`Filed on behalf of: Momentum Dynamics Corporation
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`Entered: July 8, 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 IPR2021-01166
`Patent 8,304,935
`______________________
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`PETITIONER’S REPLY
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`IPR2021-01166 (USP 8,304,935)
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`Petitioner’s Reply
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`TABLE OF CONTENTS
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`I.
`II.
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`Introduction ...................................................................................................... 1
`Ground 1: Claims 1, 5-8, 15 and 19-22 are anticipated by O’Brien ............... 2
`A. O’Brien discloses the claimed “source resonator” and “second
`resonator” .............................................................................................. 2
`1.
`O’Brien discloses the claimed “source resonator” ..................... 3
`2.
`O’Brien discloses the claimed “second resonator” ..................... 8
`O’Brien discloses the “shaping” requirement of claim 1 .................... 11
`B.
`III. Ground 2: Claims 1-23 would have been obvious over O’Brien in
`view of Haaster .............................................................................................. 12
`IV. Conclusion ..................................................................................................... 15
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`IPR2021-01166 (USP 8,304,935)
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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
`Bristol-Myers Squibb Co. v. Ben Venue Labs., Inc.,
`246 F.3d 1368 (Fed. Cir. 2001) .......................................................................... 12
`In re Gleave,
`560 F.3d 1331 (Fed. Cir. 2009) .......................................................................... 13
`SHDS, Inc. v. Truinject Corp.,
`IPR2020-00935, Paper 30 (P.T.A.B. Nov. 15, 2021) ........................................... 7
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`ii
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`IPR2021-01166 (USP 8,304,935)
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`Petitioner’s Reply
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`Exhibit List
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`Description
`Ex.
`1001 U.S. Patent No. 8,304,935 (“’935 patent”)
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`1002 File History for ’935 patent (“’935 patent FH”)
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`1003 Declaration of Mark Allen (“Allen Decl.”)
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`1004 Curriculum Vitae of Mark Allen
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`1005 Declaration of Sylvia Hall-Ellis
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`1006 Curriculum Vitae of Sylvia Hall-Ellis
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`1007 Kathleen O’Brien, Inductively Coupled Radio Frequency Power
`Transmission System for Wireless Systems and Devices (2007) (Ph.D.
`dissertation, Technical University of Dresden) (“O’Brien”), including
`certified translation of the German portions of pages 1-3
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`1008 U.S. Patent No. 2004/0001299, van Haaster, et al., “EMI Shield
`Including a Lossy Medium” (“Haaster”)
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`1009
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`International Publication No. WO 2005/024865, P. Beart, et al.,
`“Inductive Power Transfer Units Having Flux Shields” (“Beart”)
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`1010 U.S. Patent No. 6,501,364, Hui, et al., “Planar Printed-Circuit-Board
`Transformers with Effective Electromagnetic Interference (EMI)
`Shielding” (“Hui-364”)
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`1011 U.S. Patent Application Publication No. 2005/0189910, S.R. Hui,
`“Planar Inductive Battery Charger” (“Hui-910”)
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`1012 U.S. Patent No. 7,358,447, J.F. Gabower, “Electromagnetic Interference
`Shields for Electronic Devices” (“Gabower”)
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`iii
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`Ex.
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`Description
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`Petitioner’s Reply
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`1013 Frederick Emmons Terman, et al., Electronic and Radio Engineering
`(4th ed. 1947) (“Terman”) (excerpted)
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`1014 Kathleen O’Brien, et al., Magnetic Field Generation in an Inductively
`Coupled Radio-Frequency Power Transmission System, IEEE 2006
`37th Annual Power Electronics Specialists Conference (July 2006)
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`1015 G. Scheible, et al., Novel Wireless Power Supply System for Wireless
`Communication Devices in Industrial Automation Systems, IEEE 2002
`28th Annual Conference of the Industrial Electronics Society (Nov.
