throbber
Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`In re Inter Partes Review of:
`U.S. Patent No. 9,306,635
`Issued: Apr. 5, 2016
`Application No.: 13/752,169
`Filing Date: Jan. 28, 2013
`
`For: Wireless Energy Transfer with Reduced Fields
`
`FILED VIA E2E
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`DECLARATION OF DR. DAVID ARNOLD IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 9,306,635
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`Momentum Dynamics Corporation
`Exhibit 1003
`Page 001
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`TABLE OF CONTENTS
`Introduction and Qualifications ......................................................... 3
`I.
`Level of Skill in the Art ..................................................................... 5
`II.
`III. Materials Reviewed ........................................................................... 6
`IV. The ’635 Patent .................................................................................. 7
`Background ............................................................................. 7
`
` Magnetic Resonators ............................................................... 7
`Dipole Moment ..................................................................... 14
`
`Reduced Magnetic Fields ...................................................... 16
`
`Claim Construction .......................................................................... 19
`V.
`VI. Understanding of Legal Principles .................................................. 19
`VII. Summary of Primary Prior Art References ..................................... 21
`
` U.S. Patent No. 8,698,350 (“Kanno”) ................................... 21
` Wireless Power Transmission Unit ............................. 22
`Power Generator ......................................................... 28
`
`Real-World Implementation of the Power Generator . 32
`
`VIII. Claims 1-8 are Anticipated By Kanno ............................................. 35
`Claim 1: Preamble ................................................................ 36
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`Limitation 1[a]: first source magnetic resonator ................... 37
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`Limitation 1[b]: second source magnetic resonator .............. 42
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`Limitation 1[c]: device magnetic resonator .......................... 48
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`Limitation 1[d]: first dipole moment ..................................... 56
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`Limitation 1[e]: second dipole moment ................................ 64
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`Limitation 1[f]: magnetic field cancellation .......................... 70
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` Dependent Claims ................................................................. 74
`Claim 2: quality factor ................................................ 74
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`Claim 3: coil size and turns ......................................... 76
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`Claim 4: dipole moment magnitude ............................ 78
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`Claim 5: wireless power source .................................. 80
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`Claim 6: wireless power device .................................. 82
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`Claim 7: coil co-planar ................................................ 83
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`Exhibit 1003
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`Claim 8: coil axis parallel ........................................... 85
`IX. Claims 1-8 are Obvious Over Kanno .............................................. 87
` Overview ............................................................................... 87
`Claim 5 .................................................................................. 89
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`Claim 6 .................................................................................. 91
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`Conclusion ....................................................................................... 93
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`X.
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`Page 003
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`I.
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`Introduction and Qualifications
`
`I have been retained by Momentum Dynamics Corp. (“Petitioner”) to
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`provide my opinion concerning the validity of U.S. Patent No. 9,306,635
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`(Ex. 1001) which I will refer to as “the ’635 patent.” I am being compensated for
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`my time in connection with this IPR at my standard consulting rate of $625 per
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`hour, regardless of the outcome of this matter.
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`
`
`I am currently the George Kirkland Engineering Leadership Professor
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`in the Dept. of Electrical and Computer Engineering at the University of Florida.
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`I have held a tenure-track professorial position at the University of Florida since
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`2005. I began as an Assistant Professor in 2005, was promoted with tenure to
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`Associate Professor in 2010, was promoted to Full Professor in 2014, and was
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`honored with the George Kirkland Engineering Leadership Professorship in 2016.
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`
`
`I teach graduate level classes in electrical engineering and supervise
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`and mentor masters and doctoral candidates who perform research in various areas
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`relating to wireless power transfer, including power/energy systems, power
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`electronics, electromechanical transducers, magnetic materials, electromagnetics,
`
`and applied physics. I have supervised and mentored 20 Ph.D. students (3 current,
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`17 graduated), and 8 Postdoctoral Associates.
