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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________________
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`COOLIT SYSTEMS, INC.,
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`Petitioner,
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`v.
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`ASETEK DANMARK A/S,
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`Patent Owner.
`_____________________________
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`IPR2021-01196
`U.S. Patent 10,599,196
`_____________________________
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`
`DECLARATION OF DAVID TUCKERMAN, PH.D., IN SUPPORT OF
`PATENT OWNER’S PRELIMINARY RESPONSE
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`I.
`II.
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`TABLE OF CONTENTS
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`QUALIFICATION AND EXPERIENCE ....................................................... 2
`LEGAL STANDARDS ................................................................................... 5
`A.
`Claim Construction................................................................................ 5
`B. Anticipation ........................................................................................... 6
`C. Obviousness ........................................................................................... 6
`III. DEFINITION OF A PERSON OF ORDINARY SKILL IN THE ART ........ 9
`IV. THE ’355 PATENT .......................................................................................10
`V.
`THE DUAN REFERENCE ...........................................................................14
`VI. CLAIM CONSTRUCTION ..........................................................................16
`VII. DUAN DOES NOT DISCLOSE ALL LIMITATIONS OF CLAIM 1 ........19
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`i
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
`
`
`I, David B. Tuckerman, declare as follows:
`
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`1. I have been retained by Finnegan, Henderson, Farabow, Garrett & Dunner
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`LLP (“Finnegan”) on behalf of Asetek Danmark A/S (“Asetek”) as an expert
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`in the field of liquid cooling of computers and servers. This Declaration is in
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`support of the Inter Partes Review of U.S. Patent No. 10,599,196 to André
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`Eriksen (“the ’196 patent”).
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`2. I am being compensated at the rate of $475.00 per hour for my work on this
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`matter. My compensation in no way depends on the outcome of this
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`proceeding, the content of my testimony, or any issues involved in or related
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`to this proceeding. In preparing this Declaration, I reviewed and considered
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`the ’196 patent, the prosecution history of the ’196 patent, the Petition, Dr.
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`Pokharna’s declaration, and the Duan prior art reference that I discuss in this
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`Declaration. In addition to these materials, I may consider additional
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`documents and information in forming any supplemental opinions. To the
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`extent I am provided additional documents or information, including any
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`additional expert declarations filed by Petitioner in this proceeding, I may
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`offer further opinions.
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`3. Based on my experience, knowledge of the art at the relevant time, analysis
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`of prior art references, and the understanding a person of ordinary skill in the
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`1
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`art would have of the claim terms in light of the specification, it is my opinion
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`that claims 1 and 2 of the ’196 patent are not unpatentable based on the prior
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`art references discussed below.
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`I.
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`QUALIFICATION AND EXPERIENCE
`4. I have B.S. degrees in Electrical Engineering and Physics, and M.S. in
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`Electrical Engineering and Computer Science from Massachusetts Institute of
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`Technology, Cambridge, Massachusetts. I also have a Ph.D. in Electrical
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`Engineering and a M.B.A. from Stanford University, Stanford, CA. My Ph.D.
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`thesis, titled “Heat-Transfer Microstructures for Integrated Circuits,” focused
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`on developing new, high-performance liquid-cooled heat sinks for thermal
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`management of high-speed integrated circuits, and received the Fannie and
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`John Hertz Foundation Hertz Thesis Prize. The key results in my Ph.D. thesis
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`were published in the peer-reviewed journal IEEE Electron Device Letters
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`with the title “High-Performance Heat Sinking for VLSI”, and this publication
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`has so far received over 5000 citations in the professional literature, as
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`reported by Google Scholar. This paper was selected by the IEEE Electron
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`Devices Society to receive the first “Paul Rappaport Award”, although this
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`new award series did not get officially approved by IEEE until 1983.
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`2
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`5. I am an experienced innovator and inventor with over 120 issued U.S. patents,
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`many foreign patents, and numerous pending applications, spanning the fields
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`of thermal management systems, heat transfer, electronic packaging and
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`interconnect technologies, and superconducting devices and circuits, etc.
