`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`IPR2022-00117
`U.S. Patent No. 9,843,215
`_____________________
`
`
`DECLARATION OF DR. JOSHUA PHINNEY,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
`
`
`
`
`
`
`
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`1
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`Inter Partes Review of U.S. 9,843,215
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`TABLE OF CONTENTS
`
`
`
`Introduction ...................................................................................................... 4
`I.
`Qualifications and Professional Experience .................................................... 6
`II.
`III. Level of Ordinary Skill in the Art ................................................................... 9
`IV. Relevant Legal Standards .............................................................................. 10
`V.
`Background .................................................................................................... 13
`VI. Overview of the ’215 Patent .......................................................................... 14
`VII. Claim Construction ........................................................................................ 17
`VIII. Identification of how the Claims are Unpatentable ....................................... 17
`A. Ground 1: Claims 1, 8-11, 13, 17, and 19-21 are obvious under
`35 U.S.C. § 103 over Sawa and Park. ................................................. 18
`1.
`Summary of Sawa .......................................................... 18
`2.
`Summary of Park ........................................................... 21
`3.
`Reasons to Combine Sawa and Park ............................. 23
`4.
`Claim 1 ........................................................................... 27
`5.
`Claim 8 ........................................................................... 47
`6.
`Claim 9 ........................................................................... 49
`7.
`Claim 10 ......................................................................... 51
`8.
`Claim 11 ......................................................................... 54
`9.
`Claim 13 ......................................................................... 56
`10.
`Claim 17 ......................................................................... 60
`11.
`Claim 19 ......................................................................... 60
`12.
`Claim 20 ......................................................................... 60
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`2
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`B.
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`Claim 21 ......................................................................... 60
`13.
`Ground 2: Claims 5, 12, 18, and 22 are obvious under 35
`U.S.C. § 103 over Sawa, Park, and Inoue. .......................................... 60
`1.
`Summary of Inoue ......................................................... 61
`2.
`Reasons to combine Sawa and Inoue ............................ 63
`3.
`Claim 5 ........................................................................... 66
`4.
`Claim 12 ......................................................................... 70
`5.
`Claim 18 ......................................................................... 75
`6.
`Claim 22 ......................................................................... 75
`IX. Conclusion ..................................................................................................... 76
`
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`3
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`Phinney Declaration
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`I, Joshua Phinney, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
`
`Inter Partes Review of U.S. 9,843,215
`
`
`
`1.
`
`I am making this declaration at the request of Apple, Inc. in the matter
`
`of the Inter Partes Review of U.S. Patent No. 9,843,215 (“the ’215 Patent”) to
`
`Yeom et al.
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the outcome of this matter or the specifics of my testimony.
`
`3.
`
`I have been asked to provide my opinions regarding whether claims 1,
`
`5, 8-13, and 17-22 (“the Challenged Claims”) of the ’215 Patent are unpatentable
`
`as they would have been obvious to a person having ordinary skill in the art
`
`(“POSITA”) at the time of the alleged invention, in light of the prior art. It is my
`
`opinion that all of the limitations of the challenged claims would have been
`
`obvious to a POSITA.
`
`In the preparation of this declaration, I have studied:
`
`the ’215 Patent, Ex.1001;
`
`the prosecution history of the ’215 Patent (“’215 File History”),
`
`4.
`
`a.
`
`b.
`
`Ex.1002;
`
`c.
`
`U.S. Patent No. 9,443,648 to Sawa (“Sawa”), Ex.1005;
`
`
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`4
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`d.
`
`e.
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`5.
`
`U.S. Patent No. 8,922,162 to Park (“Park”), Ex.1006;
`
`U.S. Patent No. 8,922,160 to Inoue (“Inoue”), Ex.1007;
`
`In forming the opinions expressed below, I have considered:
`
`the documents listed above;
`
`the relevant legal standards, including the standard for obviousness,
`
`and any additional authoritative documents as cited in the body of this
`
`declaration; and
`
`my own knowledge and experience based upon my work in the field
`
`of networking as described below, as well as the following materials.