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`
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`The focus of my research has been electromagnetic and energy
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`systems, including wireless power transfer systems and their components for use
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`Exhibit 1003
`Page 004
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`in consumer, industrial, scientific, healthcare, and other industries. In connection
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`with this research, I have researched and developed power converters, power
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`electronics, and systems compatible with alternative energy sources.
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`
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`I am a Senior Member of the IEEE, including its Magnetics Society
`
`and Electron Devices Society. I have co-authored 215 peer-reviewed journal
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`articles and conference publications in areas relating to wireless power transfer and
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`its underlying concepts and technologies. I am currently on the editorial board of
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`two scientific journals, Micromachines and the Journal of Micromechanics and
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`Microengineering. From 2013-2019, I was also on the editorial board of Energy
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`Harvesting and Systems. I also review submitted articles for various refereed
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`journals including IEEE Transactions on Power Electronics, IEEE Transactions
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`on Industrial Electronics, IEEE Transactions on Antennas and Propagation, IEEE
`
`Transactions on Magnetics, Journal of Applied Physics, Applied Physics Letters,
`
`and others.
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`
`
`I hold two Bachelor of Science degrees, one in Electrical Engineering
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`and another in Computer Engineering, both from the University of Florida
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`(May 1999). I also hold a Master of Science degree in Electrical and Computer
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`Engineering from the University of Florida (December 2001) and a Ph.D. in
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`Electrical and Computer Engineering from the Georgia Institute of Technology
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`(December 2004).
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`Exhibit 1003
`Page 005
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`
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`I am a named inventor of at least 26 United States patents and at least
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`10 pending United States and international patent applications. At least 16 of these
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`patents and applications relate to power electronics and other technologies used in
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`wireless power transfer systems.
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`II. Level of Skill in the Art
`
`I understand that certain issues relating to validity must be judged
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`from the perspective of a person of ordinary skill in the art (“POSA”). I was asked
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`to apply the January 2012 timeframe for my analysis.
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`
`
`The ’635 patent relates to “wireless energy transfer using coupled
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`electromagnetic resonators.” ’635 patent 4:16-17. The ’635 patent uses “a
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`conductive first loop having a first dipole moment” and “a conductive second loop
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`having a second dipole moment.” Id. Abstract. The first and second dipole
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`moments are “substantially opposite” in order to reduce electromagnetic fields at
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`a distance from the resonator system. Id. Abstract, 51:29-33, 52:6-10, 54:39-51.
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`
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`In the January 2012 timeframe, a POSA would have had a Bachelor’s
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`degree in electrical engineering, physics, or an equivalent field, and at least two
`
`years’ industry experience, or equivalent research. Alternatively, a POSA could
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`substitute directly relevant additional education for experience, e.g., an advanced
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`degree relating to the design of circuits using inductive coupling, or an advanced
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`Exhibit 1003
`Page 006
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`degree in electrical engineering, physics, or an equivalent field with at least one
`
`year of industry experience.
`
` Although I exceeded this skill level in 2012, I have significant
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`experience supervising and working with engineers at that skill level. I believe this
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`provides me with a good understanding of the knowledge and skill of a POSA at
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`that time.
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` My opinions do not depend on a precise definition of a POSA and
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`would apply under any reasonable definition.
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`III. Materials Reviewed
` My opinions are based on the documents listed below as understood
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`by a POSA. My knowledge and experience in wireless power transfer using
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`magnetic resonators, including teaching and supervising engineers who were at the
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`level of a POSA, informed my opinions regarding how a POSA would understand
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`the disclosures of these materials.
`
`Description
`Ex.