`2002) (“Scheible”)
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`1016 Estill I. Green, The Story of Q, 43 Am. Scientist 584 (Oct. 1955) (“Story
`of Q”)
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`1017 David H. Staelin, et al., Electromagnetic Waves 46 (1998) (“Staelin”)
`(excerpted)
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`1018 Herbert L. Krauss, et al., Solid State Radio Engineering (1980)
`(“Krauss”) (excerpted)
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`1019 U.S. Patent No. 8,169,185, A. Partovi & M. Sears, “System and Method
`for Inductive Charging of Portable Devices” (“Partovi”)
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`1020 U.S. Patent No. 7,561,114, M. Maezawa, et al., “Electromagnetic
`Interference Suppressor, Antenna Device and Electronic Information
`Transmitting Apparatus” (“Maezawa”)
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`1021 Kathleen O’Brien, et al., Design of Large Air-Gap Transformers for
`Wireless Power Supplies, IEEE 2003 34th Annual Conference on Power
`Electronics Specialists (June 2003)
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`1022 Kathleen O’Brien, et al., Analysis of Wireless Power Supplies for
`Industrial Automation Systems, 29th Annual Conference of the IEEE
`Industrial Electronics Society (2003)
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`iv
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`Ex.
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`Description
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`Petitioner’s Reply
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`1023 U.S. Patent No. 5,639,989, Leo M. Higgins, III, “Shielded Electronic
`Component Assembly and Method for Making the Same” (“Higgins”)
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`1024 Declaration of Michael T. Pierce In Response to Patent Owner’s
`Objections to Petitioner’s Exhibits [served, not filed]
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`1025 Declaration of Sylvia D. Hall-Ellis, PH.D., as filed in IPR2021-01165
`[served, not filed]
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`1026 Declaration of Jeffrey G. Homrig in Support of Petitioner’s Unopposed
`Motion for Pro Hac Vice Admission Under 37 C.F.R. § 42.10(c)
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`1027 Declaration of Blake R. Davis in Support of Petitioner’s Unopposed
`Motion for Pro Hac Vice Admission Under 37 C.F.R. § 42.10(c)
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`v
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`IPR2021-01166 (USP 8,304,935)
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`I.
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`Introduction
`The Petition established, with supporting testimony from Dr. Allen, that the
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`Petitioner’s Reply
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`challenged claims are unpatentable over O’Brien alone (Ground 1), or O’Brien in
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`view of Haaster (Ground 2). This Reply addresses Patent Owner’s flawed and
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`unsupported attorney arguments, having declined to depose Petitioner’s expert.
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`Patent Owner argues that the Petition improperly “mixes” disclosures of
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`O’Brien’s “Tuneable Resonant Circuit” and “source coil” to satisfy the “source
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`resonator” element of the claims. Similarly, Patent Owner argues the Petition
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`improperly “mixes” disclosures of O’Brien’s “Resonant Circuit” and “receiving
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`coil” to satisfy the claimed “second resonator.” Patent Owner claims these circuits
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`and coils are “separate components.” Patent Owner is wrong. The Petition relies on
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`O’Brien’s “Tuneable Resonant Circuit,” including its source coil, as disclosing the
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`“source resonator.” Likewise, the Petition relies on the “Resonant Circuit,”
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`including its receiving coil, as disclosing the “second resonators.”
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`Patent Owner also makes a conclusory argument that O’Brien fails to disclose
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`claim 1’s shaping feature because O’Brien does not teach how to “intentionally
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`shield devices or components.” But claim 1 has no “devices” or “components”
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`requirement. Rather, the claim requires that the “field … is shaped using a
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`conducting material and a magnetic material,” regardless of any “devices” or
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`“components.” And even if there was such a requirement, O’Brien in view of
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`1
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`Haaster renders it obvious for the reasons set forth in Ground 2 of the Petition and,
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`Petitioner’s Reply
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`as explained below, because in the combination Haaster’s shielding would shape
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`O’Brien’s source field around devices or components.