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`6. I was a member of the Josephson junction computer project (superconducting
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`logic circuit design, simulation, and testing) while attending M.I.T., and
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`worked as a project leader at Lawrence Livermore National Laboratory
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`(LLNL), supervising and managing advanced R&D programs in various fields
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`including electronic packaging and interconnect. My PhD thesis work on
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`microchannel was applied by researchers at LLNL to cool high-power laser
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`diodes; this work was published in the peer-reviewed journal Applied Physics
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`Letters.
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`7. I founded nCHIP, Inc. in 1989, focusing on advanced multi-chip module
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`technologies enabling ultracompact high-performance digital systems, which
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`was later sold to Flextronics International Ltd. in 1995.
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`8. I am an experienced entrepreneur, venture capitalist, and executive leader
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`with over 20 years of experience founding, growing and leading technology
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`companies. While working as a senior VP and CTO of Tessera Inc., I helped
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`3
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`Tessera grow via various acquisitions, one of which led to the development
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`of a new technology for silent air cooling of laptop computers.
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`9. I was elected by the IEEE to the grade of “IEEE Fellow”, which is the highest
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`membership grade, and for which selection is limited to less than 0.1% of the
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`IEEE membership each year. I was specifically cited “for contributions to
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`high-performance electronic packaging and interconnection technologies,
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`including the development of the microchannel heat sink.”
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`10. I was keynote speaker at the 9th International Conference on Nanochannels,
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`Microchannels, and Minichannels (ICNMM), invited because of my
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`pioneering work in the field of microchannel cooling. I was also co-author of
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`a review article on Heat Transfer in Microchannels in the peer-reviewed
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`Journal of Heat Transfer.
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`11. I am a licensed Professional Engineer in California.
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`12. I am currently an independent consultant through my own company
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`Tuckerman & Associates, Inc., working on various technical and intellectual
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`property matters in the high-tech industries. Some of my major clients have
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`included CMEA Capital, Tessera, Intellectual Ventures, and Microsoft. I have
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`consulted for Microsoft’s Quantum Computing and “Cold Logic” programs
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`for 9 years (2011-2020), including management of a 6-year research contract
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`4
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`with Auburn University to develop high-density flexible thin-film cryogenic
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`interconnect having optimal heat-transfer properties (i.e., minimal heat
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`leakage between temperature stages) while maintaining excellent electrical
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`performance. I was also a consultant for the first phase of Microsoft’s “Project
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`Natick” (which implemented a demonstrative underwater datacenter off the
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`southern California coast in 2015), including the design of the heat exchanger
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`structures and the subsequent analysis of its actual undersea performance.
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`13. Attached as Exhibit A to this Declaration is a copy of my CV, which provides
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`a detailed listing of my publications and patents, as well as my education and
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`experience.
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`II. LEGAL STANDARDS
`A. Claim Construction
`14. I have been informed by counsel and I understand that the first step in
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`determining the patentability of a patent claim is for the claim terms to be
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`properly construed. I understand that in the related district court litigation
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`involving the ’196 patent, certain claim terms have been construed. I agree
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`with those claim constructions. All other terms should be given their plain and
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`ordinary meaning as understood by those skilled in the art.
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`5
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`B. Anticipation
`15. I am not an attorney and have not been asked to offer my opinion on the law.
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`However, as an expert offering an opinion on whether the claims of the ’196
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`patent are unpatentable, I have been told that I am obliged to follow existing
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`law.
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`16. I have been told the following legal principles apply to an analysis of
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`patentability pursuant to 35 U.S.C. § 102, a provision in the patent law
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`regarding anticipation. I have been told that, in an inter partes review
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`proceeding, patent claims may be deemed unpatentable if it is shown by
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`preponderance of the evidence that the claims were anticipated by prior art
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`patents or printed publications.
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`17. I have been told that for a claim to be anticipated under § 102, every limitation
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`of the claimed invention must be disclosed by a single prior art reference,
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`viewed from the perspective of a person of ordinary skill in the art.
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`C. Obviousness
`18. I have been told that under 35 U.S.C. § 103(a), “[a] patent may not be obtained
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`although the invention is not identically disclosed or described as set forth in
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`section 102, if the differences between the subject matter sought to be patented
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`and the prior art are such that the subject matter would have been obvious at
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`6
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`the time the invention was made to a person having ordinary skill in the art to
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`which said subject matter pertains.”