`1001 U.S. Patent No. 9,306,635 (“the ’635 patent”)
`1005 U.S. Patent No. 8,698,350 (“Kanno”)
`1006 U.S. Patent App. Pub. No. 2010/0237709 (“Hall”)
`1007 U.S. Patent Pub. No. 2010/0181843 (“Schatz”)
`1008
`Joseph C. Stark, III, Wireless Power Transmission Utilizing a Phased
`Array of Tesla Coils (May 2004) (M.A. thesis Massachusetts Institute of
`Technology (“Stark”)
`1009 U.S. Patent No. 454,622 (“Tesla”)
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`1010
`
`Jay Newman, Physics of the Life Sciences (Springer Science +Media,
`LLC 2008) (“Physics of Life Sciences”)
`1011 Chabay, Ruth W., Matter & Interactions (John Wiley & Sons, Inc. 3d
`ed. 2011) (“Matter & Interactions”)
`
`
`IV. The ’635 Patent
` Background
` The ’635 patent “relates to wireless energy transfer using coupled
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`electromagnetic resonators” but acknowledges
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`that
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`this
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`technology was
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`well-known. ’635 patent 4:16-35. For example, the ’635 patent states that
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`“wireless energy transfer resonators” and “important considerations for resonator-
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`based power transfer includ[ing] resonator efficiency and resonator coupling” are
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`discussed extensively in U.S. Patent Publication Nos. 2010/0237709 (Ex. 1006,
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`“Hall”) and 2010/0181843 (Ex. 1007, “Schatz”). I understand that Hall and Schatz
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`are prior art to the ’635 patent.
`
` Magnetic Resonators
` A resonator is a device or system that exhibits resonance. Resonance
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`describes the physically observed phenomenon for systems to naturally oscillate at
`
`a particular frequency. Hall explains that a resonator “store[s] energy in at least
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`two different forms[] where the stored energy is oscillating between the two
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`forms.” Hall [0135.]1 For example, a pendulum is a mechanical resonator that
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`oscillates by successively exchanging potential energy and kinetic energy. By way
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`of another example, electromagnetic resonators oscillate by successively
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`exchanging electrical energy and magnetic energy. Hall [0012]. The frequency of
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`this oscillation is called the “resonant frequency.” Id. [0135], [0194].
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` Electromagnetic resonators store electric energy and magnetic
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`energy. Electric energy is associated with an electric field, and magnetic energy is
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`associated with a magnetic field. An electromagnetic resonator typically exhibits a
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`capacitance (i.e., the ability to store electric energy in response to a voltage) and
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`an inductance (i.e., the ability to store magnetic energy in response to a current
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`flow). An electromagnetic resonator oscillates by successively cycling between
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`states of maximum electric energy storage (corresponding to a peak in voltage) and
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`maximum magnetic energy storage (corresponding to a peak in current).
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` At a point in time a resonator contains a certain amount of total stored
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`energy. While one can theorize and model a lossless resonator, in practical physical
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`systems, lossless resonators do not exist. Due to dissipative (energy loss)
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`processes, the total energy in physical resonator will decay with time, and the
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`strength/amplitude of the oscillation will correspondingly diminish. The quality
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`1 Although I primarily cite Hall in this Declaration, I understand that similar
`disclosures can also be found in Schatz.
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`factor (also called Q-factor or sometimes just Q) of a resonator is defined as the
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`amount of energy stored per cycle divided by the energy lost per cycle. The quality
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`factor of the resonator is an indicator of the idealness of the resonator, i.e. a larger
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`quality factor means low energy loss. For example, a quality factor of 1000 means
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`the resonator loses 1/1000th of its energy during each oscillation cycle. A quality
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`factor of 10 means the resonator loses 1/10th of its energy during each oscillation
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`cycle.
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` Due in part to the natural decay of a physical resonator, a resonator
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`must be excited (stimulated) by some external energy source. For example, in a
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`mechanical pendulum, one must initially pull the pendulum up to a certain swing
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`height, thereby supplying an initial amount of potential energy to the resonator.
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`Similarly, for an electromagnetic resonator, external energy must be supplied to
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`excite the resonator, which could come from an external voltage source, an external
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`current source, an external electric field, or an external magnetic field.
