UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner.
`____________
`
`Case IPR2021-00472
`Patent 10,562,077 B2
`___________________________
`
`DECLARATION OF ROBERT STILLERMAN REGARDING APPLE’S
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO.
`
`10,562,077
`
`
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`i
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`Apple v. GUI Global Products
`IPR2021-00472
`GUI EX. 2001
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`TABLE OF CONTENTS
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`
`
`I.
`
`Introduction and Qualifications ......................................................................... 1
`
`II. Assignment ........................................................................................................ 9
`
`III. Legal Principles ............................................................................................... 12
`
`IV. Methodology .................................................................................................... 20
`
`V. Technology Overview ...................................................................................... 22
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`A. Magnets/Magnetism ................................................................................. 22
`
`B. Headsets, Headphones, Earphones ........................................................... 23
`
`C. Battery Charging: Conductive and Inductive ........................................... 24
`
`D. Speakers/headsets ..................................................................................... 35
`
`VI. Overview of the ‘077 Patent ............................................................................ 37
`
`VII. Overview of Gundlach and Lee ....................................................................... 42
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`A. Gundlach .................................................................................................. 43
`
`B. Lee ............................................................................................................ 49
`
`VIII. Analysis of the Cooperstock Declaration ....................................................... 54
`
`A. A POSITA Would Not Have the Skills Needed Nor Would the
`POSITA Have Been Motivated to Combine Gundlach and Lee .............. 54
`
`B. ‘077 Patent Claim Analysis of Cooperstock ............................................ 80
`
`IX. Summary of My Opinions ............................................................................... 95
`
`X. Amendments and Modifications ...................................................................... 96
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`I.
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`
`
`INTRODUCTION AND QUALIFICATIONS
`
`My name is Robert Stillerman. I have been retained by counsel for GUI
`
`Global Products, Ltd. (“Gwee” or “Patent Owner”) as a technical expert in this
`
`case. I have been asked by counsel for the Patent Owner to provide my opinions
`
`with respect to the petition by Apple, Inc. (“Apple” or “Petitioner”) for instituting
`
`an Inter Partes Review of U.S. Patent No. 10,562,077 (“the ‘077 Patent”). In
`
`particular, I have been asked to review the opinions in a document entitled,
`
`“Declaration of Dr. Jeremy Cooperstock,” dated the 5th day of February 2021
`
`(“Cooperstock Declaration” or “Cooperstock”)
`
`
`
`My background and qualifications are set forth in my curriculum vitae
`
`attached as Ex. 2002. In summary, I have a Bachelor of Science degree in
`
`Electrical Engineering, a Master of Science degree in Electrical Engineering and
`
`Computer Science, and a Master of Business Administration degree. I have over 40
`
`years of experience in the design, use and application of electronic devices and
`
`systems. This includes extensive experience with communications devices and
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`systems and switching equipment. I have experience with wireless systems for use
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`in a number of applications, including cellular communications, point-to-point
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`communications, point-to-multipoint communications, radio frequency
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`identification (RFID), voice and data. I have experience with networking products,
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`such as switches and routers. I have designed, developed, and managed the design
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`and development of computer and communications software, hardware and
`
`systems. I have experience with the delivery of services to enterprises and
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`consumers via different technologies and communications systems. I have
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`experience with devices used for voice and data communication for consumers and
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`network services providers. I have extensive experience in call centers and call
`
`center operation. I have been involved with and designed processes for use in
`
`project management, change management, client onboarding and training, and
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`installation and configuration of systems.