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`II. Ground 1: Claims 1, 5-8, 15 and 19-22 are anticipated by O’Brien
`A. O’Brien discloses the claimed “source resonator” and “second
`resonator”
`Challenged independent claims 1 and 15 recite a “source resonator” (element
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`[a]), “a second resonator located a distance from the source resonator” (element [b])
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`and “the source resonator and the second resonator are coupled to provide near-field
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`wireless energy transfer among the source resonator and the second resonator”
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`(element [c]).
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`Patent Owner does not dispute that O’Brien discloses each of these elements
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`arranged as in the claim. Patent Owner instead argues that the Petition failed to
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`consistently map these components to the claim elements. POR 3. In particular,
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`Patent Owner argues the Petition first relies on the “Tuneable Resonant Circuit” and
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`“Resonant Circuit” from O’Brien’s Figure 5-1 as the claimed “source resonator” and
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`“second resonator” in elements [a] and [b], but then relies on O’Brien’s “source coil”
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`and “receiving coil” as satisfying the “coupled to” requirement in element [c].
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`According to Patent Owner, “O’Brien makes clear that these ‘source coils’ and
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`‘receiving coils’ are separate from the ‘source side resonant circuit’ (the alleged
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`source resonator) and the ‘receiver side resonant circuit’ (the alleged second
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`Petitioner’s Reply
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`resonator).” POR 6.
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`Patent Owner is incorrect. The Petition does not improperly “mix” O’Brien’s
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`disclosures. As discussed below, O’Brien’s “Tuneable Resonant Circuit” includes a
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`source coil and a tuning circuit connected on the source side, and the Petition maps
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`them together as the claimed “source resonator.” Similarly, O’Brien’s “Resonant
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`Circuit” includes a receiving coil connected to a tuning circuit on the receive side,
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`and the Petition maps them together as the claimed “second resonator.”
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`1. O’Brien discloses the claimed “source resonator”
`The Petition maps the “Tuneable Resonant Circuit,” including its source coil,
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`to the claimed source resonator.1 Contrary to Patent Owner’s arguments, O’Brien’s
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`“source coil” and “Tuneable Resonant Circuit” are not “separate components,” nor
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`does the Petition exclude the source coil from the claimed “source resonator.” See
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`POR 3-6.
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`To explain, the Petition points to more than the “high level block diagram” in
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`O’Brien’s Figure 5-1 as disclosing the claimed “source resonator.” That block
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`diagram shows a general system layout, but it does not specifically depict the
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`1 Indeed, a resonant circuit includes an inductor and a capacitor. Allen Decl.
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`¶¶ 37-38.
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`3
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`particular components making up its “Tuneable Resonant Circuit” or explain how
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`Petitioner’s Reply
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`the “Loosely Coupled Transformer” is formed. See O’Brien 85 (Ex. 1007); Pet. 17-
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`19, 21. To understand O’Brien’s high-level block diagram in Figure 5-1 and to show
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`what components are included in the “Tuneable Resonant Circuit,” O’Brien (and the
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`Petition) directs the reader to O’Brien’s Chapter 6 for a more detailed description of
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`the source side resonant circuit. Pet. 17-19, 21; O’Brien 85.
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`There, O’Brien
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`includes a Section 6.3 entitled “Tuning circuit
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`characteristics.” The introduction of that section states that the source and receiver
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`sides of the system have “tuned” circuits including the source and receiver coils that
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`together may form the “Loosely Coupled Transformer” illustrated in the Figure 5-1
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`block diagram:
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`As the source and receiver sides of the system are tuned to a resonant
`frequency, and form a transformer with a large air-gap, the
`characteristics of tuned transformers are investigated in this section.
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`O’Brien 1142; Pet. 19. Thus, the “Tuneable Resonant Circuit” and the “Resonant
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`Circuit” of Figure 5-1 include the source and receiver coils that, when coupled, form
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`the “Loosely Coupled Transformer” illustrated in Figure 5-1.