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`Furthermore, if a lossy resonator is to maintain a constant total energy, it must be
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`driven by (sometimes call ‘pumped by’) an external energy source, where the
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`external energy source supplies power to overcome the inherent losses. In a
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`mechanical pendulum, one may continue to push the pendulum. In an
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`electromagnetic resonator, an external energy source may be applied to the circuit.
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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` Hall shows a circuit model of an electromagnetic resonator in Figure
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`6a. Hall [0185]. The electromagnetic resonator includes a capacitor (C) and
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`inductor (L). Id. The capacitor (C) stores electrical energy in the electric field
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`between its two metal plates. Id. [0187]. The inductor (L) is a conductive coil that
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`stores magnetic energy in its magnetic field. Id. [0187]-[0188]
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`
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`Id. Fig. 6a.
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`
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` As an electromagnetic resonator oscillates between storing electrical
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`energy and magnetic energy, the direction of the current flow in the circuit reverses
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`and switches directions. This creates an oscillating current. With an initial storage
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`of charge, the capacitor has one plate that is positive and one plate that is negative,
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`which establishes an electric field in between the capacitor plates. This means that
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`the capacitor has an original polarity (has opposite properties). When the capacitor
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`discharges, current flows through the inductor (e.g., clockwise) and generates
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`magnetic energy stored in the inductor’s magnetic field. Hall [0185]. When the
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`capacitor is fully discharged, the stored magnetic energy causes current to continue
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`to flow in the same direction (e.g., clockwise). Id. This continued current charges
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`the capacitor opposite to its original polarity. See id. (“[T]he inductor 108 …
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`transfers energy back into electric field energy stored in the capacitor 104.”). The
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`capacitor now has an opposite polarity, and the charged capacitor then discharges
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`in the opposite direction such that current flows through the inductor in the
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`opposite direction (e.g., counterclockwise). The inductor’s magnetic field stores
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`and then returns this energy to charge the capacitor back to its original polarity. As
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`this process repeats, the oscillating current (e.g., current switching directions) in
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`the inductor generates an oscillating magnetic field around the inductor.
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` The electromagnetic resonator oscillates between storing electrical
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`energy in the capacitor and storing magnetic energy in the inductor. When the
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`capacitor discharges, current flowing through the inductor generates magnetic
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`energy stored in the inductor’s magnetic field. Id. [0185]. Then, “magnetic field
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`energy stored in the inductor 108 … in turn transfers energy back into electric field
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`energy stored in the capacitor 104.” Id. In other words, when the capacitor is fully
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`discharged, the stored magnetic energy in the inductor causes current to continue
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`to flow. This charges the discharged capacitor in the opposite direction so that it
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`develops an opposite polarity. The oppositely charged capacitor then discharges
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`back through the inductor but in the opposite direction—i.e., current flows through
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`the inductor in the reverse direction. The inductor stores and releases this energy
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`to charge the capacitor to have its original polarity. The cycle continuously repeats
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`such that the alternating current in the inductor generates an oscillating magnetic
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`field.
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`
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`In wireless power transfer, two resonators can exchange energy. If
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`two resonators are exchanging energy, the two resonators are said to be “coupled”.
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`This energy exchange can occur by the two resonators sharing some common
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`energy mechanism. For example, two electromagnetic resonators may share a
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`portion of their magnetic fields and thereby exchange magnetic energy.
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` Hall states that “magnetic resonators” are electromagnetic resonators
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`that are “designed such that the energy stored by the electric field is primarily
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`confined within the structure and [] the energy stored by the magnetic field is
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`primarily in the region surrounding the resonator.” Hall [0012]. Hall further
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`describes that “the energy exchange is mediated primarily by the resonant magnetic
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`near-field.” Id. [0012], [0185]. Thus, energy is transferred between magnetic
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`resonators primarily through their magnetic fields. Id. [0182]. A magnetic
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`resonator is one type of electromagnetic resonator. Another type is an “electric
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`resonator.” Electric resonators, in contrast, are designed such that the energy stored
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`by the magnetic field is primarily confined within the structure and the energy
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`stored by the electric field is in the region surrounding the resonator. Coupled
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`electric resonators would transfer energy primarily through their electric fields.
