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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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`_________________
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`MOMENTUM DYNAMICS CORPORATION,
`Petitioner,
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`v.
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`WITRICITY CORPORATION,
`Patent Owner.
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`Case IPR2021-01127
`Patent 9,306,635
`_________________
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`PATENT OWNER’S PRELIMINARY RESPONSE
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`Case IPR2021-01127
`Attorney Docket No: 25236-0269IP1
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`TABLE OF CONTENTS
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`INTRODUCTION .............................................................................................. 1
`I.
`II. SUMMARY OF THE ’635 PATENT ............................................................... 2
`III. CLAIM CONSTRUCTION ............................................................................... 3
`IV. STANDARD FOR GRANTING INTER PARTES REVIEW ........................... 4
`V. PETITIONER HAS NOT SHOWN A REASONABLE LIKELIHOOD THAT
`IT WOULD PREVAIL IN PROVING THE UNPATENTABILITY OF ANY
`CHALLENGED CLAIM ................................................................................... 5
`A. Ground 1: Petitioner fails to prove anticipation because the Petition
`improperly relies on multiple, distinct teachings of Kanno .......................... 5
`B. Ground 1: Petitioner fails to prove that dependent claims 9 and 10 are
`anticipated by Kanno .................................................................................. 10
`C. Ground 2: Petitioner fails to prove obviousness based on Kanno because
`the Petition has not shown that a POSITA would have been motivated to
`combine the multiple, distinct teachings of Kanno ..................................... 12
`VI. CONCLUSION ................................................................................................ 14
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`I.
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`Case IPR2021-01127
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`INTRODUCTION
`Witricity Corporation (“Patent Owner”) submits this Preliminary Response
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`to the Petition for Inter Partes Review of U.S. Patent No. 9,306,635 (“the ’635
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`patent”) filed by Momentum Dynamics Corporation (“Petitioner”). Petitioner has
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`failed to carry its burden to show unpatentability of the challenged claims and Inter
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`Partes Review should be denied.
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`For Ground 1, Petitioner fails to prove anticipation based on Kanno
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`(EX1005) because the Petition improperly combines multiple, distinct teachings of
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`Kanno that relate to different embodiments. As discussed in more detail below,
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`Petitioner relies on Kanno’s disclosures corresponding to Example 1, the
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`“fundamental arrangement” of Figures 1, 7, and 9, and the embodiment of Figure
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`16, each of which describe separate embodiments. However, Kanno’s Figure 16
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`embodiment (Kanno, 20:18-21:31) is not linked to the fundamental arrangement of
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`Figures 1, 7, and 9 (Kanno, 6:50-7:50, 11:9-12:14) or the embodiment set forth in
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`Example 1 (Kanno, 25:44-28:41), and Petitioner provides no explanation of why a
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`POSITA would conclude otherwise.
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`As to Ground 2, Petitioner fails to prove obviousness based on Kanno
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`because the Petition has not shown that a POSITA would have been motivated to
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`combine and apply the elements of the embodiment described by Figure 16 with
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`the fundamental arrangement of Figures 1, 7, and 9 and the embodiment set forth
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`In light of these deficiencies in the Petition, institution should be denied.
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`II.
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`SUMMARY OF THE ’635 PATENT
`The challenged claims of the ’635 patent are directed to systems for wireless
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`transfer that reflect the inventors’ recognition that “[i]n some wireless power
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`transfer applications, it may be beneficial to minimize or reduce the electric and
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`magnetic fields at a distance away from the system,” and it would be desirable “to
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`accomplish this without a substantial decrease of the performance of the system,
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`and/or dramatic changes to the external geometry of the system.” EX1001, 51:29-
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`39.
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`FIG. 40 of the ’635 patent shows a simplified example of one such wireless
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`energy transfer system with reduced fields away from the system. EX1001, 52:34-
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`53:7.
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`EX1001, FIG. 40. The system includes a source resonator (source 1) and a device
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`resonator (device 1). EX1001, 52:36-37. The inventors recognized, however, that
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`an additional resonator (source R) could be added to “cancel the dipole moment far
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`from the system.” EX1001, 52:38-39. More specifically, the ’635 patent discloses
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`that the current of the additional resonator (source R) can be adjusted to be exactly
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`or substantially out of phase with the source resonator (source 1) to reduce
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`electrical and magnetic fields far away from the system. EX1001, 52:34-42.
