UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE, INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner
`______________
`
`IPR2022-00117
`Patent No. 9,843,215
`____________
`
`DECLARATION OF DR. DAVID S. RICKETTS IN SUPPORT OF
`PATENT OWNER’S RESPONSE
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 1
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE, INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner
`______________
`
`IPR2022-00117
`Patent No. 9,843,215
`____________
`
`DECLARATION OF DR. DAVID S. RICKETTS IN SUPPORT OF
`PATENT OWNER’S RESPONSE
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 1
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION ......................................................................................... 1
`
`BACKGROUND AND QUALIFICATIONS ............................................... 2
`
`LEGAL PRINCIPLES ................................................................................... 6
`
`III.
`A. Claim construction ......................................................................................... 6
`B. Burden of Proof ............................................................................................. 7
`C. Anticipation ................................................................................................... 7
`D. Obviousness ................................................................................................... 7
`PERSON OF ORDINARY SKILL IN THE ART ........................................ 9
`
`IV.
`
`V.
`
`BACKGROUND ........................................................................................... 9
`
`A. Wireless Power Transfer .............................................................................. 10
`B. Magnetic Permeability and Reluctance ....................................................... 15
`C. Magnetostriction, Stress and Increased Saturation Magnetization .............. 23
`OVERVIEW OF THE ’215 PATENT ........................................................ 25
`
`VI.
`
`SUMMARY OF SAWA .............................................................................. 28
`
`VII.
`VIII. GROUND 1: CLAIMS 1, 8-11, 13, 17, AND 19-21 ARE NOT OBVIOUS
`OVER SAWA AND PARK .................................................................................... 39
`GROUND 2: CLAIMS 5, 12, 18, AND 22 ARE ADDITIONALLY NOT
`IX.
`OBVIOUS OVER SAWA, PARK, AND INOUE .................................................. 47
`
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`Ex. 2020 - Page 2
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`I, David S. Ricketts, PhD, hereby declare as follows:
`
`I.
`
`Introduction
`I am over the age of eighteen (18) years and otherwise competent to
`1.
`
`make this declaration.
`
`2.
`
`I have been retained as an expert witness on behalf of Scramoge
`
`Technology Limited (“Scramoge”) for the above-captioned inter partes review
`
`(“IPR”). I understand that the petition for inter partes review involves U.S. Patent
`
`No. 9,843,215 (“the ’215 Patent”).
`
`3.
`
`I make this declaration based on my personal knowledge, educational
`
`background and training, consideration of the materials I discuss herein, and my
`
`expert opinions.
`
`4.
`
`I am being compensated at a rate of $650 per hour for my time in this
`
`matter. My compensation does not depend on the outcome of this proceeding, and I
`
`have no financial interest in its outcome.
`
`5.
`
`In preparing this Declaration, I have reviewed and considered the ’215
`
`Patent, the ’215 Patent’s prosecution history, the Petition, the declaration of Dr.
`
`Joshua Phinney submitted in this proceeding, the deposition testimony of Dr.
`
`Phinney, and each document cited in my declaration.
`
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`II.
`
`BACKGROUND AND QUALIFICATIONS
`6.
`My qualifications for forming the opinions given in this declaration
`
`are summarized here and are addressed more fully in my curriculum vitae, which is
`
`submitted as Exhibit 2017. That exhibit also includes a list of my publications.
`
`7.
`
`I am currently Full Professor of Electrical and Computer Engineering
`
`at the North Carolina State University. In my position I conduct research and teach
`
`undergraduate and graduate students in the area of electrical and computer
`
`engineering. The courses I teach include Advanced Analog Integrated Circuit
`
`(“IC”) Design, Radio System Design, Analog Circuit Laboratory and Power
`
`Management IC Design. I also lead a research group that conducts research and
`
`design of electrical and electronic circuits, including millimeter wave and
`
`microwave circuits and systems, radio frequency identification (“RFID”) circuits,
`
`wireless power transfer circuits, antenna and inductor design, analog circuits, and
`
`radio frequency (“RF”) circuits. I lead research in power electronics and power
`
`conversion integrated circuits. I also conduct research in mixed signal RF/digital
`
`systems. I have served in my current position since 2012.
`
`8.
