Filed on behalf of: Momentum Dynamics Corporation
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`Entered: April 18, 2022
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
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`MOMENTUM DYNAMICS CORPORATION,
`Petitioner,
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`v.
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`WITRICITY CORPORATION,
`Patent Owner.
`_______________________
`Case IPR2021-01127
`Patent 9,306,635
`_______________________
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`PETITIONER’S REPLY
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`Entered: April 18, 2022
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
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`MOMENTUM DYNAMICS CORPORATION,
`Petitioner,
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`v.
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`WITRICITY CORPORATION,
`Patent Owner.
`_______________________
`Case IPR2021-01127
`Patent 9,306,635
`_______________________
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`PETITIONER’S REPLY
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`IPR2021-01127 (USP 9,306,635)
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`Petitioner’s Reply
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 1
`I.
`Claim Construction .......................................................................................... 1
`II.
`III. Ground 1: Claims 1-8 Are Anticipated by Kanno ........................................... 4
`A. Kanno discloses the claimed magnetic field cancellation ..................... 5
`B. Kanno’s real-world implementation anticipates claims 1-8 ................. 7
`IV. Ground 2: Claims 1-8 Would Have Been Obvious Over Kanno .................... 9
`V.
`Conclusion ..................................................................................................... 11
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`IPR2021-01127 (USP 9,306,635)
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`TABLE OF AUTHORITIES
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`Petitioner’s Reply
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` Page(s)
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`CASES
`Elbit Sys. of Am., LLC v. Thales Visionix, Inc.,
`881 F.3d 1354 (Fed. Cir. 2018) ............................................................................ 9
`EPOS Techs. Ltd. v. Pegasus Techs. Ltd.,
`766 F.3d 1338 (Fed. Cir. 2014) ............................................................................ 4
`GE v. Raytheon Techs. Corp.,
`983 F.3d 1334 (Fed. Cir. 2020) .......................................................................... 10
`Luminara Worldwide, LLC v. Liown Elecs. Co. Ltd.,
`814 F.3d 1343 (Fed. Cir. 2016) ............................................................................ 2
`SciMed Life Sys., Inc. v. Advanced Cardiovascular Sys., Inc.,
`242 F.3d 1337 (Fed. Cir. 2001) ............................................................................ 2
`Techtronic Indus. v. Int’l Trade Comm’n,
`944 F.3d 901 (Fed. Cir. 2019) .............................................................................. 3
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`ii
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`Petitioner’s Reply
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`Exhibit List
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`Description
`Ex.
`1001 U.S. Patent No. 9,306,635 (the “‘635 patent”)
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`1002 U.S. Patent No. 9,306,635 File History (the “‘635 FH”)
`1003 Declaration of Dr. David Arnold
`1004 Curriculum Vitae of Dr. David Arnold
`1005 U.S. Patent No. 8,698,350 (“Kanno”)
`1006 U.S. Patent Application Publication No. 2010/0237709 (“Hall”)
`1007 U.S. Patent Application Publication 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)
`1009 U.S. Letter Patent No. 454,622 (“Tesla”)
`1010
`Jay Newman, Physics of the Life Sciences (Springer Science + Media,
`LLC 2008) (“Physics of Life Sciences”)
`1011 Ruth W. Chabay et al, Matter & Interactions (John Wiley & Sons, Inc.
`3d ed. 2011) (“Matter & Interactions”)
`1012 U.S. Patent No. 4,240,010 (“Buhrer”)
`1013 U.S. Patent Application Publication. No. 2009/0051224 (“Cook”)
`1014 U.S. Patent Application Publication No. 2011/0125007 (“Steinberg”)
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`iii
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`Petitioner’s Reply
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`I.
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`Introduction
`The Petition is supported by the Declaration of Dr. David Arnold (Ex. 1003)
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`and established that claims 1-8 are anticipated and rendered obvious by Kanno. This
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`Reply addresses Patent Owner’s flawed attorney arguments, unsupported by any
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`expert testimony, on each ground.
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`Patent Owner does not dispute that Kanno discloses every element of the
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`claims under their plain meaning. Instead, Patent Owner attempts to distinguish
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`Kanno by: (i) importing a “far-field radiation” limitation into the claims; (ii) arguing
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`that the Petition relied on distinct embodiments of Kanno; and (iii) disputing that a
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`POSA would have been motivated to combine certain disclosures of Kanno.