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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` The principles behind magnetic resonators to wirelessly transfer
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`power have been known for over a century. Nikola Tesla used this technology in
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`the late 1800s in his development of energy transfer systems, including the system
`
`which is now referred to as the Tesla coil. See Stark 16; see also U.S. Pat. No.
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`454,622 (“Tesla”). A Tesla coil is a coupled magnetic resonance system in which
`
`two circuits, each having a capacitance and an inductance, share the same resonant
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`frequency. Stark 12 (“[T]he traditional Tesla coil is comprised of two coupled
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`second order systems sharing a resonant frequency”), 21 (“In the case of an
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`electrical circuit, a second order system implies that there is both a capacitance and
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`an inductance.”). In operation, “resonant circuits couple[] in such a way as to take
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`energy stored in the primary side of the circuit and transfer it onto the secondary
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`coil.” Id. 41.
`
` Hall discloses magnetic resonators that transfer energy according to
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`the same principles disclosed by Tesla. Hall’s Figure 1b shows a source magnetic
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`resonator 102S (left) that transfers energy over a distance D to a device magnetic
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`resonator 102D (right).
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`Hall Fig. 1b, [0029], [0156]. Each resonator has an inductor loop with capacitor
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`plates at its ends. Id. [0187], Fig. 6d. The resonators have “substantially the same
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`resonant frequency.” Id. [0147]. The source resonator “may be driven by a power
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`supply or generator” and produces an oscillating magnetic field. Id. [0156], [0185].
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`This induces an oscillating current in the inductor loop of the device magnetic
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`resonator. See id. [0185]. The induced current can be supplied to a load device such
`
`as a battery. Id. [0156].
`
` Dipole Moment
`
` The magnetic dipole moment (often abbreviated as “magnetic
`
`dipole” or “magnetic moment”) of a current loop is a vector that is perpendicular
`
`to the plane of the current loop and represents the overall strength and
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`direction/orientation of the magnetic field produced by the current loop. Ex. 1010
`
`(Physics of Life Sciences) at 437 (“The magnetic dipole moment is a vector
`
`quantity … perpendicular to the plane of the current loop.”). As shown below, the
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`direction of the dipole moment can be determined by the right-hand rule where the
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`fingers curl in the same direction as current flow and the thumb points in the
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`direction of the magnetic dipole moment. Id. (“[The] right-hand rule indicates
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`which of the two directions perpendicular to the current loop plane is correct: if the
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`fingers of your right hand are curled along the direction of current flow in a wire
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`loop, your thumb will point in the proper direction of the magnetic dipole
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`moment”); Ex. 1011 (Matter & Interactions) at 725 (“[C]url[] the fingers of your
`
`right hand in the direction of the conventional current, and your thumb points in
`
`the direction of the magnetic dipole moment.”).
`
`
`
`
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` Accordingly, because current in the loop of a magnetic resonator
`
`oscillates (repeatedly reverses direction), the dipole moment also oscillates,
`
`changing in both amplitude and direction/orientation. This change in direction of
`
`the dipole moment is shown below. When current flows clockwise, the dipole
`
`moment (purple arrow, left) points downward, and when current flows
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`counterclockwise, the dipole moment (purple arrow, right) points upward:
`
`
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`
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`
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`’635 patent Fig. 2A (annotated, current arrows added); Ex. 1010 (Physics of Life
`
`Sciences) at 437 (“Of course, if the current direction reverses so does the direction
`
`of the magnetic dipole moment, in accord with this right-hand rule.”).