`
`Prior to my current position, I served as an Assistant Professor of
`
`Electrical and Computer Engineering and held a courtesy appointment in the
`
`Materials Science Department at Carnegie Mellon University from 2006 to 2012.
`
`2
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`
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`9.
`
`I received my B.S. and M.S. in Electrical Engineering in 1995 and
`
`1997, respectively, from Worcester Polytechnic Institute in Worcester,
`
`Massachusetts. I received my Ph.D. in Electrical Engineering from Harvard
`
`University in Cambridge, Massachusetts in 2006.
`
`10.
`
`Prior to entering academia, I worked as an engineer in private industry
`
`holding several engineering and managerial positions where I developed and
`
`oversaw the development of electrical and electronic circuits, including those
`
`related to power transfer, power conversion, and semiconductor design in wired
`
`and wireless circuits and systems.
`
`11.
`
`From 1995 to 1999, I held a position as an engineer and senior
`
`engineer at American Power Conversion, where I designed AC-DC and DC-DC
`
`converters. In 1996 I did completed my Master’s Thesis with Analog Devices on
`
`the design of a 622 MHz Frequency Synthesizer.
`
`12.
`
`From 1999 to 2001, I held a position as a Principal Consultant at
`
`Renaissance Design, Inc., where I designed power management ICs.
`
`13.
`
`From 2000 to 2002, I held a position as a Manager of New Product
`
`Development at ON Semiconductor Corp., where I was responsible for six product
`
`development teams including market analysis, business development, system
`
`design, integrated circuit design and testing. In that role I oversaw the
`
`3
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`development of over twenty power management ICs in bipolar, CMOS, and
`
`BiCMOS technologies.
`
`14. From 2002 to 2003, I held the position of Advanced System
`
`Engineering Manager at ON Semiconductor Corp., where I directed a team of
`
`system engineers to develop multi-phase power management ICs for Intel and
`
`AMD microprocessors.
`
`15.
`
`In 2006 I received my PhD on the topic of advanced oscillator
`
`topologies. My work on integrated circuit oscillators was included in the 2008
`
`McGraw-Hill Yearbook of Science and Technology and discussed in Nature, the
`
`pre-eminent science journal. In addition, my work on advanced materials for
`
`circuits included the first Si-Ge shell-core nanowire oscillator on plastic.
`
`16.
`
`I have published at least 49 academic journal papers, as shown in my
`
`curriculum vitae, relating to various topics related to millimeter wave and
`
`microwave circuits and systems, RFID circuits, wireless power transfer circuits,
`
`magnetic circuits and materials, analog circuits, and RF circuits.
`
`17.
`
`I have been the author of at least 78 conference articles, as shown in
`
`my curriculum vitae, relating to various topics related to millimeter wave and
`
`microwave circuits and systems, RFID circuits, wireless power transfer circuits,
`
`magnetic circuits and materials, analog circuits, and RF circuits.
`
`
`
`
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`18. More particularly, I have published more than twenty journal and
`
`conference papers on wireless power transfer in leading publications for wireless
`
`power, such as the Transactions on Microwave Theory and Techniques, Applied
`
`Physics Letters, Antennas and Wireless Propagation Letters, as well as United
`
`States, European, and Asia-Pacific wireless conferences. Several of these papers
`
`were on the role of magnetic materials and their effect on wireless power transfer. I
`
`was an invited speaker to the 2014 Wireless Power Summit, San Francisco, a
`
`leading annual conference for wireless power industry providers in the United
`
`States. At that conference, I presented advances in wireless power transfer from
`
`my research. I have served on the technical committee for the International
`
`Microwave Symposium, where I co-chaired the committee on wireless power
`
`transfer. I have also served on the technical committee for the Institute of Electrical
`
`and Electronics Engineers (IEEE) Wireless Power Transfer Conference (WPTC),
`
`the premier global conference dedicated to wireless power transfer. In addition, I
`
`have developed multiple commercial solutions in wireless power for companies
`
`such as General Motors (detailed in my publications).
`
`19.
`
`I am the recipient of the National Science Foundation CAREER
`
`award for work in emerging magnetic devices known as spin-torque oscillators. I
`
`also received the Defense Advanced Research Projects Young Faculty Award for
`
`my work in emerging magnetic devices.