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`But nothing in the intrinsic record supports departing from the plain meaning
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`to inject a “far-field radiation” requirement, and in any event, Kanno’s system meets
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`it. Further, the Petition not only relied on a single preferred embodiment of Kanno,
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`but also showed that Kanno anticipates the claims independent of the supposedly
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`“distinct” embodiment. Relatedly, no motivation is required for what Kanno
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`discloses expressly.
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`II. Claim Construction
`Claim 1 recites:
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`“wherein the first and second source magnetic resonators are positioned
`so that the second magnetic field at least partially cancels the first
`magnetic field outside a spatial region through which power is
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`transferred from the first source magnetic resonator to the device
`magnetic resonator.”
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`’635 patent, claim 1.
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`Patent Owner does not dispute that Kanno teaches this limitation under its
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`plain meaning. See Pet. 19-20, 22, 48-48; POR 5-9. The claims do not mention far-
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`field radiation. Nor do the claims suggest that the partially cancelled magnetic field
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`must be a far-field as opposed to a near-field portion of the claimed magnetic field.
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`Rather, the claim requires only that the partially cancelled portion of the first
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`magnetic field is “outside a spatial region through which power is transferred from
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`the first source magnetic resonator to the device magnetic resonator.” ’635 patent,
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`claim 1.
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`Patent Owner instead argues that the phrase “outside a spatial region through
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`which power is transferred” should be limited to “far-field radiation,” contending
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`that it disavowed near-field cancellation in the specification. Patent Owner is wrong.
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`“The standards for finding lexicography and disavowal are ‘exacting.’” Luminara
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`Worldwide, LLC v. Liown Elecs. Co. Ltd., 814 F.3d 1343, 1353 (Fed. Cir. 2016).
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`“The specification or prosecution history” must “make clear that the invention does
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`not include a particular feature” by including “clear and unmistakable statements by
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`the patentee that limit the claims.” Id. (discussing SciMed Life Sys., Inc. v. Advanced
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`Cardiovascular Sys., Inc., 242 F.3d 1337, 1341 (Fed. Cir. 2001)); see also
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`2
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`Techtronic Indus. v. Int’l Trade Comm’n, 944 F.3d 901, 907 (Fed. Cir. 2019)
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`(requiring lexicography or “clear” disavowal).
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`The passages cited by Patent Owner are a far cry from the clear and
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`unmistakable disavowal required to narrow the claims to exclude near-field
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`cancellation and require far-field cancellation. To the contrary, the cited passages
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`expressly disclose that “[t]he fields that need to be minimized or reduced can be
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`either the far-field, or the near-field.” ’635 patent 51:29-37 (also disclosing that the
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`desired magnetic field cancellation can occur “at distances substantially larger than
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`the system” or “at a distance within several centimeters away from the system.”);
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`see also Ex. 1002 (’635 FH) 2023 (citing same passage of published application as
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`support for the limitation at issue); Arnold Decl. (Ex. 1003) ¶ 28 (POSA would have
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`understood that the purpose of this magnetic field cancellation is to reduce the
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`harmful effects of electromagnetic radiation to people and electronic devices near
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`the system).1
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`Patent Owner also argues that “[a]ll embodiments in the ’635 patent are
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`consistent with this goal [of attenuating far-field radiation].” POR 6 (citing
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`1 Dr. Arnold’s opinions are unrebutted and unchallenged. Patent Owner did not
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`submit expert testimony in support of its Patent Owner Response, and Patent Owner
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`did not depose Dr. Arnold.
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`’635 patent 2:3-14, 5:47-53, 51:43-55:14). But again, the cited passage expressly
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`discloses that “[t]he fields that need to be minimized or reduced can be either the
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`far-field, or the near-field.” POR 6 (citing ’635 patent 51:33-43). And whether all
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`embodiments are “consistent with” far-field cancellation is irrelevant because
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`near-field and far-field cancellation are not mutually exclusive. Arnold Decl. ¶ 114
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`(“A reduction in the strength of the electromagnetic near field generally corresponds
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`with a reduction in the strength of the electromagnetic far field.”). Moreover, “it is
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`improper to read limitations from a preferred embodiment … even if it is the only
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`embodiment … absent a clear indication in the intrinsic record that the patentee
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`intended the claims to be so limited.” EPOS Techs. Ltd. v. Pegasus Techs. Ltd., 766
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`F.3d 1338, 1341 (Fed. Cir. 2014).