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`Additionally, the ’635 patent discloses that source 1 and source R can be designed
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`such that they “are of identical or near identical sizes and have an equal number of
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`wires, that the orientation of their dipoles are substantially the same, and that they
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`circulate substantially the same amount of current.” EX1001, 52:42-47. Further,
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`the system can be configured such that “the centers of the wireless power system
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`and the source R are not very far from each other.” EX1001, 53:3-5.
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`III. CLAIM CONSTRUCTION
`All claim terms in this proceeding are to be construed according to the
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`Phillips standard. Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005); 37
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`C.F.R. §42.100. No claim construction is necessary to deny institution. Patent
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`Owner’s arguments for denial do not hinge on the outcome of an actual
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`controversy about any claim construction expressed in the Petition. See Wellman,
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`Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011) (“[C]laim terms
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`need only be construed to the extent necessary to resolve the controversy.”). As
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`detailed below, the defects in the Petition are readily identifiable without defining
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`any specific claim term.1
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`IV. STANDARD FOR GRANTING INTER PARTES REVIEW
`The Board may grant a petition for inter partes review only where “the
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`information presented in the petition … shows that there is a reasonable likelihood
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`that the petitioner would prevail with respect to at least 1 of the claims challenged
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`in the petition.” 35 U.S.C. §314(a); 37 C.F.R. §42.108(c). Petitioners bear the
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`burden of showing that this statutory threshold has been met. See Office Patent
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`Trial Practice Guide, 77 Fed. Reg. 48,756, 48,756 (Aug. 14, 2012). Critically,
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`Petitioners must fulfill this burden based on “information presented in the petition”
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`(35 U.S.C. §314(a)), and the law forbids Petitioners from subsequently adding
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`theories/arguments that should have been part of their initial Petition. Intelligent
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`Bio-Systems, Inc. v. Illumina Cambridge, Ltd., 821 F.3d 1359, 1369 (Fed. Cir.
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`2016) (citing to 35 U.S.C. § 312) (“It is of the utmost importance that petitioners in
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`the IPR proceedings adhere to the requirement that the initial petition identify
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`‘with particularity’ the ‘evidence that supports the grounds for the challenge to
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`each claim.’”); see also Cuozzo Speed Techs., LLC v. Lee, 136 S.Ct. 2131, 2154
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`(2016) (Alito, J. concurring in part and dissenting in part) (“Thus, if a petition fails
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`1 Patent Owner reserves the right to make claim construction arguments in other
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`proceedings.
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`to state its challenge with particularity—or if the Patent Office institutes review on
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`claims or grounds not raised in the petition—the patent owner is forced to shoot
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`into the dark. The potential for unfairness is obvious.”).
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`V.
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`PETITIONER HAS NOT SHOWN A REASONABLE LIKELIHOOD
`THAT IT WOULD PREVAIL IN PROVING THE
`UNPATENTABILITY OF ANY CHALLENGED CLAIM
`A. Ground 1: Petitioner fails to prove anticipation because the
`Petition improperly relies on multiple, distinct teachings of Kanno
`The Petition fails to meet its threshold evidentiary burden of establishing
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`that Kanno (EX1005) anticipates under pre-AIA §102(a), because it combined
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`multiple, distinct teachings within the reference. In order to anticipate a claimed
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`invention, a prior art reference must “disclose all elements of the claim within the
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`four corners of the document,” and it must “disclose those elements ‘arranged as in
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`the claim.’” Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359, 1369 (Fed. Cir.
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`2008) (quoting Connell v. Sears, Roebuck & Co., 722 F.2d 1542, 1548 (Fed. Cir.
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`1983)). Because of this and other legal authorities, “anticipation is not proven by
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`‘multiple, distinct teachings that the artisan might somehow combine to achieve
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`the claimed invention.’” Microsoft Corp. v. Biscotti, Inc., 878 F.3d 1052, 1069
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`(Fed. Cir. 2017). A reference, however, “can anticipate a claim even if it ‘d[oes]
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`not expressly spell out’ all the limitations arranged or combined as in the claim, if
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`a person of skill in the art, reading the reference, would ‘at once envisage’ the
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`claimed arrangement or combination.” Id. (alteration in original). Petitioner has
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`not demonstrated a reasonable likelihood a POSITA would “at once envisage” the
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`claimed wireless power transfer system based on the multiple, distinct portions of
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`Kanno describing different embodiments.