`
`
`
`
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`20. My current curriculum vitae, provided in Exhibit 2017, contains more
`
`information on my background and experience, as well as the cases in which I have
`
`served as an expert witness the past four years.
`
`21. No part of my compensation is contingent upon the outcome of this
`
`inter partes review or any district court litigation between the parties. I have no
`
`other interests in this inter partes review, any litigation between the parties, or with
`
`any of the parties.
`
`III. LEGAL PRINCIPLES
`A.
`Claim construction
`22.
`I understand that the first step in performing a validity analysis of the
`
`patent claims is to interpret the meaning and scope of the claims by construing the
`
`terms and phrases found in those claims. I understand that the appropriate
`
`construction of a claim term is its ordinary and accustomed meaning as understood
`
`by one of ordinary skill in the art at the time of the invention in the context of the
`
`entire patent.
`
`23.
`
`I understand that standard for claim construction in an inter partes
`
`review is the same standard as is applied in district court proceedings.
`
`24.
`
`I understand that a determination of the meaning and scope of the
`
`claims is a matter of law. I have been informed that to determine the meaning of
`
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`the claims, one should consider the intrinsic evidence, which includes the patent’s
`
`claims, written description, and prosecution history.
`
`B.
`
`Burden of Proof
`25.
`I understand that in an inter partes review, the petitioner has the
`
`burden of proving unpatentability by a preponderance of the evidence.
`
`C.
`26.
`
`Anticipation
`I have been instructed by counsel and understand that a reference is
`
`anticipated if a single prior art reference discloses each and every claim element,
`
`either explicitly or inherently, as arranged in the same way as in the claim. I
`
`understand that where even one claim element is not disclosed in a reference, a
`
`contention of anticipation fails.
`
`27.
`
`I further understand that when a reference fails to explicitly disclose a
`
`claim element, that reference inherently discloses that element only if the reference
`
`must necessarily include the undisclosed claim element.
`
`D.
`28.
`
`Obviousness
`I have been instructed by counsel and understand that a combination
`
`of prior art references may render a claim obvious if, at the time of the invention, a
`
`person of ordinary skill in the art would have selected and combined those prior-art
`
`elements in the normal course of research and development to yield the claimed
`
`invention.
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`29.
`
`I understand that in an obviousness analysis, one should consider the
`
`Graham factors: the scope and content of the prior art; the differences between the
`
`claimed inventions and the prior art; the level of ordinary skill in the art; and
`
`certain secondary considerations, identified below. I further understand the
`
`obviousness analysis is to be performed on a claim-by-claim basis. I understand
`
`that a person of ordinary skill in the art is a person of ordinary creativity, not an
`
`automaton.
`
`30.
`
`I have been instructed by counsel and understand that obviousness
`
`requires more than a mere showing that the prior art includes separate references
`
`covering each separate limitation in a claim under examination. I understand
`
`obviousness requires the additional showing that a person of ordinary skill at the
`
`time of the invention would have been motivated to combine those references in a
`
`manner that would include all limitations of the challenged claim, and, in making
`
`that combination, a person of ordinary skill in the art would have had a reasonable
`
`expectation of success.
`
`31.
`
`I also understand that an obviousness analysis must be conducted with
`
`awareness of the distortion caused by hindsight bias and with caution of arguments
`
`reliant upon ex post reasoning. For instance, I understand that when considering
`
`obviousness, I should put myself in the position of a person of ordinary skill in the
`
`
`
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`field at the time of the invention, rather than considering new information that is
`
`known today but was not known before the priority date of the challenged patent.
`
`32.
`
`In particular, I understand that it is improper to use the challenged
`
`patent’s disclosure or invention as a roadmap to find its prior-art components,
`
`because such an approach discounts the value of combining various existing
`
`features or principles in a new way to achieve a new result.
`
`IV.
`
`Person of ordinary skill in the art
`33. Dr. Phinney states that a person of ordinary skill in the art “would
`
`have a master’s degree in electrical engineering, or equivalent training, and
`
`approximately two years of experience working in the electrical engineering field.
`
`Lack of work experience can be remedied by additional education, and vice versa.”
`
`Ex. 1003 at ¶ 19. For purposes of this declaration, I apply the level of skill in the
`
`art described above.
