectors increase both “end user complexity” and “the risk of failure .
`
`. . caused by fatigue and corrosion of contact elements.” (Id.) Thus, Lee concluded
`
`that “[w]hat is needed in the art is a mechanism to re-charge batteries in wireless
`
`headphones/headsets in order to minimize size and weight, maximize reliability, and
`
`improve end user experience.” (Id., 3:17-20.)
`
`9.
`
`Lee’s solution to the above-discussed challenges with conductive
`
`charging for wireless headsets is to implement inductive charging. Lee describes
`
`several embodiments to this effect. (See generally Lee, 3:32-7:36, Figures 5-24.)
`
`Accordingly, a POSITA reading the disclosure would have noted Lee’s express
`
`
`
`5
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`teaching to modify wireless headsets employing older conductive charging
`
`technology by employing newer inductive charging technology. (Id., 1:14-2:2, 3:15-
`
`6:4). The picture Lee painted would have prompted a POSITA to pursue design
`
`options that employ inductive charging technology to substitute for the existing
`
`conductive charging architecture in Gundlach’s embodiments. Indeed, the fact that
`
`Lee describes an analog to Gundlach as prior art—i.e., conductive charging via USB
`
`connections—supports my understanding that Lee’s teachings would have led the
`
`POSITA to the Gundlach-Lee combination. In short, the POSITA would have
`
`arrived at the Gundlach-Lee combination by simply following the guidance provided
`
`in Lee.
`
`Lee’s Depiction of a USB Conductive
`Charging Prior Art Embodiment
`
`Gundlach’s Depiction of a USB
`Conductive Charging Embodiment
`
`
`
`
`
`
`
`
`
`
`
`
`
`6
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`The technologies of Gundlach and Lee were well known, and
`the result of combining them was predictable to a POSITA.
`
`B.
`
`10. Wireless Headsets: In my First Declaration, I cited several prior art
`
`documents that demonstrate the conventional nature of wireless headsets. For one,
`
`Gundlach and Lee both include explanations of the prior art that support this
`
`conclusion. (E.g., Gundlach, [0005] (“Many operated wireless headsets (with
`
`rechargeable batteries) . . .”); Lee, 1:14-61 (“For added convenience, wireless
`
`headphones/headsets are available. For example, Bluetooth headsets are available
`
`for telephone conversations as well as headphones for audio listening. Because the
`
`headphones/headsets are wireless, they are required to provide their own power
`
`source, typically a battery[.]”).) The table below summarizes the additional
`
`documents I cited on the subject of wireless headsets.
`
`Document
`APPLE-1023—U.S. Pat. No.
`7,211,986
`
`Description
`APPLE-1023 explains that “[w]ireless
`headsets and other portable
`communications devices are often battery
`powered such that a user can use the
`wireless headset or other such device
`without being directly connected to [a]
`larger power source such as an a/c outlet
`or automobile battery. This allows
`wireless headset users flexibility and
`convenience to move about without being
`tied to a power cord. Wireless headset
`batteries are generally rechargeable so that
`the batteries can be recharged and need
`not be discarded after use.” (1:10-19.)
`
`
`
`
`7
`
`
`
`APPLE-1024—U.S. Publication. No.
`2008/0085617
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`APPLE-1023 also describes as its solution
`“an inventive inductive battery charger”
`(3:25-29) for use with wireless headsets
`(5:1-4).
`APPLE-1024 describes a charging system
`that “allows for the compact wall
`mounting of an electronic device, such as
`a wireless headset, while being charged.”
`([0022]; see also [0004-0008].)
`
`
`APPLE-1027—U.S. Publication No.
`2008/0152182
`
`
`
`APPLE-1027 describes various
`embodiments involving wireless headsets
`with replaceable earpieces. ([0027];
`[0043]; see also [0003-0010].)
`
`
`
`
`
`
`
`
`8
`
`
`
`APPLE-1029—U.S. Pat. No.
`7,627,289
`
`APPLE-1035—U.S. Publication No.
`2006/0166715
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`In APPLE-1029, “[t]he system generally
`includes a first headset component and a
`second headset component. Both the first
`headset component and the second headset
`component may be wireless devices.”
`(Abstract.)
`
`APPLE-1029 further describes
`embodiments with a multi-purpose coil so
`that “[t]he earbud advantageously does not
`require charging contacts on its small
`exterior surface.” (8:35-46.) The coil
`“functions multiply to receive charging
`power for [the] battery, generate a wake
`up signal, or receive an audio signal
`carrier.” (Id.)