`
`a.
`
`b.
`
`c.
`
`U.S. Patent No. 9,030,724 to Agrawal (“Agrawal”), Ex.1008;
`
`U.S. Patent Publication No. 2012/0236528 to Le (“Le”), Ex.1009;
`
`U.S. Patent Publication No. 2014/0320369 to Azenui (“Azenui”),
`
`Ex.1010; and
`
`d.
`
`e.
`
`Ex.1012;
`
`f.
`
`g.
`
`6.
`
`added.
`
`
`
`
`U.S. Patent No. 9,252,611 to Lee et al. (“Lee”), Ex.1011;
`
`U.S. Patent No. 8,427,100 to Vorenkamp et al. (“Vorenkamp”),
`
`U.S. Patent No. 8,687,536 to Michaelis (“Michaelis”), Ex.1013; and
`
`U.S. Patent No. 9,627,646 to Ellinger (“Ellinger”), Ex.1014.
`
`Unless otherwise noted, all emphasis in any quoted material has been
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`5
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`Inter Partes Review of U.S. 9,843,215
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`7. My complete qualifications and professional experience are described
`
`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
`
`following is a brief summary of my relevant qualifications and professional
`
`experience.
`
`8.
`
`I am a Principal Engineer in the Electrical Engineering and Computer
`
`Science practice at Exponent, an engineering and scientific consulting firm
`
`headquartered at 149 Commonwealth Drive, Menlo Park, California 94025. I
`
`received a Ph.D. in Electrical Engineering from the Massachusetts Institute of
`
`Technology (“MIT”) in 2005. I also earned S.M. and B.S. degrees in Electrical
`
`Engineering from MIT and the University of Illinois, Chicago (“UIC”),
`
`respectively.
`
`9. My master’s thesis at MIT focused on the miniaturization of power
`
`converters, by reducing the energy storage and improving the performance of
`
`inductors. As part of this work, I designed, tested, and constructed ferrite, iron-
`
`powder, and air-core inductors, while minimizing magnetic losses. During this
`
`time, I invented with my advisor, Dr. David Perreault, an electrical component
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`with a capacitive impedance and an inductance-cancellation feature provided by
`
`magnetically coupled windings. A filter having a capacitor with inductance
`
`cancellation provides enhanced performance over frequency compared with
`
`
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`6
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`conventional capacitors. This work was later extended to a second patent, with
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`Inter Partes Review of U.S. 9,843,215
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`magnetically coupled windings used to improve EMI filters and common-mode
`
`chokes.
`
`10. My doctoral work at MIT centered on miniaturization of power
`
`converters and magnetics. As part of my doctoral work, I constructed and modeled
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`planar magnetic systems, including magnetically coupled, printed magnetic coils.
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`By incorporating such compact, magnetic structures into power converters, the
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`resulting converter enjoyed multiple benefits, including waveform-shaping and
`
`reduction of switch stresses. Through the modeling associated with this
`
`dissertation, I become proficient in methods for analyzing the inductances of
`
`packages and interconnects, especially planar or filamentous systems of
`
`conductors.
`
`11.
`
` For my publications related to both my Master’s and Ph.D. thesis, I
`
`received the William M. Portnoy Prize Paper Award (2003) and the IEEE Power
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`Electronics Society Transactions Prize Paper Award (2004).
`
`12. After earning my Ph.D., I joined Exponent and have led technical
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`investigations to portable electronic devices, microcomputers, as well as industrial
`
`and consumer devices with embedded controllers. My job functions include
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`analyzing hardware and software of these devices to understand their modes of
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`failure, and testifying regarding these devices in legal matters involving patents
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`
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`7
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`and trade secrets.