`
`V.
`
`Background
`34. Wireless charging as contemplated by the ’215 Patent involves
`
`various technical principles related to electromagnetic radiation and the magnetic
`
`behavior of materials. Thus, I start with a basic explanation of those principles and
`
`add more detail as is relevant.
`
`9
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`Ex. 2020 - Page 11
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`A. Wireless Power Transfer
`35. Wireless power transfer (“WPT”) is a method to transfer energy from
`
`a source to a load through the air with no direct connection. In the context of the
`
`’215, the wireless power transfer method uses a source coil that generates a time-
`
`varying magnetic field that is sensed by a second coil in a receiver, or load. The
`
`two coils form a transformer. A transformer is a basic electromagnetic device that
`
`transfers energy from one circuit to another. The operating principles of a
`
`transformer are based on the law of induction by Michael Faraday (Faraday’s Law)
`
`and Ampere’s Law, which states that a current in a wire will generate a magnetic
`
`field.
`
`36. A basic magnetic transformer consists of two coils of wire that are in
`
`close proximity to each other (but not in direct contact). When the transformer is
`
`operated under the (proper) conditions, an electric current is applied to one coil as
`
`an energy input; that energy is transferred (via a magnetic field) to the second
`
`coil—across a gap between them. Direct electrical contact is unnecessary for this
`
`energy transfer. For convenience and general convention, we will call the coil
`
`supplying the energy the primary coil and the coil receiving the energy as the
`
`secondary coil.
`
`37. Specifically, in a magnetic transformer a current in one coil generates
`
`a magnetic field (Ampere’s Law). If that magnetic field varies with time, i.e., is an
`
`
`
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`Ex. 2020 - Page 12
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`
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`alternating current (AC) field created by an AC current in the primary coil, it will
`
`generate a voltage on the secondary coil (Faraday’s Law) placed within the
`
`primary coil’s AC magnetic field. The voltage on the secondary coil can then be
`
`used to supply energy to a second circuit/device/system. Thus, in a magnetic
`
`transformer, energy from the first coil can be transferred to the second coil even
`
`though the two coils are not in direct contact.
`
`38. The electromotive force (emf) of the secondary coil, measured in
`
`Volts, is determined Faraday’s Law and is given by the cross-sectional area of the
`
`coil, A, the frequency, f, the number of turns, N, and the external magnetic field, B,
`
`perpendicular to the coil:
`
`V
`
`N j
`=- ×
`
`2
`f
`
`
`N j
`p f=- ×
`
`(
`2
`f B A
`p ^
`
`)
`
`,
`
`where the magnetic flux, f, is the integral of the magnetic field over a surface, in
`
`this case the area A in the figure below. Stated generally, voltage on the secondary
`
`coil is directly related to the voltage on the primary coils, the turns (N), and area
`
`(A).
`
`39.
`
`It is important to note that Faraday’s Law explicitly recognizes that an
`
`AC current and AC flux are required to transfer energy, hence the frequency term
`
`(f) in the above equations. A static current and flux (e.g., f = 0) do not transfer
`
`energy. There is no voltage induced on the secondary coil if the current through
`
`
`
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`11
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`Ex. 2020 - Page 13
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`
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`primary coil is static or a direct current (DC) (again, f = 0). Thus the transformer
`
`does not function for DC, but rather only for AC.
`
`40. To increase the energy transferred across a transformer, it is desirable
`
`to couple the maximum amount of magnetic flux inside the primary coil and
`
`secondary coil. Under Faraday’s Law , the induced voltage is proportional to the
`
`amount of magnetic flux in the coils area, A. The figure below illustrates this
`
`coupling of magnetic flux (shown in the below figure in red) in an air-gap (or air-
`
`core) transformer (the material between and surrounding the coils is air):
`
`
`
`41.
`
`If the flux generated by the current in the primary coil changes with
`
`time, i.e. is AC, then a voltage proportional to the flux passing through the
`
`secondary coil will be induced and energy can be transferred. A DC (non-time
`
`varying) current in the primary coil will generate a DC magnetic flux (Ampere’s
`
`Law), but per Faraday’s Law, no voltage appears on the secondary coil as there is
`
`
`
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`12
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`Ex. 2020 - Page 14
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`
`
`no AC flux and thus no energy is transferred. In other words, a magnetic
`
`transformer only functions for AC.