`
`
`
`In APPLE-1035,
`“FIG. 1 is a diagram
`of a modular wireless
`headset 10 wirelessly
`coupled to base unit
`16 that includes
`wireless earpiece 12
`and wireless
`microphone 14.”
`([0024].)
`
`
`
`
`
`
`9
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`APPLE-1036 describes a wireless
`“accessory” device, such as a wireless
`headset, designed to “manipulate media
`playback controls. ([0038]; see also id.,
`[0029].)
`APPLE-1038 and APPLE-1039 show
`commercialized wireless headsets.
`
`APPLE-1036—U.S. Publication No.
`2008/0070501
`
`APPLE-1038 Voyager 855 Bluetooth
`Headset—User Guide, Plantronics
`Sound Innovation
`
`APPLE-1039 Jabra Sport—User
`Manual, Jabra
`
`APPLE-1046 U.S. Publication No.
`2007/0135185
`
`
`
`
`APPLE-1046 describes a flip-phone with a
`camera, where the flip-phone functions as
`a charging case for a wireless headset.
`(Abstract, [0005-0007], [0018-0019],
`[0026].)
`
`
`APPLE-1047—U.S. Pat. No.
`7,130,654
`
`
`
`APPLE-1047 (Figure 8) and APPLE-1048
`(Figure 1) show examples of wireless
`headsets charged in the storage
`compartment of a cellular phone.
`
`
`
`10
`
`
`
`APPLE-1048—U.S. Publication No.
`2008/0132168
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`
`
`
`
`APPLE-1050 U.S. Publication No.
`2008/0076489
`
`
`In APPLE-1050, “FIG. 5 is an illustration
`of a user 500 wearing a wireless headset
`comprising first and second wireless
`earphones 502, 504, in accordance with an
`embodiment of the present invention.”
`([0030].)
`
`
`
`
`
`
`11
`
`
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`APPLE-1068 describes a wireless headset
`with two Bluetooth earpieces. (Abstract,
`[0002-0004], Figures 1, 4-7.)
`
`
`
`
`
`
`11.
`
`Inductive Charging: The principles of inductive charging were
`
`discovered in the 19th century by Nikola Tesla. These century-old principles were
`
`well understood and practiced in many different applications decades before the ’077
`
`Patent. As illustrated below, patent literature from the 1970s and 1980s shows that
`
`inductive charging technology was applied as a substitute for conductive charging
`
`in small handheld electronic devices like toothbrushes, hearing aids, and watches.
`
`US 3,840,795 Hand Held Battery Operated Device and Charging Means Therefor
`(Filed Jan. 21, 1970) APPLE-1069
`
`
`
`
`
`12
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`US 4,379,988 Molded Hearing Aid and Battery Charger
`(Filed Jan. 19, 1981) APPLE-1070
`
`US 4,873,677 Charging Apparatus For an Electronic Device
`(Filed Jul. 7, 1988) APPLE-1071
`
`
`
`12.
`
`In addition to the example above, the prior art patent literature was
`
`replete with inductively charged hearing aids. The documents listed in the table
`
`
`
`below are illustrative.
`
`Pat./Pub. No.
`
`US 4,379,988
`(APPLE-1080)
`
`Jan. 19, 1981
`
`Filing Date Exemplary
`Citations
`1:39-55,
`2:21-37,
`4:39-50,
`5:13-26
`
`Exemplary Quotes
`
`“It is still another object of the
`invention to provide a charging
`system for a self-contained
`rechargeable battery in a miniature
`hearing aid having an oscillator
`
`
`
`13
`
`
`
`US 6,310,960
`(APPLE-1072)
`
`Oct. 7, 1999
`
`Abstract,
`1:7-11, 4:2-
`22, 14:18-
`39
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`which can be coupled to an inductor
`disposed within the hearing aid to
`transfer energy thereto.” (2:21-26.)
`
`“[T]he coupling between the
`charging unit and the hearing aid is
`purely inductive, [so] no trouble
`will be experienced in poor or
`broken connections as in prior art
`units.” (5:23-26.)
`“A contactless rechargeable hearing
`aid system in which a rechargeable
`hearing aid may be … inductively
`recharged by … an inductive
`recharger.” (Abstract.)