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`Inter Partes Review of U.S. 9,843,215
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`
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`13. As part of my employment at Exponent, I have performed design,
`
`design reviews, and failure analysis for wireless charging and communication
`
`systems. The focus of this work has been (1) coupling between transmitter and
`
`receiver coils from the standpoint of efficiency and magnetic-field exposure to
`
`users, in particular for the Power Matters Alliance; (2) coupling of interrogators
`
`and transponder coils in printed magnetic cards; and (3) integrated-circuit and coil
`
`failures due to wear, dimensional changes, and triboelectric charging. In addition
`
`to testifying regarding resonant and inductive wireless-power transfer, I have
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`consulted for industry regarding coil design, RFID and near-field communication
`
`(NFC) integrated circuits, modulation methods, and on-metal RFID tags.
`
`14.
`
`I have testified regarding the software-defined features, internal
`
`circuitry, and physical embodiments of electronic equipment. Regarding
`
`electronics, I have testified regarding power electronics in communication systems,
`
`wind turbines, grid-scale photovoltaic plants, and consumer electronics. In
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`addition, I have testified regarding control and compensation in industrial
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`controllers, voltage regulators, and switched-mode power converters. My
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`experience with wireless RF circuitry includes failure analysis of amplifiers, power
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`supplies, matching networks, and multiplexers in satellites, semiconductor-
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`processing equipment, and medical devices.
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`
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`15. Regarding the mechanical elements of electronic equipment, I have
`
`
`
`testified regarding buttons and touch interfaces, connectors, linear and rotary
`
`actuators, position-measuring devices, and the design and construction of modular
`
`housings for computerized equipment and peripherals. In particular, I have
`
`testified regarding detachable components as they are constructed in relation to the
`
`housing and underlying electronic assemblies, including printed circuit boards, flex
`
`printed circuits, and other connector assemblies within the housing of electronic
`
`equipment.
`
`16.
`
`In addition to the forgoing, I perform electromagnetic assessment of
`
`utility and communication infrastructure. These issues include permitting,
`
`interference, and environmental impact of radar, AC and HVDC transmission
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`lines, substations, photovoltaic installations, generators, broadcast antennas, and
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`electrified mass transit systems.
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`17.
`
`I am being compensated for my work associated with this case plus
`
`reimbursement of reasonable expenses. My compensation is not contingent on my
`
`opinions or the outcome of the case, and I have no other interest in this case or the
`
`parties thereto.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`
`18.
`
`I understand there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
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`9
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`experience of persons working in the field at the time of the invention; (2) the
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`Inter Partes Review of U.S. 9,843,215
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`
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`sophistication of the technology; (3) the types of problems encountered in the field;
`
`and (4) the prior art solutions to those problems.
`
`19. A person of ordinary skill in the art (“POSITA”) in the field of the
`
`’215 Patent, as of its earliest possible filing date of March 4, 2014, would have
`
`been someone knowledgeable and familiar with the wireless charging arts that are
`
`pertinent to the ’215 Patent. That person 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.
`
`20. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the alleged
`
`priority date of the ’215 Patent (i.e., March 4, 2014). Unless otherwise stated, when
`
`I provide my understanding and analysis below, it is consistent with the level of a
`
`POSITA prior to the alleged priority date of the ’215 Patent.
`
`IV. RELEVANT LEGAL STANDARDS
`
`21.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’215 Patent, I am relying on certain basic
`
`
`
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`legal principles that counsel have explained to me. These principles are discussed
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`Inter Partes Review of U.S. 9,843,215
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`below.
`
`22.
`
`I understand that prior art to the ’215 Patent includes patents and
`
`printed publications in the relevant art that predate the alleged priority date of the
`
`alleged invention recited in the ’215 Patent. For purposes of this Declaration, I am
`
`applying March 4, 2014 as the earliest possible alleged priority date of the ’215
`
`Patent.
`
`23.