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`19. When considering the issues of obviousness, I have been told that I am to do
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`the following:
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`a. Determine the scope and content of the prior art;
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`b. Ascertain the differences between the prior art and the claims at issue;
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`c. Resolve the level of ordinary skill in the pertinent art; and
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`d. Consider evidence of secondary indicia of non-obviousness (if
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`available).
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`20. I have been told that the relevant time for considering whether a claim would
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`have been obvious to a person of ordinary skill in the art is the time of alleged
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`invention, which I have assumed is shortly before the effective filing date of
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`the application leading to the ’196 patent.
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`21. I have been told that any assertion of secondary indicia of non-obviousness
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`must be accompanied by a nexus between the merits of the invention and the
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`evidence offered.
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`22. I have been told that a reference may be combined with other references to
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`disclose each element of the invention under § 103. I have been told that a
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`reference may also be combined with the knowledge of a person of ordinary
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`7
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`skill in the art and that this knowledge may be used to combine multiple
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`references. I have also been told that a person of ordinary skill in the art is
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`presumed to know the relevant prior art. I have been told that the obviousness
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`analysis may account for the inferences and creative steps that a person of
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`ordinary skill in the art would employ.
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`23. I have been told that whether a prior art reference renders a patent claim
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`unpatentable as obvious is determined from the perspective of a person of
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`ordinary skill in the art. I have been told that there is no requirement that the
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`prior art contain an express teaching or suggestion to combine known
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`elements to achieve the claimed invention, but that a motivation or rationale
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`for combining prior art elements in a way that realizes the claimed invention
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`is required to show obviousness, and that it seeks to counter impermissible
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`hindsight analysis.
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`24. I have been told that when a work is available in one field, design alternatives
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`and other market forces can prompt variations of it, either in the same field or
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`in another. I have been told that if a person of ordinary skill in the art can
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`implement a predictable variation and would see the benefit of doing so, that
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`variation is likely to be obvious. I have been told that, when there is a design
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`need or market pressure and there are a finite number of predictable solutions,
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`8
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`a person of ordinary skill in the art has good reason to pursue those known
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`options that realizes the claimed invention. In addition, I have been informed
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`and I understand that there must be a reasonable expectation of success—not
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`absolute predictability of success—in combining prior art teachings to arrive
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`at the claimed invention.
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`III. DEFINITION OF A PERSON OF ORDINARY SKILL IN THE ART
`25. The ’196 patent has an effective filing date of May 6, 2005. A person having
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`ordinary skill in the field of liquid cooling systems at that time (i.e., in May
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`2005) would have
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`(i) completed college
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`level course work
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`in
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`thermodynamics, fluid mechanics, and heat transfer, and (ii) attained two or
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`more years of experience in designing liquid cooling systems for computers,
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`servers, or other electronic devices, or very similar technology. Alternatively,
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`a person with a more advanced degree in the above fields may have had less
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`practical experience and be a person of ordinary skill in the art.
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`26. I believe that I have the relevant experience and understanding of one of
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`ordinary skill in this field.
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`27. The claims of the ’196 patent are not unpatentable under either Petitioner’s
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`definition of a “POSITA” (Pet., 9), or my definition given above.
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`9
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`IV. THE ’355 PATENT
`28. Computers (and particularly their central processing units, or “CPUs”)
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`generate heat during operation, and as CPU performance increases, so does
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`heat generation. The performance of a computer CPU chip is proportional to
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`the density of the circuits and the clock speed. The greater the circuit density
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`and clock speed, the greater the performance of the CPU. As CPU
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`performance increases, so does the amount of heat generated by the CPU, and
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`also the need for efficient and effective dissipation of the heat generated by
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`the CPU. This is true for both personal computers (desktops, laptops,
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`netbooks, etc.) and computer servers/data centers.
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`29. There are various air cooling and liquid cooling methods to manage heat in a
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`computer system. While air cooling systems are cheaper and easier to install,
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`air cooling has a fundamental limit in heat density, and this limit is surpassed
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`in many high-end applications, often necessitating a shift towards liquid
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`cooling systems. Liquid cooling systems are more efficient at heat removal
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`than air cooling systems. Prior art liquid cooling systems, however, were
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`bulky and posed significant risk of leakage because they comprised several
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`separate components (such as a heat exchanger, a liquid reservoir, a pump,
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`10
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`and a heat radiator) coupled together using tubes, as shown in Prior Art Figure
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`3 of the Asetek patents (depicted below).