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`Patent Owner’s proposed construction should be rejected.
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`III. Ground 1: Claims 1-8 Are Anticipated by Kanno
`Kanno anticipates claims 1-8. Pet. 13-57. Patent Owner does not dispute that
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`Kanno discloses every element of the claims under the plain meaning. POR 8-16.
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`Patent Owner argues only that (i) Kanno does not disclose Patent Owner’s “far-field
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`radiation” construction, and (ii) Kanno’s Figure 16 describes a different embodiment
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`than the Example 1 embodiment depicted in Figures 1, 7, and 9. Id. Patent Owner
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`is wrong on both points.
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`On (i), Patent Owner relies on its overly narrow construction. As discussed
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`above, the claims mean what they say—the broadly claimed magnetic field
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`cancellation may be near-field, far-field, or both. In any event, Kanno teaches both
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`near-field and far-field cancellation.
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`On (ii), Figure 16 describes the same embodiment as Example 1. And Kanno
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`anticipates the claims even without Figure 16.
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`A. Kanno discloses the claimed magnetic field cancellation
`Patent Owner does not dispute that Kanno discloses the magnetic field
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`cancellation limitation under its plain meaning. See Pet. 19-20, 22, 48-48; POR 5-
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`9. If the Board agrees and rejects Patent Owner’s construction, no further analysis
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`is needed—it is undisputed that Kanno teaches near-field cancellation. And even if
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`the Board adopts Patent Owner’s overly narrow construction, Kanno still anticipates
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`the claims because it teaches far-field cancellation, too.
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`As the Petition explained, Kanno discloses driving the first and second source
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`resonators 180° out of phase such that they have equal but opposite dipole moments:
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`Pet. 41-46. As a result, the second magnetic field 195b produced by the second
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`source resonator at least partially cancels the first magnetic field 195a of the first
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`source resonator, outside the spatial region through which power is transferred from
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`the first source resonator to the device resonator. Id. 47-48.
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`Patent Owner’s only argument relies on importing a “far-field radiation”
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`limitation in the claims. POR 8-9. This should be rejected for the reasons discussed
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`above—there is no support for deviating from the plain meaning and importing this
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`limitation into the claims. See Section II above.
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`Regardless, Kanno discloses that the second magnetic field at least partially
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`cancels the first magnetic field in the far-field in the same way as the ’635 patent.
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`In particular, the ’635 patent discloses that “if the dipole moment vectors of the two
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`systems are the same in direction and in magnitude, and one ensures to operate the
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`systems [] out of phase, the dipole component will be canceled far from the
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`systems.” ’635 patent 53:11-14; see also POR 6 (equating “far from the system”
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`with “the far-field.”); Pet. 8-9. And as the petition explained, Kanno’s first and
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`second source resonators have the same configuration (e.g., same size, shape, and
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`number of turns) and thus produce dipole moment vectors that are the same in
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`direction and in magnitude such that they are equal but opposite when the resonators
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`are driven out of phase. Pet. 18-23, 35-36, 47-48. Kanno thus discloses the same
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`far-field cancellation as the ’635 patent. Id.; see also Arnold Decl. ¶ 114
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`(“A reduction in the strength of the electromagnetic near field generally corresponds
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`with a reduction in the strength of the electromagnetic far field.”), ¶ 115 (Kanno’s
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`measurements show magnetic field cancellation 5 meters away from the system, i.e.,
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`a distance “10 times larger the antenna size of 50 cm and 22 times larger the antenna
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`gap of 22.5 cm.”).
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`Accordingly, the Petition established that Kanno discloses “the second
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`magnetic field at least partially cancels the first magnetic field outside a spatial
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`region through which power is transferred from the first source magnetic resonator
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`to the device magnetic resonator” under both the plain meaning and Patent Owner’s
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`unsupported and overly narrow construction.
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`B. Kanno’s real-world implementation anticipates claims 1-8
`Patent Owner argues that the Petition relied on “multiple, distinct teachings
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`of Kanno.” Not so. The Petition demonstrated that Kanno’s Example 1 describes a
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`real-world implementation of the power generator shown in Figures 1, 7 and 9. Pet.