`
`I have been informed that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the
`
`invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains. I have also been informed by counsel that the obviousness analysis
`
`takes into account factual inquiries including the level of ordinary skill in the art,
`
`the scope and content of the prior art, and the differences between the prior art and
`
`the claimed subject matter.
`
`24.
`
`I have been informed by counsel that the Supreme Court has
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
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`obtain predictable results; (c) use of a known technique to improve a similar device
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`Inter Partes Review of U.S. 9,843,215
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`(method, or product) in the same way; (d) applying a known technique to a known
`
`device (method, or product) ready for improvement to yield predictable results; (e)
`
`choosing from a finite number of identified, predictable solutions, with a
`
`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
`
`in the prior art that would have led one of ordinary skill to modify the prior art
`
`reference or to combine prior art reference teachings to arrive at the claimed
`
`invention.
`
`25.
`
`I further understand that certain factors may support or rebut the
`
`obviousness of a claim. I understand that such secondary considerations include,
`
`among other things, commercial success of the patented invention, skepticism of
`
`those having ordinary skill in the art at the time of invention, unexpected results of
`
`the invention, any long-felt but unsolved need in the art that was satisfied by the
`
`alleged invention, the failure of others to make the alleged invention, praise of the
`
`alleged invention by those having ordinary skill in the art, and copying of the
`
`alleged invention by others in the field. I understand that there must be a nexus—a
`
`connection—between any such secondary considerations and the alleged invention.
`
`I also understand that contemporaneous and independent invention by others is a
`
`secondary consideration tending to show obviousness.
`
`26.
`
`I am not aware of any allegations by the named inventor of the ’215
`
`
`
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`12
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`Patent or any assignee of the ’215 Patent that any secondary considerations are
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`
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`relevant to the obviousness analysis of any Challenged Claim of the ’215 Patent.
`
`V. BACKGROUND
`
`27. Mobile devices such as smart phones provide users with a wide
`
`variety of communication mechanisms such as phone calls, text messages, internet
`
`access, as well as providing other features. Mobile devices typically include a
`
`built-in or detachable battery pack that is chargeable. Some types of devices may
`
`be charged wirelessly using principles of induction. Specifically, a coil on the
`
`charger is inductively coupled with a coil in a phone or other wirelessly chargeable
`
`device. To improve the power transfer efficiency, the coils in both the power
`
`transmitting device and power receiving device are placed adjacent to a magnetic
`
`sheet. As will be described in more detail below, the ’215 Patent describes and
`
`claims no more than what was already known in the art with regard to such
`
`magnetic sheets.
`
`28. At the time of the alleged priority date of the ’215 Patent, the
`
`transmission of data by electromagnetic induction – not just power – was known in
`
`the mobile device industry. Near-field communication (NFC) is a “proximity
`
`card” technology that can be used for contactless exchange of data over short
`
`distances. NFC devices (including cell phones) can act as electronic credentials,
`
`e.g., identity documents and keycards and are used in contactless payment systems
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`and allow mobile payment to replace credit cards and electronic-ticket smart cards.
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`29. Like wireless power-transfer technologies, NFC is based on inductive
`
`coupling between the two coils—for example in a smartphone and a fixed reader—
`
`for communication in one or both directions. As exemplified by the Park
`
`reference, discussed below, separate coils for NFC and wireless power transfer can
`
`be integrated in one device to support both power and data-exchange protocols.
`
`VI. OVERVIEW OF THE ’215 PATENT
`
`30. The ’215 patent generally relates to a “a wireless charging and
`
`communication device.” ’215 Patent, Abstract. In particular, the ’215 Patent
`
`describes a device that includes a coil that is placed adjacent to a magnetic layer
`
`220, 230. See ’215 Patent, 5:24-31. The magnetic layer 220, 230 is sandwiched
`
`between two polymeric layers 310, 312: “The polymeric material layer 310, 312 …
`
`may be disposed on one surface and the other surface of the first and second soft
`
`magnetic layers 220, 230.” ’215 Patent, 6:39-41. The magnetic layer as shown in
`
`Fig. 1 below.