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`2 Emphasis added unless otherwise noted.
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`Petitioner’s Reply
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`To remove any doubt, O’Brien further discloses choosing a “series resonant
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`configuration” for the source side, shown in Figure 6-4, reproduced in the Petition
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`and below.
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`O’Brien 114-15 (highlighting added to Figure to show source coil), 119; Pet. 18-19.
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`Figure 6-4 depicts the source-side resonant circuit including the source coil
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`(highlighted Lsr) connected to a capacitor (Csr) in series. Pet. 18-19; O’Brien Fig.
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`6-4, 114-15 (describing the “parameters of the resonant circuit” with equations
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`including the coil “L”), 119 (section entitled “Source side resonant circuit” stating
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`the “characteristic parameters of the series resonant circuit were discussed in Section
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`6.3.1,” which includes Figure 6-4 and its associated equations). Thus, again,
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`O’Brien discloses that its “resonant circuit” on the source-side includes the source
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`coil. See also Inst. Dec. 20 (“[T]he Petition appears to reasonably convey the
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`contention that the Tuneable Resonant Circuit is inexorably linked to the source coils
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`Petitioner’s Reply
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`and that the circuits are thus tuned to resonance.”).
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`In addition, the Petition also cites O’Brien’s Chapter 7, which describes an
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`experimental validation of the described system in Chapters 5 and 6, as further
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`evidence that O’Brien discloses the claimed “source resonator.” Pet. 19-20; O’Brien
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`139-40. There, O’Brien describes in detail that its source coils are connected to
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`tuning circuits, and together are tuned to resonance as a “source side system.” See
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`also Inst. Dec. 19-20.
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`Patent Owner also omits other annotated figures in the Petition and supporting
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`declaration of Dr. Allen showing the Petition’s consistent mapping of O’Brien’s
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`“source coil” and connected “tuning circuit” as together forming the claimed “source
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`resonator.” For example, challenged dependent claims 5-7 and 19-21 further require
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`a plurality of “source resonators” and/or “second resonators.” The Petition
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`explained that O’Brien discloses such a configuration in the context of annotated
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`Figure 6-1, reproduced below, where the Petition specifically annotated the claimed
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`“resonators” as inclusive of O’Brien’s “tuning circuit” and the inductor circuit
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`element representing the source coil.
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`Petitioner’s Reply
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`Pet. 37; see also id. 35 (explaining that independent “claims 1 and 15 are
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`unpatentable for the same reasons as their dependent claims”). The Petition also
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`explained in words that “each source resonator includes an inductor, resistor, and
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`tuning circuit (e.g., a capacitor).” Pet. 36. The “inductor” of each “source resonator”
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`is O’Brien’s source coil. See Allen Decl. ¶¶ 116-117 (Ex. 1003); O’Brien 13
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`(defining “L” as “Self inductance of a coil”).
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`In sum, Patent Owner’s only argument that the Petition fails to disclose the
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`“source resonator” limitations is based on its misreading of O’Brien and the Petition
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`as excluding the “source coil” from the Petition’s mapping of the “source resonator.”
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`The Board should reject Patent Owner’s argument because Patent Owner
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`misinterprets the Petition and O’Brien, and fails to address Petitioner’s analysis,
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`which is not limited to Figure 5-1. Inst. Dec. 17-20; see SHDS, Inc. v. Truinject
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`Corp., IPR2020-00935, Paper 30 at 37 (P.T.A.B. Nov. 15, 2021) (rejecting “Patent
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`Petitioner’s Reply
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`Owner’s myopic focus on a single statement in the Petition” because it “does not
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`address adequately Petitioner’s analysis”).