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`
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`30. The ’196 patent discloses many technological advances in the art of computer
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`liquid cooling. Among other things, Asetek’s patented technology disclosed
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`in the ’196 patent is a significant advancement from the modular approach of
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`the prior art liquid cooling devices. Figures 17 and 20 of the ’196 patent
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`represent embodiments of the claimed invention. As evident from the patent
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`claims and the figures, Asetek’s claimed invention has, among other features,
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`a pump unit that combines a pump, a dual-chambered “reservoir,” and a “heat-
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`exchanging interface” (i.e., a cold plate) into a single component. The
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`reservoir in Asetek’s patented design is divided into two chambers, referred
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`11
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`to as the “pump chamber” and “thermal exchange chamber,” as shown in
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`Figure 20 (annotated below). The chambers are vertically spaced apart and are
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`fluidly coupled together to allow for heat dissipation from the CPU via the
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`“heat exchanging interface,” which forms the boundary wall of the thermal
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`exchange chamber, and which is placed in thermal contact with the CPU. This
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`novel and innovative configuration, among other features of the patented
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`inventions, enables separate and independent optimization of the pumping
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`function in the pump chamber and the heat transfer function in the thermal
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`exchange chamber.
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`12
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`31. In exemplary embodiments disclosed and claimed in the ’196 patent, the
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`pump chamber is defined by a double-sided chassis and an impeller cover. For
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`example, in the preferred embodiment shown in Figures 17 and 20, pump
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`chamber 46 is defined by a double-sided chassis on the top and impeller cover
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`46A on the bottom. See ’196 patent, 23:1-29. Cooling liquid enters pump
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`chamber 46 through an inlet in impeller cover 46A, the inlet being positioned
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`below the rotational center of an impeller 33 housed in the pump chamber.
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`See id. at 23:1-29, Figs. 17 and 20. Cooling liquid exits pump chamber 46
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`through an outlet 34 provided in impeller cover 46A, the outlet being
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`positioned tangentially to the circumference of impeller 33. Id. Thermal
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`exchange chamber 47A is defined between pump chamber 46 and heat
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`exchange interface 4. See id. at Figs. 17 and 20.
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`32. In addition to improved efficiency and compactness, Asetek’s patented
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`designs have greatly reduced and/or eliminated the risk of coolant leakage and
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`have enabled pre-filled (factory assembled) liquid cooling products that are
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`easy to install by users. The novel and innovative concepts disclosed in the
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`’196 patent have also made manufacturing of liquid cooling products simpler
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`and less costly.
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`13
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`V. THE DUAN REFERENCE
`33. The only ground applicable to claims 1 and 2 is Ground 1 (obviousness based
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`on Duan). Accordingly, Duan (Ex. 1004) is the only reference I have
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`discussed in this Declaration.
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`34. Duan discloses a “cooling plate module” for cooling a central processing unit
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`(CPU). Ex. 1004, ¶[0002]. Duan’s “cooling plate module” includes a “cooling
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`plate [] integrally formed with [a] liquid driving module such that the layout
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`of the cooling plate module can be minimized to reduce space.” Id. at ¶[0007].
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`The “liquid driving module” includes an “accommodation chamber” and a
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`“liquid driving unit.” Id. at ¶[0009]. The “liquid driving unit” drives the
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`coolant through a cooling loop comprising the “cooling plate module” and a
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`“water tank module” that cools heated coolant. Id. at ¶¶[0009], [0010].
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`35. Figure 6, annotated below, shows Duan’s cooling plate module 10 in
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`communication with water tank module 20 through ducts. Id. at ¶[0022].
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`Cooling plate module 10 includes a cooling plate 1 and a liquid driving
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`module 2, which comprises an accommodation chamber 21 and a liquid
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`driving unit 22 located in accommodation chamber 21 and configured to drive
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`the coolant (accommodation chamber 21 and liquid driving unit 22 are not
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`annotated in the figure below but are included in liquid driving module 2). Id.