`
`“Accordingly, the rechargeable
`hearing aid system of the present
`invention may comprise an
`inductive charger that may be
`inductively coupled to an
`inductively rechargeable hearing aid
`having a rechargeable battery;
`wherein energy may be transferred
`from the charger to the hearing aid
`by the use of inductive transfer,
`rather than by the use of electrical
`contacts.” (4:2-8.)
`“A rechargeable hearing aid
`eliminates the requirement for
`frequency replacement of a
`disposable hearing aid battery. The
`rechargeable hearing aid features
`inductive charging using a charging
`reservoir.” (Abstract.)
`
`“a rechargeable hearing aid that is
`recharged by placing the hearing aid
`in an inductive charging reservoir.
`
`US 6,658,124
`(APPLE-1073)
`
`Mar. 16, 2001 Abstract,
`1:8-14,
`2:37-3:22
`
`
`
`14
`
`
`
`US 6,661,197
`(APPLE-1074)
`
`US 2008/0205678
`(APPLE-1075)
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`Power for recharging the hearing
`aid battery is provided through
`inductive coupling of a primary coil
`in a charging reservoir and a
`secondary coil in the hearing aid.”
`(2:25-30.)
`“[T]he battery is actively charged
`by means of an inductor circuit …
`The hearing aid may simply be
`placed within the charger housing
`(or cradle) to charge the battery. No
`electrical connection by either wires
`or electrical contacts is needed to
`recharge the batter, which is located
`inside the hearing aid housing.”
`(Abstract.)
`
`“[T]he present invention is directed
`toward a hearing aid battery with a
`built-in inductive charging coil for
`recharging the hearing aid battery in
`situ.” (1:19-21.)
`“An inductive charging device 19 is
`shown in FIG. 2 physically
`separated from the hearing device.
`This inductive charging device 19
`generates a magnetic alternating
`field … [that] can induce a current.
`This current can be used to charge
`the battery 17 [of a hearing device]
`with the aid of a charging circuit.”
`([0032].)
`
`Sep. 27, 2002 Abstract,
`1:19-21,
`2:19-20,
`3:33-55,
`Fig. 4
`
`Feb. 26, 2008 Abstract,
`[0006],
`[0007],
`[0032],
`[0038],
`[0046]
`
`13. Given the application of inductive charging to hearing aids, it is
`
`unsurprising to see the same technology applied to similar devices like wireless
`
`headsets. As I explained in my First Declaration and above, Lee, APPLE-1023 (U.S.
`
`
`
`15
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`Pat. No. 7,211,986), and APPLE-1029 (U.S. Pat. No. 7,627,289) disclosed
`
`implementations of inductive charging in the context of wireless headsets. And like
`
`hearing aids, the prior art patent literature was replete with other examples of
`
`inductively charged wireless headsets, a sampling of which are identified in the table
`
`below.
`
`Pat./Pub. No.
`
`Filing Date
`
`US 2003/0211871
`(APPLE-1076)
`
`May 9, 2002
`
`US 2003/0048254
`(APPLE-1077)
`
`Jul. 4, 2002
`
`Exemplary
`Citations
`Abstract,
`[0022],
`[0025],
`[0034],
`[0051],
`[0065],
`claim 1
`[022-0025],
`Figs. 3-4
`
`EP1942570
`(APPLE-1078)
`
`US 2011/0115429
`(APPLE-1079)
`
`Dec. 24, 2007 Abstract,
`[0001],
`[0004]-
`[0005],
`[0027]
`
`Nov. 13, 2009 Abstract,
`[0003],
`[0041]-
`[0042],
`[0062]
`
`
`
`Exemplary Quotes
`
`“The battery in the base
`transceiver unit, and the battery in
`the headset, are both inductively
`recharged.” ([0022].)
`
`“FIG. 3 is a perspective view of
`another embodiment of the
`present invention in which a
`wireless earphone 50 is charged
`by an induction power device.”
`([0022].)
`“A headset with a rechargeable
`battery is charged inductively via
`a secondary coil, which is
`coupled to a primary coil which is
`incorporated in a base unit.”
`(Abstract.)
`“Example embodiments are
`disclosed for wirelessly charging
`batteries of relatively small
`devices, such as wireless
`headsets, using a relatively large
`wireless charging plate … using
`contact-less electromagnetic
`induction.” (Abstract.)