`
` Reduced Magnetic Fields
` The ’635 patent states that “[i]n some wireless power transfer
`
`applications, it may be beneficial to minimize or reduce the electric and magnetic
`
`fields at a distance away from the system, at distances substantially larger than the
`
`system, and sometimes at a distance within several centimeters away from the
`
`system.” ’635 patent 51:29-57. It is desirable to reduce these fields for multiple
`
`reasons, which may include, but not limited to, reducing electromagnetic
`
`interference with other circuitry, reducing parasitic heating of neighboring objects,
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`reducing electromagnetic exposure to humans or living organisms, minimizing any
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`shift in the resonant frequency of a resonator, maximizing wireless energy transfer,
`
`or maximizing wireless energy transfer efficiency.
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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` The ’635 patent reduces these electric and magnetic fields at a
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`distance away from the system by driving two wireless power transfer systems out
`
`of phase such that they have opposite dipole moments. Id. 53:8-14. For example,
`
`the ’635 states that “if the dipole moment vectors of the two systems are the same
`
`in direction and in magnitude, and one ensures to operate the systems [] out of
`
`phase, the dipole component will be canceled far from the systems.” Id. 53:11-14.
`
`The ’635 patent also states that when “an additional resonator (source R) is used
`
`whose main purpose is to cancel the dipole moment far from the system … the
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`current of the additional resonator (source R) is adjusted to be exactly or
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`substantially out of phase with the source resonator (source 1).” Id. 52:34-42. At
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`some distance away from the resonators, the fields produced by the two oppositely
`
`oriented dipole moments effectively cancel each other due to the principle of
`
`superposition. In other words, at some distance away from the resonators, the field
`
`produced by a first resonator is substantially equal in magnitude, but in opposite
`
`direction to the field produced by a second resonator. Therefore, the total field (the
`
`sum of the field from the first resonator and the field from the second resonator)
`
`would be minimized, or ideally totally cancelled.
`
` The ’635 patent shows one exemplary embodiment for reducing
`
`magnetic fields in Figure 41. In Figure 41 below, the first wireless power transfer
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`system includes a first source magnetic resonator (“source 1,” blue) and a first
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`device magnetic resonator (“device 1,” light blue). Id. 53:18-20. The second
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`wireless power transfer system includes a second source magnetic resonator
`
`(“source 2,” green) and a second device magnetic resonator (“device 2,” light
`
`green). Id.
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`
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`’635 patent Fig. 41 (annotated).
`
`
`
`In Figure 41, “each of the source coils may be driven and controlled
`
`by a separate amplifier operating out of phase of one another.” Id. 53:37-39. As
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`indicated by the arrows pointing left in source 1 and right in source 2, source 1 and
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`source 2 are out of phase, and the oscillating current in source 1 flows in the
`
`opposite direction as the oscillating current in source 2. This produces the opposite
`
`dipole moments shown by the purple arrows pointing down in first wireless power
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`transfer system and up in the second wireless power transfer system. See id. 53:8-
`
`14. Consequently, “the dipole component will be canceled far from the systems.”
`
`Id. 53:11-14.
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`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
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`V. Claim Construction
`
`I have applied the plain meaning of the claims in my analysis for the
`
`claim terms in the ’635 patent as a POSA would have understood the terms in the
`
`context of the patent at the relevant time, i.e., around the year 2012. The prior art I
`
`discuss in this declaration discloses the subject matter of the Challenged Claims
`
`under any reasonable construction.
`
`VI. UNDERSTANDING OF LEGAL PRINCIPLES
`
`I understand that a prior art reference can render a patent claim
`
`obvious to one of ordinary skill in the art if the differences between the subject
`
`matter set forth in the patent claim and the prior art are such that the subject matter
`
`of the claim would have been obvious at the time the claimed invention was made.
`
`I understand that obviousness is a legal conclusion, but I am not offering a legal
`
`conclusion. I am testifying regarding the relevant facts that underlie the legal
`
`conclusion: the level of skill in the relevant art, the scope and content of the prior
`
`art, the differences between the prior art and the claims, and any secondary
`
`considerations.