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`14
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`at ¶¶[0022], [0023]. The coolant collects heat from CPU 200 at cooling plate
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`1, which has a heat absorbing face 11 in thermal contact with the CPU. Ex.
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`1004, Fig. 6 (annotated below), ¶[0022]. The heated coolant flows to water
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`tank module 20 where the coolant is cooled, and the cooled coolant flows back
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`to the liquid driving module 2 and then to cooling plate 1. Id. at Fig. 6,
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`¶¶[0022], [0027], [0028].
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`36. Cooling plate 1 is assembled with a cap 3 to define a closed space therein
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`(the alleged “thermal exchange chamber”). Id. at ¶[0023], Fig. 7 (not shown);
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`15
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`Ex. 1003, ¶61. Heat-dissipating plates 12 are located in the cap. Ex. 1004,
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`¶[0024]. Liquid driving unit 22 (included in accommodation chamber 21 of
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`liquid module 2) has a lower cover 225, which includes a liquid inlet 23
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`through which cooled coolant from the water tank module 20 enters
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`accommodation chamber 21 and is driven by liquid driving unit 22. Ex. 1005,
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`¶¶[0023], [0027]. According to Dr. Pokharna, lower cover 225 and
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`accommodation chamber 21 together form the claimed “pump chamber.” Ex.
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`1003, ¶¶55, 57. Coolant in accommodation chamber 21 flows to cap 3
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`through first liquid outlet 24. Ex. 1004, Fig. 8, ¶[0027]. The coolant collects
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`heat from heat-dissipating plates 12 in cap 3. Id. at ¶[0027]. Cap 3 includes a
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`second liquid outlet 31 through which heated coolant exits and flows to water
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`tank module 20. Id. at Figs. 6 and 8, ¶[0023].
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`37. According to Petitioner’s expert, Dr. Pokharna, the combination of
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`accommodation chamber 21, lower cover 225, cap 3, and cooling plate 1
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`forms the claimed “reservoir.” Ex. 1003, ¶¶51-53.
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`VI. CLAIM CONSTRUCTION
`In my opinion, only the limitation “a first passage fluidly coupling the pump
`38.
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`chamber and the thermal exchange chamber, wherein the first passage is
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`configured to direct the cooling liquid from the outlet of the pump chamber
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`16
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`into the thermal exchange chamber between a first end and a second end of
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`the thermal exchanger chamber” of claim 1 requires review and determination
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`by the Board because Petitioner is misinterpreting the meaning of this claim
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`limitation and applying it to Duan incorrectly.
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`39. To a person skilled in the art, this limitation in claim 1 of the ’196 patent
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`would mean that the first passage, which fluidly couples the pump chamber
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`and the thermal exchange chamber, is so configured that cooling liquid enters
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`the thermal exchange chamber at a location between a first end and a second
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`end of the thermal exchange chamber.
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`40. This interpretation is fully support by the specification of the ’196 patent. The
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`preferred embodiment shown in Figure 17 (annotated below) shows that the
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`“first passage 48 for leading cooling liquid from the pump chamber 46 to a
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`thermal exchange chamber 47A” is provided between a first end and a second
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`of thermal exchange chamber 47A. See generally ’196 patent, 23:1-29. In
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`contrast, the “second passage 49 for leading cooling liquid from the thermal
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`exchange chamber 47A” is provided at the end of the thermal exchange
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`chamber (as recited in claim 2).
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`17
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`41.
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`I disagree with Dr. Pokharna that “[t]here is no claim language that directly
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`provides the location of the first passage itself” and that the first passage must
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`only be “configured to direct the cooling liquid between two ends of the
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`thermal exchange chamber.” Ex. 1003, ¶46 (emphasis in original). Dr.
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`Pokharna’s interpretation disregards the term “into” in the claim limitation.
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`Specifically, this claim limitation specifies that cooling liquid is directed “into
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`the thermal exchange chamber between a first end and a second end of the
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`thermal exchanger chamber,” thus providing a location where the first passage
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`18
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`connects with the thermal exchange chamber. Dr. Pokharna’s interpretation
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`that this limitation means cooling liquid is directed “between two ends of the
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`thermal exchange chamber” (see id.) disregards the positional requirement of
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`the first passage relative to the thermal exchange chamber that is imposed by
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`the word “into” in the claim limitation.