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`2. O’Brien discloses the claimed “second resonator”
`As with the “source resonator” limitations, Patent Owner mischaracterizes
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`what the Petition relies on as the claimed “second resonator” in O’Brien. The
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`Petition maps the “Resonant Circuit,” including its receiving coil, to the claimed
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`second resonator. Pet. 20-24; Inst. Dec. 20-22. Patent Owner argues O’Brien’s
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`“receiving coil” and “Resonant Circuit” on the receive side are “separate
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`components” and the Petition excludes the receiving coil from the claimed “second
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`resonator.” See POR 3-6. Patent Owner premises this argument entirely on
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`Petitioner’s annotations to Figure 5-1. Id. But Figure 5-1 is not all that the Petition
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`says about the “second resonator.” Patent Owner ignores the remainder of the
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`Petition’s analysis, which demonstrate that O’Brien’s receiving coil is part of and
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`inextricably linked to the Resonant Circuit. See Pet. 20-22.
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`For example, the Petition explained that the components of the receive side
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`“Resonant Circuit” in Figure 5-1 are depicted and described in O’Brien’s Chapter 6.
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`Pet. 20-21. There, O’Brien describes that the “tuned circuit” in the receiver side of
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`the system (i.e., the “Resonant Circuit” of Figure 5-1) together with the “tuned
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`circuit” on the source side of the system (i.e., the “Tuneable Resonant Circuit”) form
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`the “Loosely Coupled Transformer,” meaning that the “Resonant Circuit” includes
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`Petitioner’s Reply
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`the receive coils. O’Brien 114. Indeed, O’Brien explains that the “receiver side
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`resonant circuit” includes a receiving coil arranged in parallel with a capacitor Cr to
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`form a “parallel resonant circuit.” Pet. 21-22, citing O’Brien 133 (Section 6.6.2
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`entitled “Receiver side resonant circuit” explaining the “receiver-side resonant
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`capacitance Cr is tuned to compensate the self-inductance of the receiving coils”),
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`114-15, 115-18; see also, e.g., id. 134 (“the receiver side parallel resonant circuit
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`with one coil”). Next, the Petition cited pages from Chapter 7 of O’Brien, where
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`O’Brien taught that its “resonant circuit” on the receive side includes the receiving
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`coils and a tuning circuit. Pet. 21-22, citing O’Brien 141-42 (showing “equivalent
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`circuit of receiver used for tests” and stating “each receiving coil … is separately
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`compensated and tuned to the system’s operating frequency”). The Petition also
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`consistently annotated the receiving coils and tuning circuit(s) on the receive side
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`together as disclosing the claimed “second resonator” in the context of dependent
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`claims 5-7 and 19-21. Pet. 37 (annotating O’Brien Fig. 6-1 to include the receiving
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`inductor coils as part of the “second resonator”); see also id. at 35 (“[C]laims 1 and
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`15 are unpatentable for the same reasons as their dependent claims.”).
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`The Petition also cited—in the context of the “source resonator” and “second
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`resonator” limitation [b]—O’Brien’s disclosure of the large air-gap in the magnetic
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`path that separates the “receivers” (which as argued by Patent Owner, means the
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`receiver coils) from the “sources” (which means the source coils). Pet. 22, citing
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`Petitioner’s Reply
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`O’Brien 19; see POR 5-6; Inst. Dec. 22 (acknowledging that Patent Owner contends
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`“receivers” in O’Brien means receiving coils and “sources” means source coils).
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`The Petition also pointed out O’Brien’s disclosure of the distance between “source
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`and receiver” for near-field energy transfer, i.e., between the source coil and the
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`receiver coil, as disclosing near field energy transfer between the claimed “source
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`resonator” and “second resonator.” Pet. 22, citing O’Brien 23, Fig. 2-3.
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`Accordingly, as the Board preliminarily found, the Petition’s “disclosures address
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`the receiver coils and their distance from the source coils, dispelling the notion that
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`Petitioner only relies on resonant circuits on the receiver side, without the
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`corresponding receiver coils.” Inst. Dec. 22. Patent Owner provides no response to
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`this evidence.