`
`
`
`During my career, I have worked for a number of communications
`
`equipment suppliers. I worked for Bell Telephone Laboratories designing hardware
`
`and software for an electronic switching system for toll network applications. At
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`Bell Telephone Laboratories, I worked with the proprietary signals between
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`controllers and peripheral equipment. I was a Member of Technical Staff and part
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`of a development team working on hardware and software development. I worked
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`for ITT as a development manager. In that position, I designed hardware and
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`software for an electronic, class 5 central office switching system, and worked on
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`analog line and trunk test panels, all of which are part of the infrastructure for the
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`public telephone network. I worked for BNR Inc., a subsidiary of Bell Northern
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`Research (part of Northern Telecom), designing hardware and software for an
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`Electronic Private Branch Exchange (PBX) system, which is a switching system
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`for telephones, and working on the specification of an “office of the future
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`system.” I worked for IBM/ROLM Systems, designing and testing portions of its
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`Electronic PBX, voicemail systems and phones, as well as devices such as analog
`
`and digital line and trunk circuit interfaces, and applications such as Automatic
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`Call Distribution, Call Monitoring and other applications used in call centers. At
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`ROLM, I was a section manager, being responsible for multiple development
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`projects consisting of both hardware and software, including early projects
`
`involving computer-telephony integration, a capability now used widely in call
`
`center operations. At ROLM, I also supervised a group of Product Managers
`
`involved in product development. I participated in the creation of ROLM’s Product
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`Development Process, which was a methodology that the company applied to
`
`development activities in order to manage and track product development,
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`including the formal development of documents and specifications used in the
`
`development process. I also have experience in installation of electronic and
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`wireless equipment, including outside plant and indoor wiring.
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`
`
`I worked for Unisys Corporation where I was involved with computer-
`
`based industrial and commercial applications, including electronic document
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`interchange. I managed the operation of a demonstration center for shop floor,
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`Enterprise Resource Management, CAD/CAM and electronic document
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`management systems.
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`
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`I worked for First Pacific Networks, a company that produced cable
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`telephony products, in which hybrid fiber coax installations were used for
`
`distribution of signals between the cable head end and the subscriber set top box
`
`(receiver).
`
`
`
`I worked for Harris Corporation in their Microwave Communication
`
`Division where I was Vice President of Marketing and Vice President of Business
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`Development. Harris’ microwave radios are wireless products used widely in the
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`network infrastructure for fixed communication as well as cellular and mobile
`
`networks. In my role as head of Marketing, I managed teams for market
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`development, product management, marketing communications and technical
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`marketing. In my role as head of Business Development, I was involved in the
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`evaluation and acquisition of businesses outside of Harris. In that capacity, I was
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`responsible for finding target companies and evaluating their business value to
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`Harris. Subsequent to an acquisition, I managed the integration of the acquired
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`company unit to Harris.
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`I worked on wireless technologies at Wireless Dynamics, Inc and at RS
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`International Consulting Inc, and have experience and knowledge regarding a
`
`range of wireless technologies and standards for the operation of such
`
`technologies. This includes, among other things, Payment Card Industry Data
`
`Security Standards, RFID technologies, telematics, the use of smartphones and the
`
`cellular data networks, Zigbee, self-organizing sensor networks and other
`
`technologies.
`
`
`
`I worked as a software developer for many different types of applications. I
`
`have worked with many different operating systems, using many different
`
`computer languages, and many different software libraries and code sets.
`
`
`
`I designed, wrote and licensed software as a service to institutions such as
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`Stanford University and the University of California. I designed many website and
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`web applications.
`
`
`
`I have worked for Tocca, Inc. which offers software as a service (SaaS)
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`solutions for hosting virtual spaces and virtual events. In my consulting role for
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`Tocca, I have written software, and led a number of teams in product, customer
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`services, customer on-boarding, system configuration and deployment and other
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`functional activities.
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`In prior cases I have opined on technologies such as: electronic devices
`
`including mobile devices such as phones, smartphones and tablets, RFID,
`
`recording devices and systems, security devices and systems, computer networks,
`
`communications networks and equipment, software algorithms, functions and
`
`features, user interfaces, switching devices, switching systems and equipment,
`
`gateways, messaging, voice storage and retrieval, paging and mobile networks,
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`tracking devices and systems, thermal performance of computing devices, Voice
`
`over IP Networks and Systems, wireless and mobile networks and related
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`standards, call centers, facsimile products and protocols, web technologies, hard
`
`drive forensics and analysis, email protocols and transmission, cell phone record
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`analysis, cable systems, GSM networks and standards, computer algorithms, PBX
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`operation and installation, computer server architectures, manufacturing process
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`technologies, antivirus software and others.
`
`
`
`In prior cases I have opined on the process of installation and on existing
`
`installations of electronic equipment, including wireless technologies.
`
`
`
`I have extensive experience with large software code bases, with many
`
`different operating systems, and with many different programming languages, both
`
`from my direct work experience and from analyzing software as a consultant and
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`expert in other cases. I have offered opinions relating to the functionality and
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`operation of such software.