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`
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`polymeric
`layer
`
`
`
`
`
`magnetic
`layer
`
`polymeric
`layer
`
`coil
`
`’215 Patent, Fig. 1 (partial, annotated).
`
`31. To overcome the references cited by the Office during prosecution of
`
`the ’215 Patent, the Applicant added limitations related to encapsulating the
`
`magnetic layer by having the top polymeric layer connect to the bottom polymeric
`
`layer. ’215 Patent File History, 81-87. After receiving a first notice of allowance,
`
`the Applicant filed a petition to withdraw from issue and a request for continued
`
`examination to make further amendments to the claims related to the device having
`
`a plurality of magnetic layers, as well as the type of material that may comprise the
`
`magnetic layers. ’215 Patent File History, 32-39, 50. These limitations then
`
`resulted in the Office issuing a second notice of allowance. ’215 Patent File
`
`History, 21-25. The additionally added limitations (encapsulating polymeric layer
`
`
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`15
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`and plurality of magnetic layers) are shown below in Figs 5 and 10.
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`Inter Partes Review of U.S. 9,843,215
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`polymeric
`layer
`
`magnetic
`layer
`magnetic
`layer
`polymeric
`layer
`
`coil
`
`’215 Patent, Fig. 10 (partial, annotated).
`
`first extending
`portion
`
`magnetic
`layer
`
`coil
`
`second
`extending
`portion
`Ex.1001, Fig. 5 (annotated)
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`32. As I explain below, the various limitations added to gain allowance of
`
`the ’215 Patent (polymeric encapsulation, plurality of magnetic layers, and type of
`
`material) were all known in the art when the ’215 patent was filed.
`
`VII. CLAIM CONSTRUCTION
`
`33.
`
`It is my understanding that in order to properly evaluate the ’215
`
`Patent, the terms of the claims must first be interpreted. It is my understanding that
`
`for the purposes of this inter partes review, the claims are to be construed under the
`
`so-called Phillips standard, under which claim terms are given their ordinary and
`
`customary meaning as would be understood by one of ordinary skill in the art in
`
`light of the specification and prosecution history, unless the inventor has set forth a
`
`special meaning for a term. It is my opinion that none of the claim terms require a
`
`specific construction for the purposes of this declaration, and all will be given their
`
`plain and ordinary meaning.
`
`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`
`34.
`
`I have been asked to provide my opinion as to whether the Challenged
`
`Claims of the ’215 Patent would have been obvious in view of the prior art. The
`
`discussion below provides a detailed analysis of how the prior art references
`
`identified below teach the limitations of the Challenged Claims of the ’215 Patent.
`
`35. As part of my analysis, I have considered the scope and content of the
`
`prior art and any differences between the alleged invention and the prior art. I
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`describe in detail below the scope and content of the prior art, as well as any
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`Inter Partes Review of U.S. 9,843,215
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`
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`differences between the alleged invention and the prior art, on an element-by-
`
`element basis for each Challenged Claims of the ’215 Patent.
`
`36. As described in detail below, the alleged invention of the Challenged
`
`Claims would have been obvious in view of the teachings of the identified prior art
`
`references as well as the knowledge of a POSITA.
`
`37.
`
`I further note that the concepts claimed in the ’215 Patent may be
`
`fabricated in different ways. Accordingly, the analysis below provides different
`
`examples (in different grounds) of how the claim elements, such as the adhesive
`
`layer, may be embodied.
`
`A. Ground 1: Claims 1, 8-11, 13, 17, and 19-21 are obvious under 35
`U.S.C. § 103 over Sawa and Park.
`
`1.