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`Petitioner relies on Kanno’s “real-world implementation of the power
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`generator” described as “Example 1” with two power generating units connected in
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`parallel. See, e.g., Petition, 21-23. According to Petitioner, Kanno’s Example 1
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`“provides the specific values and other implementation details for constructing a
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`power generator having the same fundamental arrangement shown in Figures 7 and
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`9.” Id.
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`Petition, 31 (annotating Kanno Figures 7 and 9).
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`Petition, 36 (modifying and annotating Kanno Figure 7 to reflect implementation
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`details of Example 1).
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`Petitioner states that the power generator of Figure 7 “uses the wireless
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`power transmission unit of Figure 1 with power generating sections 101.” Petition,
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`17. Kanno illustrates and describes its “fundamental arrangement” or
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`“fundamental configuration” of Figures 1, 7, and 9 at 6:50-7:50 and 11:9-12:14,
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`and describes a specific embodiment in “Example 1” at 25:44-28:41.
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`Petitioner’s anticipation arguments for elements 1[e] and 1[f] depend on
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`Kanno’s statement that the “the two resonant magnetic fields will cancel each
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`other,” with respect to the embodiment described in Figure 16. Petition, 20, 46-47
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`(citing Kanno, 20:62-21:4). But Kanno explicitly describes Figure 16 as a
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`different embodiment than the fundamental arrangement of Figures 1, 7, and 9 and
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`the embodiment of Example 1. Because the Petition relies on the Figure 16
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`embodiment for elements 1[e] and 1[f], the Petition’s analysis of these elements as
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`anticipated by Kanno is deficient.
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`Specifically, Kano describes Figure 16 under the heading “Embodiment 1,”
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`one of five different embodiments discussed by Kanno, separate and apart from the
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`fundamental arrangement shown in Figures 1, 7, and 9 and from the “real-world”
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`embodiment set forth in Example 1. Under the heading “Embodiment 1,” Kanno
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`explicitly breaks Embodiment 1 into three different embodiments. Kanno, 12:45-
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`47 (“a First Specific Preferred Embodiment of a power generator according to the
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`present invention will be described with reference to FIGS. 12 and 13.”), 19:16-20
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`(“FIG. 14 illustrates a preferred embodiment in which to increase the inductance
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`L2 of the power receiving inductor 109a, the number of turns N2 of the power
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`receiving inductor 109a is set to be greater than the number of turns N1 of the
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`power transmitting inductor 107a.”). With respect to Figure 16, Kanno states that
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`“[h]ereinafter, a preferred embodiment of a power generator according to the
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`present invention will be described” and “FIG. 16... illustrates a preferred
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`embodiment of a power generator according to the present invention that includes
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`a number of power generating units 131a, 131b, and 131n.” Kanno, 20:18-25.
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`Kanno does not describe combining the embodiment in Figure 16 (or the
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`accompanying description) with the “fundamental arrangement” of Figures 1, 7,
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`and 9 or with the “Example 1” embodiment that Petitioner separately relies upon.
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`And Petitioner provides no explanation for why a POSITA would have “at once
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`envisaged” combining the embodiment set forth in Figure 16 with these other
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`embodiments described in Kanno.
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`The Arnold Declaration mirrors the Petition in this respect and relies on the
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`same figures and portions of Kanno. See, e.g., EX1003, ¶¶46-56, 100-115. Dr.
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`Arnold alleges that a “POSA would understand that... the real-world
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`implementation in Example 1 implements the power generator with two power
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`generating units as disclosed as Embodiment 1 and Figure 7.” EX1003, ¶53. But
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`Dr. Arnold’s assertion is incorrect with respect to the embodiment of Figure 16
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`because the Figure 16 embodiment includes more than two power generating
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`units—namely, “a number of power generating units 131a, 131b, and 131n.”
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`Kanno, 20:20-25, FIG. 16.
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`Dr. Arnold further alleges that “Example 1 includes all the components
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`disclosed in Embodiment 1 and Figure 7” EX1003, ¶53. This assertion by Dr.
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`Arnold is also incorrect with respect to the embodiment of Figure 16. Kanno
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`discloses that the Figure 16 embodiment includes the “arrangement that has
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`already been described with respect to FIGS. 3 and 4.” Kanno, 20:56-61. In
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`Kanno, “FIG. 3 illustrates a modified example of the wireless power transmission
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`unit shown in FIG. 1,” and “FIG. 4 illustrates another modified example of the
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`wireless power transmission unit shown in FIG. 1.” Kanno, 7:51-52, 7:63-64. As
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`discussed in the Arnold Declaration, Kanno’s Figure 3 “describes adding a phase
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`controller at the output of a power receiving antenna 109,” and Figure 4 “describes
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`reversing the output connection of a power receiving antenna 109.” Kanno does
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`not disclose that Example 1 or the fundamental arrangement of Figures 1, 7, and 9
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`includes the modifications of Figure 3 and/or Figure 4.