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`In sum, Patent Owner’s argument that the Petition failed to prove that O’Brien
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`disclose the “coupling” limitation (element [c]) is based only on its misreading of
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`the Petition’s annotations to Figure 5-1 as excluding O’Brien’s “source coil” and
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`“receiving coil” from the claimed source resonator and second resonator in elements
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`[a] and [b]. Because Patent Owner ignores what the Petition reasonably conveys,
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`Patent Owner’s argument should be rejected. Inst. Dec. 20-24. O’Brien discloses
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`the claimed “source resonator” and “second resonator.”
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`Petitioner’s Reply
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`B. O’Brien discloses the “shaping” requirement of claim 1
`Claim 1 further requires “the field of at least one of the source resonator and
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`the second resonator is shaped using a conducting material and a magnetic material.”
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`’935 patent cl. 1 (Ex. 1001). The Petition demonstrated that O’Brien discloses this
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`limitation because it taught a source field created by its source resonator is shaped
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`by (1) conducting materials and surfaces, (2) magnetic materials, and (3) conducting
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`materials coated with a layer of magnetic materials. Pet. 24-35.
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`Patent Owner disagrees, arguing that O’Brien does not disclose the shaping
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`feature because claim 1 is a “system” claim and so the shaping feature requires a
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`disclosure of “intentionally shield[ing] devices or components.” POR 7-8. Patent
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`Owner is wrong for two reasons.
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`First, Patent Owner does not articulate any factual or legal basis for importing
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`its “intentionally shield[ing] devices or components” limitation into the claims.
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`Indeed, no limitation of claim 1 recites a “device” or “component” separate from the
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`“source resonator” and “second resonator.” See ’935 patent cl. 1. The shaping
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`feature requires only a conducting material and a magnetic material that shape the
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`field of the source or second resonator. O’Brien discloses this. Pet. 24-35; Inst. Dec.
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`26 (“In sum, we are persuaded that Petitioner’s arguments and evidence show, at this
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`juncture, that the shape of the source field is shaped using conducting material coated
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`with a layer of magnetic material.”).
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`Petitioner’s Reply
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`Second, whether O’Brien actually designed a system using a conducting
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`material and a magnetic material to shape a source field is irrelevant. Anticipation
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`does not require “actual performance of suggestions in a disclosure.” See Bristol-
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`Myers Squibb Co. v. Ben Venue Labs., Inc., 246 F.3d 1368, 1379 (Fed. Cir. 2001).
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`Here, Patent Owner admits O’Brien discloses that components can be “shielded”
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`(see POR 7-8) by shaping the field of a source resonator, which is all that is needed
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`to disclose the shaping feature. The Petition and Dr. Allen also explained how
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`O’Brien discloses—in detail—that the field generated by a source resonator in
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`O’Brien’s “system” would be shaped by conducting and magnetic materials. Pet.
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`24-35; Allen Decl. ¶¶ 90-110.
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`For the reasons discussed here and in the Petition, O’Brien anticipates claims
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`1, 5-8, 15, and 19-22.
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`III. Ground 2: Claims 1-23 would have been obvious over O’Brien in view
`of Haaster
`The Petition establishes in Ground 2 that the combination of O’Brien and
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`Haaster also renders claims 1-23 obvious. Patent Owner challenges the combination
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`only with respect to independent claims 1 and 15.
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`Patent Owner first argues that Ground 2 “suffers from the same issues as
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`Ground 1” with respect to the “source resonator” and “second resonator” elements
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`[a]-[c]. POR 7. Those arguments are wrong for the reasons discussed above with
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`respect to Ground 1. See supra Sections II.A-B.
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`Petitioner’s Reply
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`Patent Owner also argues the Petition has not shown the combination of
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`O’Brien and Haaster renders obvious claim 1’s shaping feature discussed in the
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`immediately preceding section. POR 7-8. According to Patent Owner, the shaping
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`limitation requires “intentionally shield[ing] devices and components.” Id. That
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`interpretation is wrong as discussed above.