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`42.
`
`If Dr. Pokharna’s interpretation is accepted, then the preferred embodiment
`
`shown in Figure 17 (annotated above) will be excluded from the claim scope
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`because in the embodiment shown in Figure 17, cooling liquid is not directed
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`from one end of the thermal exchange chamber to the other end, rather cooling
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`liquid is directed into the thermal exchange chamber at a location between the
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`first and second ends and cooling liquid then spreads outwardly from that
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`entry location towards the ends of the thermal exchange chamber.
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`VII. DUAN DOES NOT DISCLOSE ALL LIMITATIONS OF CLAIM 1
`43. Duan does not disclose the limitation “a first passage fluidly coupling the
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`pump chamber and the thermal exchange chamber, wherein the first passage
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`is configured to direct the cooling liquid from the outlet of the pump chamber
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`into the thermal exchange chamber between a first end and a second end of
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`the thermal exchanger chamber” of claim 1. This is because Duan does not
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`disclose cooling liquid entering into the thermal exchange chamber “between”
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`19
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`the ends of the thermal exchange chamber. Instead, as shown in Figures 6 and
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`8 of Duan, the Duan device has end-to-end flow in the alleged thermal
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`exchange chamber, which requires cooling liquid to enter at one end of the
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`thermal exchange chamber and exit at the opposite end.
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`44. Specifically, Dr. Pokharna maps the “first passage” to first liquid outlet 24 of
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`Duan. Ex. 1003, ¶70. But as his own annotations (on page 63 of his
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`Declaration) show, outlet 24 is located at the first end of Duan’s alleged
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`thermal exchange chamber; outlet 24 is not located between the first and
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`second ends of the alleged thermal exchange chamber. Therefore, outlet 24 is
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`not configured to direct cooling liquid “into the thermal exchange chamber
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`between a first end and a second end of the thermal exchanger chamber” as
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`required by claim 1. Therefore, this limitation of claim 1 is not disclosed or
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`suggested by Duan. Accordingly, claim 1 is not rendered obvious by Duan.
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`45.
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`If Dr. Pokharna or CoolIT argues that outlet 24 is located between the ends of
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`Duan’s alleged thermal exchange chamber, then by that same logic, second
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`liquid outlet 31 (which Dr. Pokharna maps to the “second passage” of claim
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`2) cannot be at the end of the thermal exchange chamber and would instead
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`be positioned in between the two ends. See Ex. 1003, pp. 65, 67. That is, Duan
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`20
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`IPR2021-01196
`U.S. Patent No 10,599,196
`Declaration of D. Tuckerman
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`cannot simultaneously satisfy both the last limitation of claim 1 and the
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`limitation in claim 2.
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`46.
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct, that all statements made herein
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`of my knowledge are true, and that all statements made on information and
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`belief are believed to be true, and that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable
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`by fine or imprisonment, or both, under Section 1001 of Title 18 of the United
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` Respectfully submitted,
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`By:__________ ______ ___
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` David B. Tuckerman, Ph.D.
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`States Code.
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`Dated: September 30, 2021
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`21
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`EXHIBIT A
`EXHIBIT A
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`Asetek Exhibit 2013 - Page 24 of 36
`CoolIT v. Asetek - IPR2021-01196
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`

`

`David B. Tuckerman
`3 Wellesley Ct
`Lafayette CA 94549
`Cell: 415-298-4040
`d.tuckerman@comcast.net
`
`
`EXPERIENCE:
`
`Tuckerman & Associates, Inc., 2009-present: Independent consultant on a variety of
`technical and IP matters in high-tech industries. Major clients have included CMEA
`Capital, Tessera, Intellectual Ventures, and Microsoft. Consultant to Microsoft’s
`quantum computing program from 2011 through 2020, including management of a 6-year
`research contract with Auburn University to develop high-density flexible thin-film
`superconducting interconnect for quantum computing applications.