`
`42. The amount of coupled magnetic field is affected by the shape and
`
`proximity of the coils. Since the magnetic field decreases by approximately one
`
`over the cube of the distance, the closer the proximity, the higher the coupled
`
`magnetic field. Shape will also aid in concentrating the magnetic field. The
`
`coupled flux is shown and is highest in the center of the coil.
`
`43. While an air-gap transformer enables important functionality, such as
`
`in wireless power transfer, it has significant limitations as a substantial amount of
`
`flux is not coupled between primary coil and secondary coil.
`
`44. Because of this, transformers may incorporate a magnetic core or
`
`sheet to aid in concentrating of the magnetic flux to increase the coupling between
`
`coils. The purpose of the core or sheet is to provide a more desirable path for the
`
`magnetic field between the coils. This more desirable path is quantified by the
`
`magnetic reluctance, which is a direct analogy to electrical resistance. A higher
`
`reluctance means that it is a less desirable path for magnetic flux, just like a higher
`
`electrical resistance is a less desirable path for current to flow. For magnetic
`
`circuits one considers the flux and the reluctance; for electrical circuits one
`
`considers the current and resistance.
`
`
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`45. The magnetic reluctance is inversely proportional to the permeability
`
`of a magnetic material, with air having a much higher reluctance, or resistance, to
`
`flux than a material with high permeability.
`
`46. To increase the amount of coupled AC flux between primary coil and
`
`secondary coil, a magnetic core or sheet can be used. When the reluctance is very
`
`low (flux prefers to be concentrated in the core), the majority of the magnetic flux
`
`will be concentrated in the core.
`
`47. Magnetic cores or sheets also have a number of ancillary effects that
`
`may be considered drawbacks in certain applications. The magnetic flux inside of
`
`a magnetic core can cause a phenomenon known as eddy currents within the
`
`magnetic core. Eddy currents are circular currents that flow inside the magnetic
`
`core material that are induced by the AC flux in the core. If the magnetic core
`
`material is electrically conductive, the AC magnetic field from the primary coil
`
`will induce small voltages inside the core and cause current to flow inside the core,
`
`just like it induces a larger voltage on the secondary coil and causes current to flow
`
`in the device connected to the secondary coil. The eddy currents will cause energy
`
`loss.
`
`48. Additionally, there is a phenomenon known as core loss. This occurs
`
`because microscopic magnetic domains within material will switch back and forth
`
`as they follow the AC current.
`
`
`
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`49. Thus, the use of a magnetic core or sheet may provide increased flux
`
`coupling between the primary and secondary coils of a transformer, but may add
`
`some additional loss.
`
`B. Magnetic Permeability and Reluctance
`50. Properties that underlie magnetic cores or sheets used in WPT are
`
`known as magnetic permeability and its inverse, magnetic reluctance, are
`
`important to understanding the ’215 Patent.
`
`51. The magnetic flux in a vacuum created by a current flowing through a
`
`coil can be calculated. When a material other than vacuum is present, the magnetic
`
`flux in that material may be different than in a vacuum. The ratio between the two
`
`magnetic fields or fluxes is characterized by the relative permeability, µr, of a
`
`material:
`
`𝜇!"#$%&"’= 𝜇% ∙ 𝜇(
`
`where permeability of a vacuum has a value of 4π×10-7 H/m (Henrys per meter)
`
`and is represented by the symbol µo.
`
`52. As an example, a material with a relative permeability of 10 would
`
`have a magnetic flux 10 times the flux value if the material was not present (in a
`
`vacuum). Thus, permeability characterizes the change in magnetic flux when a
`
`coil is not in a vacuum. Air has a permeability of 1.00000037, and thus the
`
`magnetic flux in air is almost identical to that of a vacuum.
`15
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`53. Materials can have a permeability different from 1. The most notable
`
`are magnetic cores or sheets in WPT, which typically have a permeability much
`
`greater than 1. Some materials, like water have a permeability less than 1, which
`
`means the flux is lower in water than it would be in a vacuum or air.