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`But even if the Board reads in a “devices and components” requirement,
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`O’Brien in view of Haaster renders obvious the shielding feature for the reasons
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`discussed in the Petition. Pet. 44-50. For example, Haaster teaches the use of an
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`EMI shield to “attenuate a transfer of electromagnetic energy with respect to the
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`shielded device” and otherwise protect devices from electromagnetic interference.
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`Haaster ¶¶ 10, 3-5 (Ex. 1008); Pet. 51-53. Patent Owner makes three arguments that
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`a POSA would not have applied Haaster’s shielding of devices in O’Brien. All three
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`fail.
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`First, Patent Owner states that “nowhere does Haaster describe that its
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`shielding ‘shapes’ a magnetic field.” POR 8. But “the reference need not satisfy an
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`ipsissimis verbis test.” In re Gleave, 560 F.3d 1331, 1334 (Fed. Cir. 2009). Haaster
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`does not use the term “shaping,” but instead describes that its shielding will
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`“attenuate” a transfer of electromagnetic energy by reflecting and absorbing a
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`magnetic field. Dr. Allen’s unrebutted testimony establishes that a POSA would
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`IPR2021-01166 (USP 8,304,935)
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`have understood this as “shaping” a magnetic field. Pet. 51-52; Allen Decl. ¶¶ 155-
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`Petitioner’s Reply
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`156.
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`Second, Patent Owner argues “Petitioner has not shown that Haaster’s”
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`shielding would “even be suitable for shaping the magnetic field” in O’Brien.
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`POR 9 (emphasis omitted). Patent Owner is wrong. As detailed in the Petition and
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`the unrebutted testimony of Dr. Allen, Haaster discloses that its conductive shielding
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`could be formed from, for example, copper or aluminum, which are the same
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`conducting shielding materials that O’Brien taught would shape a source field at its
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`disclosed operating frequency. Pet. 52-53. Likewise, the “lossy” material used for
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`Haaster’s shield could be formed from ferrite, which is a “permeable magnetic
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`material” that O’Brien taught would shape its source field. Id. at 53.
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`Third, Patent Owner asserts that “Petitioner has not shown that a POSITA
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`would have had a reasonable expectation of success in performing the combination,
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`nor that a POSITA would have looked to techniques for blocking EMI noise in the
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`context of wireless power transfer.” POR 9. Patent Owner’s conclusory and
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`unsupported attorney argument should be disregarded. The Petition, supported by
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`the analysis of Dr. Allen, explains why “a POSA could have and would have
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`combined the teachings of O’Brien and Haaster to intentionally shield electronics or
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`other devices, while minimizing source field attenuation and the use of expensive
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`magnetic (e.g., ferrite) materials.” Pet. 44-50.
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`Petitioner’s Reply
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`For the reasons discussed here and in the Petition, O’Brien in view of Haaster
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`renders obvious challenged claims 1-23.
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`IV. Conclusion
`For the reasons above and in the Petition, the challenged claims are
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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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`unpatentable.
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`Dated: July 8, 2022
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`Petitioner’s Reply
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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 the Petitioner’s Reply contains 2,923
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`words using Microsoft Word’s counting feature, plus 28 words hand-counted in the
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`imaged text, for a total of 2,951 words, excluding the cover page, signature block,
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`and the parts of the Petitioner’s Reply exempted by 37 C.F.R. § 42.24(c).
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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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`Dated: July 8, 2022
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`IPR2021-01166 (USP 8,304,935)
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`Petitioner’s Reply
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 8th day of July, 2022,
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`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.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Telephone: 214.747.5070
`Fax: 877.769.7945
`Email: IPR25236-0267IP1@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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`IPR2021-01166 (USP 8,304,935)
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`Petitioner’s Reply
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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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`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, DC 20004-1304
`Telephone: 202.637.2200
`Fax: 202.637.2201
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`Counsel for Petitioner
`Momentum Dynamics Corporation
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