`
`16
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
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`14. Even beyond the patent literature, inductive charging was making its
`
`way into the realm of consumer products around the time of the ’077 Patent. (E.g.,
`
`Ex.2032 at 1 (“Wireless power is beginning to show great potential in the consumer
`
`market.”); Ex.2033, 1 (“In recent years, electromagnetic induction theory is adopted
`
`to develop contactless inductive power system[s], and successfully applied on
`
`electronic toothbrush[es], electronic shaver[s], cell phone[s], telephone[s] and other
`
`portable electronic devices.”.) As I explained in my First Declaration, inductive
`
`chargers for smartphones and media players were already established as commercial
`
`products. The Powermat is a particularly salient example, as is the Palm Touchstone
`
`charger. (See APPLE-1020; APPLE-1021, APPLE-1022.)
`
`
`
`
`
`17
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`15. Moreover, as one would expect given the extensive patent literature,
`
`inductively charged hearing aids, such as the Hansaton AQ In-the-Ear (ITE) hearing
`
`aids (pictured below), had also been designed, manufactured and marketed to
`
`consumers.
`
`16. This burgeoning market penetration was bolstered by organizations like
`
`the Wireless Power Consortium that sought to standardize the specifications for
`
`inductive charging. The following excerpt from Ex. 2032 (at page 1), a document
`
`submitted by Patent Owner, is informative:
`
`
`
`For ease of use and the benefit of both designers and consumers, the
`
`Wireless Power Consortium (WPC) has developed a standard (see
`
`Reference 1) that creates interoperability between the device providing
`
`power (power transmitter, charging station) and the device receiving
`
`power (power receiver, portable device). Established in 2008, the WPC
`
`is a group of Asian, European, and American companies in diverse
`
`industries, including electronics manufacturers and original equipment
`
`
`
`18
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`manufacturers (OEMs). The WPC standard defines the type of
`
`inductive coupling (coil configuration) and the communications
`
`protocol to be used for low-power wireless devices. Any device
`
`operating under this standard will be able to pair with any other WPC-
`
`compliant device. One key benefit to this approach is that it makes use
`
`of the coils for communications between the power transmitter and the
`
`power receiver.
`
`17. All of this evidence supports my understanding that inductive charging
`
`was well known as a predictable technology alternative to conventional conductive
`
`charging. In other words, inductive charging was known to accomplish the same
`
`function as conductive charging (i.e., charging a battery) but with a different set of
`
`parameters and properties. Not only would a POSITA have known about inductive
`
`charging, but they would also have been familiar with its application to wireless
`
`headsets. From this perspective, the combination of Gundlach and Lee would have
`
`produced an exceedingly familiar and predictable result—a wireless headset with a
`
`rechargeable battery that is inductively charged by a clamshell case.
`
`C. The benefits of inductive charging were known to a
`POSITA.
`
`18. As I explained above and in my First Declaration, the benefits espoused
`
`by Lee of inductive charging relative to conductive charging include enhanced
`
`reliability and improved end-user experience. (Lee, 1:62-2:2, 3:17-20.)
`
`
`
`
`
`19
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`19. As to reliability, Lee notes the “fatigue and corrosion” challenges of
`
`conductive charging connectors. (Lee, 1:64-2:1.) And Lee is but one of multiple
`
`prior art references that recognized the reliability benefit associated with inductive
`
`charging. For example, as explained by APPLE-1023 (U.S. 7,211,986) at 1:39-60:
`
`Exposed metal contacts on headsets also risk contamination by oils and
`
`moisture from the skin of the wearer. This may cause corrosion and
`
`hence poor contact with the base station. Contamination also may cause
`
`an electrical leakage path that may cause power loss from the battery
`
`and electrolytic activity.
`
`20. Similarly, APPLE-1070 (US 4,379,988) explains that its inductively
`
`charged hearing aid has “no trouble [with] . . . poor or broken connections as in prior
`
`art units” because the design “provide[s] no plugs or electrical contacts.” (5:22-26.)
`
`Likewise, as a prelude to its discussion of inductively charged hearing aids, US
`
`6,661,197 (APPLE-1074) explains that the conductive charging contacts may suffer
`
`“potential corrosion problems when placed in contact with the alimentary canal.”
`
`(1:56-60.)