`
`
`
`I understand that when the claimed subject matter involves combining
`
`pre-existing elements to yield no more than one would expect from such an
`
`arrangement, the combination is obvious. I understand that in assessing whether a
`
`claim is obvious one must consider whether the claimed improvement is more than
`
`19
`
`Momentum Dynamics Corporation
`Exhibit 1003
`Page 020
`
`

`

`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
`
`the predictable use of prior art elements according to their established functions. I
`
`understand that there need not be a precise teaching in the prior art directed to the
`
`specific subject matter of a claim because one can take account of the inferences
`
`and creative steps that a person of skill in the art would employ. I understand that
`
`a person of ordinary skill is a person of ordinary creativity, not an automaton.
`
`
`
`I understand that obviousness cannot be based on the hindsight
`
`combination of components from the prior art. I understand that in an obviousness
`
`analysis, neither the motivation nor the avowed purpose of the inventors control
`
`the inquiry. Any need or problem known in the field at the time of the invention
`
`and addressed by the patent can provide a reason for combining elements. For
`
`example, I understand that it is important to consider whether there existed at the
`
`time of the invention a known problem for which there was an obvious solution
`
`encompassed by the patent’s claims. I understand that known techniques can have
`
`obvious uses beyond their primary purposes, and that in many cases a person of
`
`ordinary skill can fit the teachings of multiple pieces of prior art together like pieces
`
`of a puzzle.
`
`
`
`I understand that, when there is a reason to solve a problem and there
`
`are a finite number of identified, predictable solutions, a person of ordinary skill
`
`has good reason to pursue the known options within his or her technical grasp. I
`
`understand that, if this leads to the anticipated success, it is likely the product not
`
`20
`
`Momentum Dynamics Corporation
`Exhibit 1003
`Page 021
`
`

`

`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
`
`of innovation but of ordinary skill and common sense, which bears on whether the
`
`claim would have been obvious.
`
`
`
`I understand that secondary considerations can include, for example,
`
`evidence of commercial success of the invention, evidence of a long-felt need that
`
`was solved by an invention, evidence that others copied an invention, or evidence
`
`that an invention achieved a surprising result. I understand that such evidence must
`
`have a nexus, or causal relationship to the elements of a claim, in order to be
`
`relevant.
`
`VII. SUMMARY OF PRIMARY PRIOR ART REFERENCES
` U.S. Patent No. 8,698,350 (“Kanno”)
` Kanno (Ex. 1005) is titled “Wireless Power Transmission Unit and
`
`Power Generator With the Wireless Power Transmission Unit.” I was asked to
`
`assume that Kanno is prior art. Kanno teaches the same solution to the same
`
`problem as the ’635 patent.
`
` Kanno describes a technique for reducing electromagnetic radiation
`
`emitted by a wireless power transfer system by driving the source magnetic
`
`resonators out of phase such that their magnetic fields will at least partially cancel
`
`each other. Kanno explains that “[i]f the absolute value of the phase difference []
`
`between the resonant magnetic fields 195a and 195b is equal to 180 degrees, then
`
`the two resonant magnetic fields will cancel each other, and therefore, leakage of
`
`21
`
`Momentum Dynamics Corporation
`Exhibit 1003
`Page 022
`
`

`

`Declaration ISO Pet. for Inter Partes Review of USP 9,306,635
`
`electromagnetic waves into the surrounding space can be substantially eliminated.”
`
`Kanno 20:62-21:4; see Fig. 2(b); see also id. 5:8-13 (“leakage of unwanted
`
`electromagnetic components into the surrounding space … can be reduced”).
`
` Wireless Power Transmission Unit
` Kanno “relate[s] to a magnetic resonant coupling wireless power
`
`transmission unit for transmitting power by non-contact method using magnetic
`
`resonant coupling.” Kanno 1:13-15. Kanno describes a system for wirelessly
`
`transferring power generated by solar cells on the exterior of a building to
`
`electronic devices interior to the building. Id. 4:62-5:5, 5:16-20. The system
`
`i

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