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`
`
`I am familiar with various means of rolling out technology systems,
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`including early trials, proofs-of-concept, and full deployments. I am familiar with
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`the processes used to assign roles and responsibilities to parties engaged in
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`technology rollouts, such as the use of statements of work, project plans and rollout
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`plans as examples. I am familiar with processes and procedures and the support
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`documentation associated with installation, test and commissioning of technology
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`systems. I am familiar with the stages of product development, including phases
`
`such as concept, specification, design, integration, test, trials and general
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`availability. I have managed the deployment of complex communications
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`equipment and systems through installation, test, commissioning, acceptance and
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`general use.
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`
`
`I have been deposed and served as an expert in a number of legal matters. I
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`have served as an expert on the deployment and installation of complex
`
`technologies, such as wireless network services in rural and metropolitan areas,
`
`call centers operated by different companies, and equipment used in server farms
`
`in computer equipment rooms. I have been qualified to serve as an expert witness
`
`in forensic analysis, computer software, and various other technologies.
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`
`I submit this Declaration (“My Declaration” or “This Declaration”) based
`
`on the information I have reviewed for purposes of this case and my own personal
`
`knowledge and experience, except where stated otherwise. I am prepared to testify
`
`beyond This Declaration concerning the matters discussed herein if requested to do
`
`so.
`
`
`
`If asked to testify beyond This Declaration, I may use materials I have
`
`relied upon in forming my opinions and documents and other materials I have
`
`reviewed. I may also present demonstratives, animations, slides or other graphics
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`to demonstrate my methodology or other relevant facts and the bases for my
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`opinions in this case.
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`
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`In this Declaration, when I write, “for example,” or when I cite an
`
`example, I am not limiting my opinion to that example.
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`
`
`The opinions expressed in This Declaration are based upon the information
`
`made available to me as of the date of this Declaration. I understand that I may be
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`asked to review information produced by either party after the date of this
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`Declaration and to update this Declaration as necessary to reflect any additional
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`analysis and conclusions.
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`I understand that Petitioner may provide expert reports detailing the
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`analyses and opinions of its experts. I may be asked to supplement my opinions
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`based on any such reports.
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`
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`I am being compensated for my time on this case at a rate of $435 per
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`hour. No part of my compensation is based on the outcome of this case or the
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`substance of my opinions.
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`
`
`II. ASSIGNMENT
`
`
`
`I have been asked to review Apple’s petition and offer my opinions on
`
`whether the art cited in the Cooperstock Declaration would render the ‘077 Patent
`
`invalid or unpatentable at the relevant timeframe. The Cooperstock Declaration
`
`uses the August 5, 2011 filing date of provisional application No. 61/515,752 as
`
`the priority date to which the ‘077 Patent is entitled. Ex. 1003 at ¶ 11. For purposes
`
`of this Declaration, I will use the same August 5, 2011 priority date (“Relevant
`
`Timeframe”).
`
` My understanding is that the Cooperstock Declaration and Apple’s
`
`grounds for institution rely on a series of obviousness arguments concerning the
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`claims of the ‘077 Patent. These arguments are broadly based on seven references,
`
`see Ex. 1003 at ¶ 16:
`
`a. Ground 1A: Apple challenges claims 1, 2, 8, 9, and 11as obvious in view of
`Gundlach and Lee.
`
`b. Ground 1B: Apple challenges claims 2 and 8 as obvious in view of Gundlach,
`Lee, and Nishikawa
`
`c. Ground 1C: Apple challenges claims 11 as obvious in view of Gundlach,
`Lee, and Rosener.
`
`d. Ground 1D: Apple challenges claims 3 and 7 as obvious in view of
`Gundlach, Lee, and Brown
`
`e. Ground 1E: Apple challenges claims 4, 5, 10, 12, and 13as obvious in view
`of Gundlach, Lee, and Mak-Fan.
`
`f. Ground 2A: Apple challenges claims 1, 2, 8, 9, and 11 as obvious in view of
`Gundlach, Lee, and Kim.
`
`g. Ground 2B: Apple challenges claims 2 and 8 as obvious in view of Gundlach,
`Lee, Kim, and Nishikawa.
`
`h. Ground 2C: Apple challenges claim 11 as obvious in view of Gundlach, Lee,
`Kim, and Rosener.
`
`i. Ground 2D: Apple challenges claims 3 and 7 as obvious in view of
`Gundlach, Lee, Kim, and Brown.