`
`21. Gundlach’s disclosure also supports the reliability challenges of the
`
`electrical connections involved in conductive charging. For example, with reference
`
`to Figures 9a and 9b (below), Gundlach explains that the embodiment involving a
`
`USB charging cable requires a special adapter [green]“formed in a manner that may
`
`reduce stress on the electronic connection [yellow]” that might otherwise be caused
`
`
`
`20
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`by “torsional motion” during use. (Gundlach, [0066].) As Gundlach notes, the
`
`adapter only “reduce[s] stress on the electronic connection.” However, a POSITA
`
`would have understood that the adapter does not eliminate stress on the connection
`
`altogether. I am unaware of any plug-in electronic connections that totally prevent
`
`mechanical stress during use (such as plugging/unplugging the connections and
`
`handling the device while plugged-in). Inductive charging, on the other hand,
`
`bypasses this issue by eliminating the connections. Moreover, as a matter of
`
`common sense, a POSITA would have appreciated that the USB port on Gundlach’s
`
`headset also would be susceptible to ingress of water, dust, or other foreign objects
`
`that could cause damage and inhibit charging.
`
`
`
`
`
`21
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`22. Basic common sense supports Lee’s reference to the “end user
`
`complexity” caused by wired conductive charging and alleviated by wireless
`
`inductive charging. As nearly anyone can attest, the USB cables employed in
`
`Gundlach’s embodiment of Figures 9a and 9b can be a pain point in the user
`
`experience. The long cables add extra clutter to a workspace, and it can be difficult
`
`to align and mate the connectors. Especially in the context of small wireless
`
`headsets, mating mini or micro-USB connections would be a hassle. (E.g., APPLE-
`
`1023, 1:33-35 (describing a “convenience feature” that avoids users “fumbling with
`
`a plug”).) Patent Owner’s Exhibit 2032 supports this point, stating (at p.1):
`
`Wireless power is beginning to show great potential in the consumer
`
`market. The ability to power an electronic device without the use of
`
`wires provides a convenient solution for the users of portable devices
`
`and also gives designers the ability to develop more creative answers to
`
`problems. This technology’s benefits can be seen in the many portable
`
`devices, from cell phones to electric cars, that normally operate on
`
`battery power.
`
`23. One further benefit of inductive charging noted by the prior art is
`
`increased safety to the user. For example, APPLE-1023 (U.S. Pat. No. 7,211,986)
`
`notes that “[e]xposed metal contacts [used in conductive charging] may also result
`
`in an allergic reaction to the user if in prolonged contact with the user’s skin.” (1:46-
`
`48.) Moreover, APPLE-1074 (US 6,661,197) explains that “[e]xternal connections
`
`
`
`22
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`. . . may present a shock hazard to the user.” (1:56-60.) Inductive charging solves
`
`these problems by removing external connections/contacts from the equation.
`
`D. A POSITA would have viewed Lee’s single, dual-purpose coil
`design as feasible in the context of Gundlach.
`
`24. The notion of a single, dual-purpose coil design for inductive charging
`
`is not unique to Lee. In fact, the general idea of using a single inductive charging
`
`coil to serve multiple purposes—namely, power and data transfer—was part of the
`
`Wireless Power Consortium’s standard for inductive charging. (See Ex.2032, pp.1-
`
`2.) Relatedly, APPLE-1029 (US 7,627,289) describes embodiments of a headset
`
`with a multi-purpose coil that “functions multiply to receive charging power for [the]
`
`battery, generate a wake up signal, or receive an audio signal carrier.” (8:35-46.)
`
`Further still, as shown below, the prior art patent literature included other sources
`
`besides Lee teaching a single coil that serves the dual purpose of facilitating
`
`inductive charging and producing sound. A POSITA possessing this background
`
`knowledge would have reasonably expected Lee’s dual-purpose coil design to be a
`
`viable option in the context of Gundlach.
`
`Pat./Pub. No.
`
`US 2009/0052721
`(APPLE-1081)
`
`Filing Date
`
`Exemplary
`Citations
`Dec. 14, 2006 Abstract,
`[0008-0014]
`
`Exemplary Quotes
`
`“The present invention is a combined
`charging coil and speaker coil
`assembly, generally shown at 30,
`referred to hereinafter as a combined
`coil assembly, for use in a personal
`care appliance, for instance the power
`
`
`
`23
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`toothbrush of FIG. 1. The combined
`coil assembly 30 includes a single
`coil 32 which serves as both a
`charging coil for charging batteries 16
`with recharging circuit 34, and as an
`audio coil for the audio speaker.”
`([0009-0010].)
`
`US 2008/0205678
`(APPLE-1075)
`
`
`Feb. 26, 2008 Abstract,
`[0031-0032],
`[0035-0037]
`
`
`
`“Supplying energy into a hearing
`apparatus in order to charge its
`rechargeable battery is to be carried
`out by way of components, which
`take up as little space as possible.