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`14-23; see also Inst. Dec. 17-19. Patent Owner agrees. POR 12-13 (“Kanno
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`illustrates and describes
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`its
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`‘fundamental arrangement’ or
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`‘fundamental
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`configuration’ of Figures 1, 7, and 9 … and describes a specific embodiment in
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`‘Example 1.’”).
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`Patent Owner only disputes whether Figure 16 relates to the same
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`embodiment. As an initial matter, however, the Petition established that Kanno
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`anticipates claims 1-8 without relying on Figure 16. See Pet. 19-20 (Figure 7
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`discloses generating opposing magnetic fields 195a and 195b that at least partially
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`cancel each other to reduce electromagnetic leakage into the surrounding space), 45-
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`46 (same); see also id. 22-23 (Example 1 discloses driving the source resonators
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`180° out of phase to minimize leakage of electromagnetic waves into the
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`surrounding space), 47-48 (same). As the Board correctly found, “Kanno’s
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`disclosure of avoiding leakage of magnetic fields is not limited to its Figure 16
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`description.” Inst. Dec. 17; see also id. 15 (citing numerous disclosures discussing
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`Figure 7 and Example 1 in finding that “Kanno discloses this [magnetic field
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`cancellation] limitation.”).
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`Patent Owner is also wrong that Figure 16 is somehow disconnected from the
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`Example 1 embodiment depicted in Figures 1, 7, and 9. Kanno discloses that Figure
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`16 not only shares the same fundamental configuration as Figures 1 and 7, but also
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`cancels magnetic fields far from the system the same way—by driving the source
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`resonators out of phase. Pet. 19-20, 22-23, 45-48; see also Kanno 20:62:21-4. Thus,
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`as the Board correctly found, “Kanno’s Figure 16 appears to be a natural extension
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`of and incorporates the fundamental features of Figures 1 through 11.” Inst. Dec.
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`17.
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`Patent Owner’s argument that Figure 16 relates to a separate, distinct
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`embodiment amounts to nothing more than unsupported attorney argument which
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`“‘is not evidence’ and cannot rebut other admitted evidence.” Elbit Sys. of Am., LLC
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`v. Thales Visionix, Inc., 881 F.3d 1354, 1359 (Fed. Cir. 2018).
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`IV. Ground 2: Claims 1-8 Would Have Been Obvious Over Kanno
`Ground 1 of the Petition established that Kanno’s Example 1 is a real-world
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`implementation of the fundamental arrangement shown in Figures 1, 7, and 9. Pet.
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`14-23. Petitioner asserted Ground 2 to “[t]o the extent Patent Owner argues
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`otherwise.” Pet. 58. Because Petitioner does not dispute that Kanno’s Example 1 is
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`a real-world implementation of this fundamental arrangement, the Board need not
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`reach Ground 2.
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`Regardless, Patent Owner’s arguments on Ground 2 also fail. Patent Owner
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`first disputes a different purported “combination” than that of Ground 2.
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`Specifically, Patent Owner argues that a POSA would not have been motivated to
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`apply “the Figure 16 embodiment to the fundamental arrangement of Figures 1, 7,
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`Petitioner’s Reply
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`and 9 and to Example 1.” As discussed in Section III.B above, however, the Petition
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`showed that (1) Kanno discloses all the elements of claims 1-8 without Figure 16;
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`and (2) Figure 16 describes the same embodiment as Figures 1, 7, and 9 and Example
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`1. Thus, no motivation is required and Patent Owner’s argument fails as a matter of
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`law. GE v. Raytheon Techs. Corp., 983 F.3d 1334, 1352 (Fed. Cir. 2020)
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`(motivation to combine elements not required where prior art reference has already
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`combined those elements).
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`Patent Owner remaining argument fails for the same reason. Patent Owner
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`argues that the Petition failed to articulate a sufficient motivation to combine
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`Example 1 with the fundamental arrangement of Figures 7 and 9. But again, Patent
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`Owner does not dispute that Kanno describes Example 1 as a real-world
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`implementation of Figures 7 and 9. No motivation is required for what Kanno
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`describes expressly. Id.