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`j. Ground 2E: Apple challenges claims 4, 5, 10, 12, and 13 as obvious in view
`of Gundlach, Lee, Kim, and Mak-Fan.
`
`
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`I have been advised by counsel to Gwee that if an independent claim is not
`
`obvious over a combination of references, then a claim that depends from the
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`nonobvious independent claim is likewise not obvious in view of those references
`
`because the dependent claim contains all of the limitations of the independent
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`claim plus one or more further limitations. Claim 1 is the sole independent claim of
`
`the ‘077 Patent and I read the petition to allege that claim 1 of the ‘077 Patent is
`
`obvious based on a combination of the teachings of Gundlach, (Ex. 1005) and Lee
`
`(Ex. 1006). Pet. at 19 et seq. (referring to “Gundlach-Lee”). As I understand it, the
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`additional references cited in connection with the dependent claims are not alleged
`
`to cure any deficiencies in Ground 1A with respect to claim 1. Hence, in This
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`Declaration I focus exclusively on the arguments concerning the alleged
`
`obviousness of claim 1 of the ‘077 Patent. I am further advised that if Inter Partes
`
`Review is instituted by the Patent Trial and Appeal Board (“PTAB”), then all
`
`alleged grounds for unpatentability of the claims of the patent must be so
`
`instituted. Consequently, should trial be instituted, I may be asked to supplement
`
`my opinions with respect to Ground 1A and the other grounds of unpatentability
`
`alleged by Apple.
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`III. LEGAL PRINCIPLES
`
`
`
`I am not an attorney and have not been asked to offer my opinion on the
`
`law. However, I understand that I am obliged to follow existing law. I have
`
`therefore been asked to apply the following legal principles in my analysis.
`
`
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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 invalid. I further am
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`advised that the first step in assessing validity of a patent claim is to properly
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`construe the claim at issue.
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`
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`I understand that validity based on novelty, i.e., anticipation, and
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`obviousness is governed by 35 U.S.C. §§ 102, 103, respectively, which read as
`
`follows:
`
`35 U.S.C. 102 Conditions for patentability; novelty
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`(a) NOVELTY; PRIOR ART.—A person shall be entitled
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`to a patent unless—-
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`(1) the claimed invention was patented, described in a printed
`publication, or in public use, on sale, or otherwise available to the
`public before the effective filing date of the claimed invention; or
`
`(2) the claimed invention was described in a patent issued under
`section 151, or in an application for patent published or deemed
`published under section 122(b), in which the patent or application,
`as the case may be, names another inventor and was effectively
`filed before the effective filing date of the claimed invention.
`
`(b) EXCEPTIONS.—
`
`(1) DISCLOSURES MADE 1 YEAR OR LESS BEFORE THE
`EFFECTIVE FILING DATE OF THE CLAIMED
`INVENTION.—A disclosure made 1 year or less before the
`effective filing date of a claimed invention shall not be prior art to
`the claimed invention under subsection (a)(1) if—
`
`(A) the disclosure was made by the inventor or joint inventor or by
`another who obtained the subject matter disclosed directly or
`indirectly from the inventor or a joint inventor; or (
`
`(B) the subject matter disclosed had, before such disclosure, been
`publicly disclosed by the inventor or a joint inventor or another
`who obtained the subject matter disclosed directly or indirectly
`from the inventor or a joint inventor.
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`(2) DISCLOSURES APPEARING IN APPLICATIONS AND
`PATENTS.—A disclosure shall not be prior art to a claimed
`invention under subsection (a)(2) if—
`
`(A) the subject matter disclosed was obtained directly or indirectly
`from the inventor or a joint inventor;
`
`(B) the subject matter disclosed had, before such subject matter
`was effectively filed under subsection (a)(2), been publicly
`disclosed by the inventor or a joint inventor or another who
`obtained the subject matter disclosed directly or indirectly from the
`inventor or a joint inventor; or
`
`
`
`(C) the subject matter disclosed and the claimed invention, not
`later than the effective filing date of the claimed invention, were
`owned by the same person or subject to an obligation of
`assignment to the same person.