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`Just as with the Petition, the Arnold Declaration fails to explain why a
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`POSITA would have viewed the embodiment set forth in Figure 16 as part of the
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`“fundamental arrangement” of Figures 1, 7, and 9 or the specific embodiment
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`described in “Example 1.” Indeed, neither the Petitioner nor Dr. Arnold discuss
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`how or why a POSITA would have envisioned the claimed systems based on the
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`disparate teachings of Kanno describing numerous different embodiments.
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`Accordingly, Petitioner has not demonstrated a reasonable likelihood that it
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`will prevail on its assertion that claims 1-10 are anticipated by Kanno. For this
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`reason, the Board should decline to institute review of the ’635 patent.
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`B. Ground 1: Petitioner fails to prove that dependent claims 9 and 10
`are anticipated by Kanno
`The Petition states that “[c]laims 2-10 depend from claim 1” and alleges that
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`“[t]hey are unpatentable for the same reasons as claim 1 and as further explained
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`below, ” but claims 9 and 10 were not included in the Petition’s “Identification of
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`Challenges” (Petition, 2). Petition, 49. Moreover, the Petition fails to provide any
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`analysis with respect to claims 9 and 10. See generally, Petition. Patent Owner
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`should not be forced to guess whether the error is in the identification of the
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`challenged claims or in the body of the Petition where the claims are referenced.
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`Claim 9 recites: “The system of claim 1, wherein the at least one capacitor is
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`a variable capacitor.” EX1001, 56:42-43. Nowhere does the Petition mention that
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`Kanno discloses a variable capacitor, or otherwise address the features of claim 9.
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`See generally, Petition. Accordingly, the Petition does not demonstrate a
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`reasonable likelihood of proving unpatentability for claim 9.
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`Claim 10 recites: “The system of claim 1, wherein the at least one capacitor
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`is in parallel with the first coil.” EX1001, 56:44-45. Nowhere does the Petition
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`mention that Kanno discloses a capacitor in parallel with a source/transmitting coil,
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`or otherwise address the features of claim 10. See generally, Petition. Rather, the
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`Petition relies on Kanno’s disclosure that “the power transmitting antenna 107 is a
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`series resonant circuit in which a power transmitting inductor 107a and a first
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`capacitor 107b are connected together in series” – not the parallel arrangement
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`required by claim 10. Petition, 27-28 (citing Kanno, 10:36-43). Accordingly, the
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`Petition does not demonstrate a reasonable likelihood of proving unpatentability
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`for claim 10.
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`For these additional reasons, the Board should decline to institute review of
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`the ’635 patent.
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`C. Ground 2: Petitioner fails to prove obviousness based on Kanno
`because the Petition has not shown that a POSITA would have
`been motivated to combine the multiple, distinct teachings of
`Kanno
`The original Petition must establish a prima facie case of obviousness with
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`regard to its proposed combinations of references. It is well settled that “there
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`must be some articulated reasoning with some rational underpinning to support the
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`legal conclusion of obviousness.” KSR Intn’l Co. v. Teleflex Inc., 550 U.S. 398,
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`418 (2007) (quoting In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006)); PersonalWeb
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`Techs., LLC v. Apple, Inc., 848 F.3d 987, 993 (Fed. Cir. 2017) (explaining that it is
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`insufficient to allege “that a skilled artisan, once presented with the two references,
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`would have understood that they could be combined.”).
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`Petitioner’s argument that the challenged claims would have been obvious
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`based on Kanno does not specifically address the deficiencies above in Petitioner’s
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`anticipation argument. For its obviousness challenge based on Kanno, Petitioner
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`alleges that “it would have been obvious to apply the implementation details of
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`Example 1 to the fundamental arrangement of Figures 7 and 9.” Petition, 58.
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`However, the Petition and the Arnold Declaration fail to establish that it would
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`have been obvious and that a POSITA would have been motivated to apply the
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`Figure 16 embodiment to the fundamental arrangement of Figures 1, 7, and 9 and
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`to Example 1.
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`Further, Petitioner and Dr. Arnold fail to provide “some articulated
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`reasoning” to combine the embodiments to achieve the elements of claim 1.