`Components, which are mostly
`already present, are thus used for the
`energy supply. Energy is inductively
`injected into the coil of a receiver,
`into a data transmission coil or a
`telephone coil for instance.
`Alternatively, acoustic energy can
`also be injected via the receiver or
`microphone and converted there into
`
`
`
`24
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`electrical energy. Special components
`need then not be provided for the
`energy supply process.” (Abstract.)
`
`US 2010/0194336
`(APPLE-1082)
`
`Jan. 25, 2010
`
`[0082-0086]
`
`
`“With reference to FIG. 18a, a
`schematic diagram of a charger 2100
`for an audio device 2200 according to
`another embodiment is shown. In this
`embodiment, the earphone unit 2120
`includes a moving coil speaker 2122
`incorporated within an earpiece 2124
`. . . The voice coil 2140 of the
`moving coil speaker 2122 is a
`transducer that receives electrical
`signals from the signal lines 2125 and
`converts them to audio signals.
`
`The voice coil 2140 is
`additionally configured to be
`couplable to an external primary
`inductor 2320 which may be housed
`within a docking station 2322. Thus
`the voice coil 2140 may serve as the
`secondary inductor 1140 (FIG. 17) of
`the inductive charger 2100, providing
`power to the audio device via the
`signal lines 2125. . .” ([0083-0084].)
`
`
`
`25
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`
`
`
`25.
`
`I understand that the Patent Owner and its expert, Dr. Toliyat, have
`
`raised multiple arguments against the viability of Lee’s dual-purpose coil design in
`
`the context of Gundlach’s headset and clamshell case. I disagree with their
`
`arguments. In my view, which is based on my personal experience and all of the
`
`evidence cited in my First Declaration and in this Supplemental Declaration, a
`
`POSITA would have viewed Lee’s dual-purpose coil as advantageous and feasible
`
`in the context of Gundlach.
`
`
`
`26
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`Patent Owner’s First Argument: Coil alignment and other issues would reduce
`charging efficiency.
`
`26. As a threshold matter, charging efficiency was a known design tradeoff
`
`between inductive and conductive charging. It would not have come as a surprise
`
`to a POSITA that inductive charging designs introduced an efficiency cost. This
`
`well-known fact would not have dissuaded a POSITA from pursuing Lee’s Figure
`
`12 embodiment, just as it did not dissuade all of the other prior art from pursuing
`
`inductive charging designs. Moreover, a POSITA would have been willing to take
`
`on the efficiency cost given the countervailing benefits—e.g., the reliability,
`
`convenience, and safety benefits of inductive charging that I discussed above.
`
`Additionally, as I explained in my First Declaration, Lee’s dual-purpose coil
`
`embodiment of Figure 12 provides the unique advantage of reducing/simplifying the
`
`assembly by using a single coil for both charging and audio.
`
`27. Tradeoffs are intrinsic to the design process. Virtually any choice
`
`between alternative design options—here, inductive charging versus conductive
`
`charging—would present pros and cons. But tradeoffs typically do not prevent
`
`POSITAs from investigating and implementing known options.
`
`28. The coil alignment challenge Patent Owner raised is a routine design
`
`problem with inductive charging systems that a POSITA would have been prepared
`
`to solve. The general goal is to [1] bring a primary coil in the charger as close as
`
`
`
`27
`
`
`
`Attorney Docket No. 50095-0030IP1
`IPR of U.S. Patent No. 10,562,077
`
`possible to a secondary coil in the device being charged; and [2] to establish a
`
`relative position between the coils that appropriately directs the magnetic field
`
`emitted by the primary coil towards the secondary coil. In many inductive charging
`
`systems, the desired relative position is for the coils to be parallel to one another and
`
`separated by an axial distance, though other arrangements are also feasible.
`
`(Compare APPLE-1032, p.1 (showing a typical arrangement with coils separated by
`
`an axial distance) with APPLE-1073, 5:2-5 (U.S. Patent No. 6,658,124) (describing
`
`a coaxial arrangement with the coils separated by a radial distance).)
`
`Typical Arrangement
`(APPLE-1032)
`
`Exemplary Alternative Arrangement
`(APPLE-1073)
`
`
`
`
`
`29.
`
`In the context of Gundlach-Lee, the most logical position for the
`
`primary coil is in the floor of the contoured recess of the clamshell case. And the
`
`most logical position for the secondary coil is along the bottom face of the headset’s
`
`main
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