`
`(c) COMMON OWNERSHIP UNDER JOINT RESEARCH
`AGREEMENTS.—Subject matter disclosed and a claimed
`invention shall be deemed to have been owned by the same person
`or subject to an obligation of assignment to the same person in
`applying the provisions of subsection (b)(2)(C) if—
`
`(1) the subject matter disclosed was developed and the claimed
`invention was made by, or on behalf of, 1 or more parties to a joint
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`research agreement that was in effect on or before the effective
`filing date of the claimed invention;
`
`(2) the claimed invention was made as a result of activities
`undertaken within the scope of the joint research agreement; and
`
`(3) the application for patent for the claimed invention discloses or
`is amended to disclose the names of the parties to the joint research
`agreement.
`
`(d) PATENTS AND PUBLISHED APPLICATIONS EFFECTIVE
`AS PRIOR ART.—For purposes of determining whether a patent
`or application for patent is prior art to a claimed invention under
`subsection (a)(2), such patent or application shall be considered to
`have been effectively filed, with respect to any subject matter
`described in the patent or application—
`
`(1) if paragraph (2) does not apply, as of the actual filing date of
`the patent or the application for patent; or
`
`(2) if the patent or application for patent is entitled to claim a right
`of priority under section 119, 365(a), 365(b), 386(a), or 386(b), or
`to claim the benefit of an earlier filing date under section 120, 121,
`365(c), or 386(c) based upon 1 or more prior filed applications for
`patent, as of the filing date of the earliest such application that
`describes the subject matter.
`
`35 U.S.C. §102.
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`35 U.S.C. 103 Conditions for patentability; non-obvious subject
`matter.
`
`A patent for a claimed invention may not be obtained,
`notwithstanding that the claimed invention is not identically
`disclosed as set forth in section 102, if the differences between the
`claimed invention and the prior art are such that the claimed
`invention as a whole would have been obvious before the effective
`filing date of the claimed invention to a person having ordinary
`skill in the art to which the claimed invention pertains.
`
`Patentability shall not be negated by the manner in which the
`invention was made.
`
`35 U.S.C. §103.
`
`
`I understand that, to be patentable, an invention must not have been
`
`obvious to a person of ordinary skill in the art (“POSITA”) at the time the
`
`invention was made. A claim is invalid for obviousness if the differences between
`
`the subject matter sought to be patented and the prior art are such that that the
`
`claimed subject matter as a whole would have been obvious, at the time the
`
`invention was made, to a POSITA.
`
`
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`In determining whether a claimed invention is invalid for obviousness, 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,
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`and whether the claimed invention would have been obvious to one of ordinary
`
`skill in the art in light of those differences. I understand that hindsight must not be
`
`used when comparing the prior art to the invention for obviousness.
`
`
`
`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. In addition, obviousness may be shown by showing that it would have
`
`been obvious to combine the teachings of more than one reference. 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 results;
`
`•
`
`Use of a known technique to improve similar devices, methods, or
`
`products in the same way;
`
`•
`
`Applying a known technique to a known device, method, or product
`
`ready 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);
`
`•
`
`Known work in one field of endeavor 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.
`
`
`
`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 able to
`
`combine the teachings of multiple patents or references employing ordinary
`
`creativity and the common sense 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. It is not necessary to
`
`demonstrate a precise teaching directed to the specific subject matter of the
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`challenged claim, for a fact finder can take account of the inferences and creative
`
`steps that a person of ordinary skill in the art would employ. A patent which
`
`merely claims predictable uses of old elements according to their established
`
`functions to achieve predictable results may be found invalid as obvious. An
`
`invention may be obvious if a designer of ordinary skill in the art, facing the wide
`
`range of needs created by developments in the field, would have seen an obvious
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`benefit to the solutions tried by the applicant. When there is a design need or
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`market pressure to solve a problem and there are a finite number of identified,
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`predictable solutions, it may have been obvious to a POSITA to try the known
`
`options. If a technique has been used to improve one device, and a POSITA would
`
`recognize that it would improve similar devices in the same way, using the
`
`technique may have been obvious.
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`
`
`In my opinion a POSITA relating to the ‘077 Patent would be someone
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`with either a bachelor’s degree in Electrical Engineering, Computer Science, or
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`Mechanical Engineering and two years of post-baccalaureate electronic device or
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`system design experience, or someone with no degree but four years of experience
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`in electronic device or system design. Dr. Cooperstock’s definition of a POSITA is
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`somewhat different than mine, see Ex. 1003 at ¶ 20, nevertheless my opinions in
`
`19
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`Apple v. GUI Global Products
`IPR2021-00472
`GUI Ex. 2001
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`

`

`This Declaration would still be the same if Dr. Cooperstock’s description of a
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`POSITA is used.