`
`Tessera Inc., 2003-2009: Senior Vice President and Chief Technical Officer. Member
`of the executive team that executed a successful IPO in November 2003, with a market
`capitalization that later exceeded $1 billion. Responsible for managing R&D activities
`and generating intellectual property in electronic packaging and related technologies, and
`for formulating a strategy for growth by acquisition. Identified numerous targets that
`were successfully acquired (North, Shellcase, Digital Optics, Eyesquad, Viewmagic,
`DBlur, Kronos); these acquisitions established Tessera in two new lines of business:
`“Imaging and Optics” (ultraminiature camera modules incorporating extended-depth-of-
`field wafer-scale optics; this ‘OptiML WLC’ technology was winner of an R&D 100
`Award) and “Silent Air Cooling” (fanless, electrostatically driven air cooling, enabling
`quiet ultra-thin laptop computers).
`
`CMEA Capital, 1997 – 2013: Venture Partner at a venture capital firm that has over $1
`billion under management. Responsible for sourcing and screening deals, performing
`due diligence, facilitating syndication, and making ongoing strategic and operational
`contributions to portfolio companies (including participating in Board meetings), for all
`deals having to do with physical technologies (electronics, optics, materials, energy, etc.).
`Primarily investing in technologies related to energy and advanced materials since 2008.
`Currently on Board of Directors of Reel Solar (electroplated CdTe photovoltaic
`technology).
`
`nCHIP, Inc., 1989-1997: Founder, Sr. VP, and Chief Technical Officer. Developed
`advanced multi-chip module technologies enabling ultracompact high-performance
`digital systems. Responsible for all technical development activities prior to transfer to
`manufacturing. nCHIP was financed by venture capital from three top-tier venture funds:
`Kleiner Perkins, Mohr Davidow, and Mayfield. nCHIP grew to approximately $12
`million in annualized revenues, and was sold to Flextronics International Ltd. in 1995
`for $38 million. Venture investors who held their Flextronics stock received up to 40x
`their initial investment.
`
`
`

`

`Lawrence Livermore National Laboratory, 1983-1989: Project Leader, Physics
`Department. Managed advanced R&D programs in laser processing, electronic
`packaging and interconnect, X-ray optics, and other national-defense related programs.
`
`IBM T. J. Watson Research Center, 1977-1980 (MIT Co-op program): Member of the
`Josephson junction computer project (superconducting logic circuit design, simulation,
`and testing). Designed and demonstrated ultrahigh-performance sampling circuitry for
`on-chip diagnostics of superconducting logic.
`
`Consultant to numerous high-technology start-ups over the past 25 years. Previously on
`Board of Directors of Eneco Inc. (thermoelectric technology).
`
`EDUCATION:
`
`M.I.T, B.S. Electrical Engineering, 1980.
`M.I.T., B.S. Physics, 1980.
`M.I.T., M.S. Electrical Engineering & Computer Science, 1980.
`Stanford, Ph.D. Electrical Engineering, 1984.
`Stanford, MBA, 1998.
`
`PUBLICATIONS:
`
`See attached list. 5000+ citations in the professional literature (per Google Scholar)
`
`PATENTS:
`
`120+ issued U.S. patents, plus various foreign patents and numerous pending
`applications.
`
`MAJOR HONORS:
`
`
`Fellow of the IEEE
`IEEE Paul Rappaport Award
`Fannie and John Hertz Foundation Outstanding Ph.D. Thesis
`Consulting Associate Professor of E.E., Stanford University (late 1980’s/early 1990’s)
`
`(co-supervised two PhD theses on ‘laser planarization’)
`Best Paper Award, VLSI Multilevel Interconnection Conference, 1989
`Technical Program Chair, IEEE Multichip Module Conference, 1995
`General Chair, IEEE Multichip Module Conference, 1996
`Plenary speaker, ASME 9th International Conference on Nanochannels, Microchannels,
`and Minichannels, 2011.
`
`
`
`
`

`

`Selected Publications
`
`
`• Tuckerman, D. B., 1978, “Analog Simulator of a Josephson Quantum Interference
`Device”, Review of Scientific Instruments, 49(6), pp. 835-839.
`• Tuckerman, D. B., 1980, “A Josephson Ultrahigh-Resolution Sampling System”,
`Applied Physics Letters, 36(12), pp. 1008-1010.
`• Tuckerman, D. B., and Magerlein, J. H., 1980, “Resonances in Symmetric
`Josephson Interferometers”, A