`
`54. Magnetic permeability can be understood by looking at the
`
`microscopic composition of many magnetic materials. Many magnetic materials
`
`are composed of microscopic (1-30 micrometer) domains that act like a small
`
`magnet. They are randomly arranged in a magnetic material, as shown below.
`
`
`
`55. A domain is like a microscopic bar magnet, with a North and South
`
`pole and the orientation shown by the arrow. In an unmagnetized material, the
`
`domains are randomly oriented. Because of their random orientation, the fields
`
`from each domain cancel one another and the net magnetic field is zero. When an
`
`external magnetic field, H, is applied some domains will align with the external
`16
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`
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`field. Now the domains aren’t all random, some point in the direction of the
`
`applied field, H. Because of this, their magnetic fields do not cancel, but rather add
`
`to the applied magnetic field, H, such that the effective magnetic field, B, is greater
`
`than the applied magnetic field, H.
`
`56. The relation between them is the permeability:
`
`𝐵= 𝜇!"#$%&"’∙ 𝐻
`
`57. As stated above, the permeability is often decomposed into the
`
`permeability of a vacuum and then the relative permeability of the material (the
`
`multiplier between the external field and the effective field due to the alignment of
`
`magnetic domains):
`
`𝜇!"#$%&"’= 𝜇% ∙ 𝜇(
`
`58. As the external field is increased, more and more domains will align.
`
`Once all of the magnetic domains are aligned, the effective magnetic field, B,
`
`cannot increase at the same rate and the material is said to be saturated. A common
`
`representation of this is the relationship between B and H, as shown below in what
`
`is often referred to as a B-H curve:
`
`
`
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`17
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`B
`
`
`
`This example displays the difference between a soft magnetic material and hard
`
`magnetic material in the presence of an applied magnetic field, H. When H=0, the
`
`domains of each of the materials are random.
`
`59. The slope of the curve is the effective permeability. The curve has
`
`hysteresis because once domains are aligned they tend to stay aligned, it takes a
`
`reduced or opposing external field to get them to return to a random orientation or
`
`to be oriented in the opposite direction. The saturation occurs when all domains are
`
`aligned.
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`
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`60. A soft magnetic material is one in which the domains align easily with
`
`the external field, H, and return to their random orientation easily when the
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`external field is removed. It can be thought of as responsive to the external field
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`and requires little energy to change.
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`61. A hard magnetic material is one in which the domains stay in place
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`and it takes a large magnetic field to change their orientation. The orientation of
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`the domains is hard to change and they are not as responsive to changes in external
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`fields, H, unless it is a large magnitude. The magnitude of the external field needed
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`to change all domains from one direction to the other is called the coercivity.
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`62. The difference between hard and soft materials can be seen in the
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`diagram above. For a soft material, a small change in H causes a small change in B.
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`As shown in the figure above, when a large H is applied in the positive direction,
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`all of the domains align and the soft material is saturated. Soft materials can be
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`easily saturated. Hard materials require a greater external field to saturate. In his
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`deposition, Dr. Phinney noted that there is “a somewhat arbitrary dividing line
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`between what we call hard and soft that’s for a particular numeric value of
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`coercivity.” Phinney Tr. at 38:23 – 39:4 (discussing whether stainless steels can be
`
`a soft magnetic material); see also Phinney Tr. at 43:9-17 (the width of the
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`hysteresis loop in the B-H curve will, along a continuum, dictate the transition
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`from soft magnetic properties to hard magnetic properties). Dr. Phinney also noted
`19
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`Scramoge Technology Ltd.
`Ex. 2020 - Page 21
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`that a clear “dividing line” between soft and hard is 1,000 Amps per meter. See
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`Phinney Tr. at 43:19 – 44:6.
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`63. One common method to create a hard magnetic material is to induce
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`an anisotropy to the shape of the domains, such that they prefer only being in one
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`direction or the other, e.g. a bar magnet that only wants to be N side up or S side
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`up, with no other possible orientation. Another method is to create crystal grains
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`that are on the order of the magnetic domains. When this happens, the magnetic
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`domains are “pinned” by the grain dimension and hard to change. In other words,
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`while the elemental components will have an effect on the magnetic characteristics
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`of a composition, the crystal structure and size, dependent on the processing of the
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`composition, plays a significant role in whether the material exhibits soft magnetic
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`characteristics or hard magnetic characteristics. In his deposition testimony, Dr.