`
`Summary of Sawa
`
`
`
`38. Like the ’215 Patent, Sawa relates to a “non-contact power receiving
`
`device.” Sawa, 1:20. In Sawa’s device, a “magnetic sheet 1 [is] provided between
`
`the spiral coil (power receiving coil) 16 and the secondary battery 18.” Sawa,
`
`15:52-54.
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`non-contact type power receiving device
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`Inter Partes Review of U.S. 9,843,215
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`magnetic sheet
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`coil
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`Sawa, Fig. 10
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`39. Sawa describes that the “magnetic sheet for non-contact power
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`receiving device of the embodiment includes a laminate of a plurality of
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`magnetic thin plates.” Sawa, 3:55-57. In particular, Sawa’s magnetic sheet
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`includes an “adhesive layer portion … between the first magnetic thin plate 2 and
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`the second magnetic thin plate 4.” Sawa, 4:32-34. Sawa’s magnetic sheet is shown
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`below.
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`magnetic
`sheet
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`second magnetic
`plate
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`Sawa, Fig. 1 (annotated)
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`40. Sawa further describes an example in which the magnetic sheet is
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`encapsulated in a polymer: “If the magnetic thin plates 2, 4 are affected by
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`corrosion such as rust, covering the entire laminate of the magnetic thin plates 2, 4
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`by the resin film 5 is effective.” Sawa, 5:11-13. “If it is necessary for the magnetic
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`thin plates 2, 4 to be electrically insulated, the resin film 5 covering the entire
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`laminate is effective.” Sawa, 5:13-16. The resin film may include polymeric
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`materials such as “PET film, a PI film, a PPS film, a PP film, a PTFE film, and so
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`on.” Sawa, 5:22-23. Sawa’s encapsulating resin film is shown in Fig. 3 below.
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`first magnetic plate
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`magnetic
`sheet
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`first magnetic plate
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`polymer
`resin
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`Sawa, Fig. 3 (annotated)
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`second magnetic
`plate
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`41. Sawa’s Fig. 3 also illustrates an example in which the first magnetic
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`plate 2 is divided into two separate smaller plates: “a laminate can have a plurality
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`of first magnetic thin plates 2A, 2B.” Sawa, 4:66-67. However, Sawa notes that “If
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`the entire laminate is covered by the resin film 5 as in the magnetic sheet 1 shown
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`in FIG. 3, it is not necessary to provide an adhesive layer portion 3 between the
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`magnetic thin plates of the same kind, for example, between the magnetic thin
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`plate 2A and the magnetic thin plate 2B.” Sawa, 5:16-21. Accordingly, the analysis
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`provided herein will treat layers 2A and 2B as a single “first magnetic plate.”
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`42. Accordingly, Sawa provides evidence that it was known for wireless
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`charging devices to include a plurality of magnetic layers, encapsulated in
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`polymer, against a wireless power coil.
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`2.
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`Summary of Park
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`43. Like Sawa and the ’215 Patent, Park relates to a device for wireless
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`charging. See Park, Abstract. Park also describes that in addition to the wireless
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`Inter Partes Review of U.S. 9,843,215
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`charging coil, the device includes “a plurality of antenna elements.” Park, 1:18-19.
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`Park notes in the background section that it was known to include both a wireless
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`charging coil and NFC antenna on the same device: “To implement both the NFC
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`function and the wireless charging function in a single portable terminal, an NFC
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`antenna element taking the form of a loop antenna and a secondary coil for
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`wireless charging should be mounted in the portable terminal.” Park, 1:54-59.
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`44. Park describes an improvement upon the known concept of having
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`both a wireless charging coil and NFC antenna in the same device: “[T]he present
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`invention is to provide a portable terminal having a structure that facilitates
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`mounting of a secondary coil for wireless charging and a Near Field
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`Communication (NFC) antenna element, without increasing the thickness of the
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`portable terminal.” Park, 2:11-16. The device of Park is shown below.