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`Petitioner alleges that “[a] POSA would have known how to combine the
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`implementation details of Example 1 with the arrangement of Figures 7 and 9 with
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`a reasonable expectation of success.” Petition, 58. Dr. Arnold makes essentially
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`the identical assertion. EX1003, ¶149. This is not enough to fulfill Petitioner’s
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`burden under §316(e). Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed.
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`Cir. 2015) (holding it is not enough to demonstrate “whether a skilled artisan not
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`only could have made” the proposed combination” (emphasis in original));
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`PersonalWeb Techs., LLC v. Apple, Inc., 848 F.3d 987, 993 (Fed. Cir. 2017)
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`(explaining that it is insufficient to allege the two references “could be combined”
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`to achieve the claim element); Olympia Tools International, Inc. v. JPW Industries,
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`Inc., IPR2018-00388, Paper 8, 19 (PTAB June 20, 2018) (concluding it is
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`“insufficient” to argue “the mere fact that a person having ordinary skill in the art
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`could make such a change” (emphasis added)); Hulu, Inc. v. Sound View
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`Innovations, LLC, IPR2018-00582, Paper 34, 21-22 (PTAB “Informative” August
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`5, 2019) (stating the petitioner’s theory “strikes us as merely a bald statement
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`about what could have been achieved at the time of the invention” (emphasis
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`added)).
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`Petitioner further alleges that “[a] POSA interested in constructing a power
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`generator with the fundamental arrangement of Figures 7 and 9 would have looked
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`to Example 1.” Petition, 59. Dr. Arnold makes essentially the identical assertion.
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`EX1003, ¶150. Petitioner’s allegation is largely conclusory and is premised on
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`hindsight in which the claims of the ’635 patent are used as a roadmap for
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`combining pieces of different embodiments, without any evidence that a POSITA
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`would have been motivated to combine Kanno’s embodiments to arrive at the
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`specific combination claimed in the ’635 patent.
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`Accordingly, the Petition has not established a prima facie case of
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`obviousness, and Petitioner has not demonstrated a reasonable likelihood that it
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`will prevail on its assertion that claims 1-8 would have been obvious over Kanno.
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`For this additional reason, the Board should decline to institute review of the ’635
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`patent.
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`VI. CONCLUSION
`For at least the reasons discussed above, Patent Owner requests that the
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`Board deny the Petition. Petitioner has failed to demonstrate a reasonable
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`likelihood that any of the challenged claims are unpatentable.
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`Date: October 12, 2021
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`Respectfully submitted,
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`/Joshua A. Griswold/
`Joshua A. Griswold, Reg. No. 46,310
`Daniel D. Smith, Reg. No. 71,278
`Kim H. Leung, Reg. No. 64,399
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 214-747-5070
`F: 877-769-7945
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`Attorneys for Patent Owner
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`CERTIFICATION UNDER 37 CFR § 42.24(d)
`Under the provisions of 37 CFR § 42.24(d), the undersigned hereby certifies
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`that the word count for the foregoing Patent Owner’s Preliminary Response to
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`Petition totals 2,909, which is less than the 14,000 allowed under 37 CFR
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`§ 42.24(b)(1).
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`Date: October 12, 2021
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`Respectfully submitted,
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`/Joshua A. Griswold/
`Joshua A. Griswold, Reg. No. 46,310
`Daniel D. Smith, Reg. No. 71,278
`Kim H. Leung, Reg. No. 64,399
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 214-747-5070
`F: 877-769-7945
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`Attorneys for Patent Owner
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. §§42.6(e), the undersigned certifies that on October
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`12, 2021, a complete and entire copy of this Patent Owner’s Preliminary Response
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`was provided via email to Petitioner by serving the correspondence email address
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`of record as follows:
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`Jonathan M. Strang
`Inge A. Osman
`Lisa K. Nguyen
`Jeffrey G. Homrig
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`Blake R. Davis
`Dale Chang
`Linfong Tzeng
`Laura Nguyen
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`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, D.C. 20004-1304
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`E-mail:
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`jonathan.strang@lw.com
`inge.osman@lw.com
`lisa.nguyen@lw.com
`jeff.homrig@lw.com
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`blake.davis@lw.com
`dale.chang@lw.com
`linfong.tzeng@lw.com
`laura.nguyen@lw.com
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`/Kristyn Waldhauser/
`Kristyn Waldhauser
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(612) 638-5731
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