`U.S. Patent No. 9,843,215
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`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00117
`
`Calmann J. Clements,
`Haynes Boone, LLP
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`Ex.1037 / IPR2022-00117 / Page 1 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`The ’215 Patent
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`Ex.1001, Figs. 5 and 10 (annotated); ’215 Petition at 9.
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`2
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`2
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`’215 Patent, Claim 1
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`Ex.1001, Fig. 10; ’215 Petition at 9.
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`Ex.1001, Claim 1
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`Ground 1: Claims 1, 8-11, 13, 17, and 19-21 are
`obvious over Sawa and Park
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`4
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`4
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`Sawa teaches a plurality of soft magnetic layers
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`Sawa
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`Ex.1005, Fig. 3 (annotated); ’962 Petition at 38.
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`’215 Petition at 32.
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`5
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`5
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`Sawa’s first magnetic thin plate is a soft magnetic layer
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`’215 Petition, 31-32.
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`Sawa’s first magnetic thin plate is a soft magnetic layer
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`Ex.1005, 8:59-9:11; Ex.1003, ¶60; ’215 Petition, 31-32.
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`7
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`Sawa’s first magnetic thin plate materials are soft magnetic materials
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`Sawa
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`Ex.1005, 8:59-9:11; Ex.1003, ¶60; ’215 Petition, 31-32.
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`Patent Evidence
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`Ex.1020, 1:17-20; ’215; Reply, 4.
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`8
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`Sawa’s first magnetic thin plate materials are soft magnetic materials
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`Sawa
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`Ex.1005, 8:59-9:11; Ex.1003, ¶60; ’215 Petition, 31-32.
`Textbook Evidence
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`Ex.1022, Figs 3.1 and 3.2; ’215; Reply, 4.
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`9
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`Sawa’s first magnetic thin plate materials are soft magnetic materials
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`Sawa
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`Ex.1005, 8:59-9:11; Ex.1003, ¶60; ’215 Petition, 31-32.
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`Patent Owner’s Evidence
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`Ex.2019, 36; Reply, 4.
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`10
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`10
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`Sawa’s first magnetic thin plate materials are soft magnetic materials
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`Patent Owner
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`Patent Owner Response, 43.
`Patent Owner’s Expert
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`Petitioner Reply, 15.
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`11
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`11
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`Patent Owner’s argues that Sawa’s magnetic plate is hard to saturate
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`• Patent Owner repeatedly points to Sawa’s first magnetic thin plate as
`being “hard to saturate.”
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`o Response, 22 (Sawa’s “first magnetic plate exhibits hard to saturate
`magnetic characteristics”)
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`o Response, 15 (“it is possible to make the first magnetic thin plate 2 hard to
`be magnetic‐saturated”)
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`o Response, 17‐19 (“a first magnetic plate … should be hard to saturate”)
`‘215 Reply, 7-8.
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`Sawa teaches “a plurality of soft magnetic layers” as claimed
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`Summary
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`• The petition establishes that Sawa teaches soft magnetic layers.
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`• Sawa’s list of materials are well-known soft magnetic materials.
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`• Patent Owner relies on the wrong characteristic to argue that Sawa’s
`first magnetic thin plate 2 is not “soft”
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`’215 Patent, Claim 1
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`Ex.1001, Fig. 10; ’215 Petition at 9.
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`Ex.1001, Claim 1.
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`Sawa teaches the claimed first and second polymeric material layers
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`Petition, 40.
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`The specification of the ’215 patent contemplates a single piece
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`Petition, 42.
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`16
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`Sawa renders obvious precisely what is recited in the claims
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`Petitioner Reply, 22.
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`17
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`Both independent claims, on their face, are apparatus claims
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`Ex.1001, Claim 1.
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`Ex.1001, Claim 13.
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`18
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`Patent Owner’s Product-by-Process construction is taught by Sawa
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`Patent Owner Response, 2.
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`Patent Owner Response, 29.
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`Sawa teaches the claimed first and second polymeric material layers
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`Summary
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`• Sawa teaches precisely what is claimed—magnetic layers
`encapsulated in polymer.
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`• Patent Owner’s proposed construction fails to overcome Sawa’s
`teachings.
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`Ground 2: Claims 5, 12, 18, and 22 are
`obvious over Sawa, Park, and Inoue
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`21
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`It was known to use adhesives to secure polymer to magnetic plates
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`Sawa
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`Inoue
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`Ex.1005, Fig. 10; ’215 Petition, 29.
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`Ex.1007, Fig. 1; Petition, 55.
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`22
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`22
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`It was known to use adhesives to secure polymer to magnetic plates
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`Sawa
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`Inoue
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`Ex.1005, Fig. 3 (annotated); ’215 Petition, 60.
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`Ex.1007, Fig. 3B (annotated); ’215 Petition, 56.
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`23
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`It was known to use adhesives to secure polymer to magnetic plates
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`Sawa and Inoue
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`Ex.1005, Fig. 3 (annotated); ’215 Petition, 62.
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`24
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`It was known to use adhesives to secure polymer to magnetic plates
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`Ex.1005, 5:16-21; ’215 Petition, 21.
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`Adhesive
`between
`plates of
`the same
`kind
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`Ex.1005, Fig. 3 (annotated); ’962 Petition at 38.
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`25
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`It was known to use adhesives to secure polymer to magnetic plates
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`Petitioner Reply, 25.
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`26
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`The test for obviousness
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`Patent Owner Response, 44.
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`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418-19 (2007); Response, 44.
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`27
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`The test for obviousness
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`Petition, 57.
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`Petition, 57-58.
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`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007); ’215 Reply, 25.
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`Sawa and Inoue teach using adhesives to secure polymer to magnetic plates
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`Summary
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`• Sawa shows that it was known to secure polymer to magnetic layers
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`•
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`Inoue shows that it was known to use adhesive to secure polymer to
`magnetic layers
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`• Because POSITAs were already using adhesive layers to secure
`polymers to magnetic sheets in wireless charging applications, as
`evidenced by Inoue, a POSITA would have had a sufficient reason to
`do the same in Sawa
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`Inter Partes Review
`U.S. Patent No. 9,843,215
`
`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00117
`
`Calmann J. Clements,
`Haynes and Boone, LLP
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`30
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`Additional Slides
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`31
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`31
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`BH Curves
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`Ex.2020, ¶58, Reply, 11.
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`Ex.1018 (Reproducing Ex.1024, Fig. 7); Reply, 12.
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`Sawa and Inoue together show that it was known to use adhesives to secure
`polymer to magnetic plates in the field of wireless charging devices
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`Sawa and Inoue
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`Ex.1005, Fig. 3 (annotated); ’215 Petition, 64.
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