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`Inter Partes Review of U.S. 9,843,215
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`wireless charging
`coil 133
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`NFC coil 135
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`Park, Figs. 3 and 4 (annotated).
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`45. Accordingly, Park provides evidence that it was known for a portable
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`device to include both a wireless charging coil and a near field communication
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`antenna, particularly on the same plane.
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`3.
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`Reasons to Combine Sawa and Park
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`46.
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`It is my opinion that a POSITA would have been motivated to
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`combine the teachings of Park with those of Sawa. In particular, before the ’215
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`patent, it would have been obvious, beneficial, and predictable for Sawa’s device
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`to include an NFC coil, as taught by Park.
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`47. As an initial matter, one of ordinary skill in the art when considering
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`the teachings of Sawa would have also considered the teachings of Park. Park is
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`analogous prior art pertaining to the same field of endeavor, namely, contactless
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`charging via electromechanical induction. See Sawa, 1:57-2:5; Park, Abstract.
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`Specifically, both references describe a contactless power apparatus having a
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`power-receiving coil. Ex.1005, 1:7-2:5, 3:46-50, Fig. 10; Ex.1006, Abstract.
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`48. Sawa notes that its contactless power apparatus may be implemented
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`in the context of a portable device such as a “cellular phone.” Sawa, 17:14-16, Fig.
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`12. Park explains that “[a]s portable terminals have become a daily commodity,
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`they are equipped with the NFC function.” Park, 1:29-33; see also id. 1:24-26.
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`(“Recently, various functions have been integrated in a single mobile
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`communication terminal called a smart phone.”). Park further explains that to
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`implement an NFC-capable portable terminal, the “portable terminal is provided
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`with an additional antenna for performing the NFC function.” Park, 1:31-33. Thus,
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`as a baseline, it was well known and obvious for a cellular phone, such as Sawa’s,
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`to include an NFC antenna coil as well as a wireless charging coil.
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`49. One of ordinary skill in the art would have been specifically
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`motivated to implement Sawa’s device with an NFC coil because NFC was a
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`standardized data transmission protocol with a multitude of commercial
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`applications and advantages over other short-range wireless communication
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`protocols. For example:
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`
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`• “Evolving from a combination of contactless, identification and networking
`technologies, NFC protocol is a short-range wireless connectivity standard.
`A number of international standards have been established for NFC
`protocols, including for example: ISO/IEC 14443; ISO/IEC 15693; ISO/IEC
`18092; ISO/IEC 21481; ISO/IEC 22536; ISO/IEC 23917; ISO/IEC DIS
`28361; ECMA-340, referred to as NFCIP-1; ECMA-352, referred to as
`NFCIP-2; ECMA-356; ECMA-362; ECMA-373; ECMA/TC32-
`TG19/2006/057; NFC-WI; and NFC-FEC.” Ex.1013, 2:64-3:6; Ex.1012,
`2:9-26.
`• “With close range communications technologies, like NFC protocol devices,
`it is possible to connect any two devices to each other to exchange
`information or access content and services-easily and securely.” Ex.1013,
`3:66-4:2.
`• “Meanwhile, a transport card, a security card, a credit card, and the like can
`be used to make payment or to authenticate a user by a Near Field
`Communication (NFC) function.” Park, 1:27-29.
`50. At the time, “familiar applications of NFC protocol technology [were]
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`electronic pass keys used in building security systems, mass transit fare card
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`systems, and Smart credit cards which need only to be brought close to a point of
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`sale reader to complete a transaction.” Ex.1013, 4:7-11. Relative to other short-
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`range wireless protocols, “NFC technology provides an advantage of fast
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`communication setup between communication devices.” Park, 1:33-36. Further,
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`“the intuitive operation of NFC protocol systems makes the technology particularly
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`easy for consumers to use (‘just touch and go’).” Ex.1013, 4:2-5. Accordingly, a
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`person of ordinary skill in the art would have been motivated to apply Park’s
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`teachings regarding an NF