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`In any event, the Petition explained at length why a POSA would have
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`combined
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`the Example 1’s
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`implementation details with
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`the fundamental
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`arrangement of Figures 7 and 9. In sum:
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`• A POSA implementing Figures 7 and 9 would have looked to Example 1
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`because it provides not only the specific implementation details, including
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`circuit component types and values, but it also provides test data showing that
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`the power generator achieves high efficiency with minimal leakage;
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`• Both include two power generating units with the same configuration that are
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`connected in parallel with each other;
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`• Both include power generating units that receive power from power
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`generating solar cells;
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`• The power transmitting and receiving antennas of each power generating unit
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`have a resonant frequency equal to the output frequency of the oscillator; and
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`• The power transmitting and receiving antennas are arranged on opposite sides
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`of a wall so that they face each other with the antennas on either side of the
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`wall being co-planar.
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`Pet. 58-59.
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`Accordingly, as the Board correctly found, the Petition “set[] forth detailed
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`reasoning, supported by citations to Kanno and to Dr. Arnold’s declaration”
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`supporting a motivation to combine. Inst. Dec. 20-22; see also id. 23 (rejecting the
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`POPR’s “conclusory” hindsight argument, which the POR repeats verbatim, because
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`“Petitioner’s arguments are rationally based on evidence in Kanno” and merely
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`combine “familiar elements according to known methods [to] yield predictable
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`results.”).
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`V. Conclusion
`For the reasons above and in the Petition, the challenged claims are
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`unpatentable.
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`Respectfully submitted,
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`Petitioner’s Reply
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`Dated: April 18, 2022
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`By: / Jonathan M. Strang /
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`Jonathan M. Strang (Reg. No. 61,724)
`jonathan.strang@lw.com
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, D.C. 20004-1304
`Telephone: 202.637.2200
`Fax: 202.637.2201
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`Counsel for Petitioner
`Momentum Dynamics Corp.
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`CERTIFICATE OF COMPLIANCE WITH 37 C.F.R. § 42.24
`I hereby certify that this Petitioner’s Reply complies with the word count
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`limitation of 37 C.F.R. § 42.24(c)(1) because it contains 2,270 words using
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`Microsoft Word’s counting feature, excluding the cover page, signature block, and
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`the parts of the Petitioner’s Reply exempted by 37 C.F.R. § 42.24(c).
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`Dated: April 18, 2022
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`Respectfully submitted,
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`By: / Jonathan M. Strang /
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`Jonathan M. Strang (Reg. No. 61,724)
`jonathan.strang@lw.com
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, D.C. 20004-1304
`Telephone: 202.637.2200
`Fax: 202.637.2201
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`Counsel for Petitioner
`Momentum Dynamics Corp.
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`Petitioner’s Reply
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 18th day of April
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`2022, a true and correct copy of the foregoing Petitioner’s Reply was served by
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`electronic mail on Patent Owner’s lead and backup counsel at the following email
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`addresses:
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`Joshua Griswold (Reg. No. 46,310)
`Dan Smith (Reg. No. 71,278)
`Kim Leung (Reg. No. 64,399)
`Kenneth Hoover (Reg. No. 68,116)
`W. Karl Renner (Reg. No. 41,265)
`Marc M. Wefers (Reg. No. 56,842)
`Andrew Kopsidas (Reg. No. 42,759)
`FISH & RICHARDSON P.C.
`320 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Telephone: 214.747.5070
`Fax: 877.769.7945
`Email: IPR25236-0269IP1@fr.com
`Email: PTABInbound@fr.com
`Email: griswold@fr.com
`Email: dsmith@fr.com
`Email: leung@fr.com
`Email: hoover@fr.com
`Email: axf-ptab@fr.com
`Email: wefers@fr.com
`Email: kopsidas@fr.com
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`Misha Hill (Reg. No. 59,737)
`57 Water Street
`Watertown, MA 02472
`Telephone: 617.926.2700
`Fax: 617.926.2745
`Email: misha.hill@witricity.com
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`By: / Jonathan M. Strang /
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`Adam R. Brausa (Reg. No. 60,287)
`Daralyn J. Durie (pro hac vice to be requested)
`217 Leidesdorff Street
`San Francisco, CA 94111
`Telephone: 415.362.6666
`Fax: 415.236.6300
`Email: abrausa@durietangri.com
`Email: ddurie@durietangri.com
`Email: SERVICE-WITRICITY@durietangri.com
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`Jonathan M. Strang (Reg. No. 61,724)
`jonathan.strang@lw.com
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, D.C. 20004-1304
`Telephone: 202.637.2200
`Fax: 202.637.2201
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`Counsel for Petitioner
`Momentum Dynamics Corp.
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