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`
`
`Although my qualifications exceed those of a POSITA for the ‘077 Patent,
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`my statements and opinions expressed herein are so expressed from the perspective
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`of a POSITA.
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`
`
`IV. METHODOLOGY
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`
`
`In arriving at my opinions, in addition to relying on my education,
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`knowledge and experience, I studied and analyzed the documents and references
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`cited in the petitions and Cooperstock Declarations submitted in IPRs 2021-00471,
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`2021-00472, and 2021-00473, as well as other documents and references cited
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`herein.
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`
`
`In reaching my opinions expressed herein I have relied upon my extensive
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`experience in industry and in product and technology design, development,
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`manufacturing, marketing, use, and deployment, including my supervision and
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`directions of persons who would be POSITAs.
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`20
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`Apple v. GUI Global Products
`IPR2021-00472
`GUI Ex. 2001
`
`

`

`
`
`In reaching my opinions expressed herein I have had conversations with
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`one of the named inventors of the ‘077 Patent, Mr. Walter Mayfield.
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`
`
`I did not see any express indication in the Cooperstock Declaration of how
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`Dr. Cooperstock read and understood the claims, nor were any express
`
`construction of the claims offered in the petition. For my own part, in reading and
`
`understanding the ‘077 Patent and the various references cited in the Cooperstock
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`Declarations submitted in IPRs 2021-00471, 2021-00472, and 2021-00473, I gave
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`the claim terms their plain and ordinary meaning as a POSITA would have
`
`understood them. Where necessary, I looked to intrinsic evidence within the
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`specification before turning to external sources to determine how a POSITA would
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`have understood the claim terms in the Relevant Timeframe.
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`
`
`Before turning to the specific arguments made in the petition, I provide
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`brief overviews of some of the technologies disclosed in the ‘077 Patent as well as
`
`in the references cited by the Cooperstock Declaration, as they would have been
`
`understood by a POSITA in the Relevant Timeframe.
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`
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`21
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`Apple v. GUI Global Products
`IPR2021-00472
`GUI Ex. 2001
`
`

`

`V. TECHNOLOGY OVERVIEW
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`
`
`In this section I offer a brief overview of some of the technologies relevant
`
`to the claims and specification of the ‘077 Patent. For completeness, I also include
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`technologies discussed in the Cooperstock Declaration. If there are other related
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`technologies that I may be asked to opine on in support of my opinions, I may
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`provide those as well.
`
`
`A. Magnets/Magnetism
`
`
`
`A magnet is article that creates a magnetic field. The magnetic field is
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`invisible but its presence can be observed according to its influence on other
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`articles containing certain metals, e.g., iron, steel, nickel and others. The magnetic
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`field is responsible for a force that attracts or repels those articles towards/away
`
`from the magnet. Magnetism is a property of a material that results from the
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`internal structure of the material. Ferromagnetic materials comprise internal
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`structures which generally align their magnetic structures in the same orientation,
`
`creating a cumulatively strong magnetic force. Ferrimagnetic materials have
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`internal structures where the internal alignment may be in different orientations,
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`resulting in a net smaller magnetic force than would be true for an equivalent
`
`ferromagnetic material.
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`22
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`Apple v. GUI Global Products
`IPR2021-00472
`GUI Ex. 2001
`
`

`

` While one often thinks of a magnet as a bar or horseshoe shaped object that
`
`has a persistent magnetic field associated with it, other forms of magnets exist. Of
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`relevance to this proceeding, when an electric current flows through a wire coiled
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`into a series of loops, a magnetic field is created and the coil acts like a magnet.
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`The magnitude of the magnetic field will be proportional to the number of loops
`
`and the cross-sections thereof, as well as the magnitude of the current passing
`
`through the wire. The orientation of the effective magnet produced by the coil will
`
`be orthogonal to that of the current flow, and is given by the “right hand rule”
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`familiar to most engineering undergraduates. The effective magnetic field strength
`
`can be increased over that produced by a coil by winding the loops of wire about a
`
`ferromagnetic core.
`
`
`
`B. Headsets, Headphones, Earphones
`
`
`
`All three of these terms relate to devices for receiving and reproducing
`
`electrical signals as audio