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`Phinney identified permalloy and silicon steel as having soft magnetic properties.
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`Phinney Tr. at 12:2-23, 38:14-22, 54:4-14. The example below shows the B-H
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`curve of each of silicon steel, configured as a hard magnetic material, and
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`permalloy, configured as a soft magnetic material. In addition it can be seen that
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`the Permalloy is easily saturated by an external magnetic field, as only a small H is
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`needed to saturate it.
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`Ex. 2020 - Page 22
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`Saturated
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`
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`Ex. 2019 at 36, Introduction to Inorganic Chemistry, Wikibook, Penn State
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`University, at 6.9.1 (available at
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`https://chem.libretexts.org/Bookshelves/Inorganic_Chemistry/Book%3A_Introduct
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`ion_to_Inorganic_Chemistry_(Wikibook)) (annotated).
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`64. As Sawa explains, “The Fe alloy of the Fe--Cr system, the Fe--Ni
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`system, and the Fe--Si system is easy to be adjusted in plate thickness by rolling.
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`Further, it is easy to form an inner strain in a stressing process step such as rolling
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`and to generate a magnetic anisotropy by an interaction with a magnetostriction.
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`Therefore, it is possible to make the first magnetic thin plate 2 hard to be magnetic-
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`saturated.” Ex. 1005, 9:4-11.
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`Ex. 2020 - Page 23
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`65. As discussed above, magnetic reluctance is the measurement of a
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`material’s resistance to magnetic flux, with lower reluctances being a more
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`desirable path for magnetic flux. This is a direct analog to electrical resistance,
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`where a lower resistance is a more desirable path for current to flow. Magnetic
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`reluctance is inversely proportional to a material’s permeability and thus two
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`properties are directly related. Magnetic flux will choose to flow in the least
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`reluctance path and thus will be concentrated by low reluctance paths in a magnetic
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`circuit.
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`66. To illustrate this, consider the magnetic flux in two materials:
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`Aluminum with a relative permeability of 1.0002 and 1018 Steel with a relative
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`permeability of approximately 100. Aluminum has approximately the reluctance of
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`air (around 1) and thus is no more a desirable path than air and it does not
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`concentrate magnetic flux as can be seen in the illustration below. 1018 Steel,
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`however, has a reluctance 1/100 (inverse of relative permeability) that of air and is
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`a more desirable path and thus concentrates magnetic flux. The below illustrations
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`shows clearly how the flux is more concentrated inside of the 1018 steel (on right
`
`in green) than aluminum (on left in blue):
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`Ex. 2020 - Page 24
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`C. Magnetostriction, Stress and Increased Saturation
`Magnetization
`67. Magnetostriction is the property of a magnetic material that it changes
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`dimension during magnetization. One example is an ultrasonic transducer where a
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`current carrying coil generates a magnetic field which then causes a magnetic
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`material with magnetostriction properties to expand/contract. Thus the current
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`carrying coil can cause a mechanical vibration through the magnetostriction
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`properties of the magnetic material.
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`68.
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`In materials with magnetostriction, a magnetic field causes a strain
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`that may lead to displacement or dimensional change of the material. Likewise, a
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`mechanical pressure can cause a magnetic field.
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`Ex. 2020 - Page 25
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`
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`Yoon Young Kim, Young Eui Kwon, Review of magnetostrictive patch
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`transducers and applications in ultrasonic nondestructive testing of waveguides,
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`Ultrasonics, Volume 62, 2015, Pages 3-19, ISSN 0041-624X,
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`https://doi.org/10.1016/j.ultras.2015.05.015.
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`69. The saturation magnetization of a material can be changed by
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`inducing stress during manufacturing or by stress induced during operation where
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`the strain impedes the alignment of the small magnetic domains, resulting in a
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`
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`Ex. 2020 - Page 26
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`higher magnetic field needed to overcome the induced strain. This may be thought
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`of as a magnet with magnetostriction in a fixed box. When a magnetic field is
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`applied, it cannot lengthen and thus the domains cannot align. The fixed box can
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`be a physical dimension limitation, e.g. an actual box, or ca
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