`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`
`
`APPLE INC.,
`Petitioner
`
`v.
`
`
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`Case IPR2022-00118
`U.S. Patent No. 10,804,740
`
`________________
`
`SUPPLEMENTAL DECLARATION OF JOSHUA PHINNEY, PH.D.,
`UNDER 37 C.F.R. § 1.68
`
`
`
`
`
`
`
`
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`Ex.1021 / IPR2022-00118 / Page 1 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`
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`TABLE OF CONTENTS
`
`A.
`
`B.
`
`Introduction ...................................................................................................... 3
`
`A POSITA would have found substitute claims 21-23 as obvious
`under 35 U.S.C. § 103 over Kato. ................................................................... 4
`
`a.
`
`b.
`
`Kato teaches the wireless power transceiver of Substitute
`Claims 21-23. ........................................................................................ 4
`
`Detailed Analysis .................................................................................. 7
`
`C. Declaration ........................................................................................................ 32
`
`2
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`Ex.1021 / IPR2022-00118 / Page 2 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`I, Joshua Phinney, Ph.D., declare:
`
`A.
`
`Introduction
`1.
`I am the Joshua Phinney, who has previously submitted a declaration
`
`as Ex.1003 and a supplemental declaration as Ex.1018 in this proceeding. The
`
`terms of my engagement, my background and qualifications, prior testimony, and
`
`the legal standards and claim constructions that I am applying are set forth in my
`
`previous CV and declarations. See Ex.1003; Ex.1004; Ex.1018. I am making this
`
`second supplemental declaration at the request of Apple Inc. in the matter of the
`
`Inter Partes Review of U.S. Patent No. 10,804,740 (the “’740 Patent”) to An et al.
`
`2.
`
`In the preparation of this declaration, I have studied the materials
`
`noted in my previous declarations, as well as the following additional materials:
`
`(1) Ex.1022 – U.S. Patent No. 9,178,369 to Partovi; and
`
`(2) Ex.1023 – U.S. Patent No. 9,178,369 to Suzuki et al.
`
`3.
`
`In forming the opinions expressed below, I have considered:
`
`(1) The documents listed above, and
`
`(2) My own knowledge and experience, including my work experience in
`
`the field of networking, as described below.
`
`
`
`
`
`3
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`Ex.1021 / IPR2022-00118 / Page 3 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`
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`B. A POSITA would have found substitute claims 21-23 as obvious under
`35 U.S.C. § 103 over Kato.
`4.
`
`I have been asked to provide my opinion as to whether Substitute
`
`Claims 21-23 of the Revised Motion to Amend (“Revised Motion,” Paper 28)
`
`would have been obvious in view of the prior art. The discussion below provides a
`
`detailed analysis of how the prior art reference identified below teaches the
`
`limitations of the Substitute Claims of the ’740 Patent.
`
`5.
`
`As stated in my previous declaration, I have considered the scope and
`
`content of the prior art and any differences between the alleged invention and the
`
`prior art as part of my analysis. I describe in detail below the scope and content of
`
`the prior art, as well as any differences between the alleged invention and the prior
`
`art, on an element-by-element basis for Substitute Claims 21-23 of the ’740 Patent.
`
`6.
`
`As described in detail below, the alleged invention of the Substitute
`
`Claims 21-23 would have been obvious in view of the teachings of Kato as well as
`
`the knowledge of a POSITA.
`
`a. Kato teaches the wireless power transceiver of Substitute
`Claims 21-23.
`Like the ’740 Patent, Kato relates to a “non-contact power-
`
`7.
`
`transmission coil for use in power transmission in a noncontact manner ... when
`
`charging a rechargeable battery incorporated in a small-size, thin portable terminal
`
`
`
`4
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`Ex.1021 / IPR2022-00118 / Page 4 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`such as a mobile phone unit.” Ex.1017, [0003]. Therefore, Kato describes a “coil”
`
`in a mobile phone unit for wireless power reception via electromagnetic induction:
`
`This invention relates to a noncontact power-transmission coil
`
`for use in power transmission in a noncontact manner using
`
`electromagnetic induction, when charging a rechargeable
`
`battery incorporated in a small-size, thin portable terminal such
`
`as a mobile phone unit.
`
`Id. (emphasis added).
`
`secondary power-transmission coil 21 (wireless power receiver)
`(wireless power receiver)
`mobile phone
`unit 2
`
`cradle 1
`
`Ex.1017, Fig. 3 (annotated)
` (annotated)
`
`
`
`8.
`
`Fig. 3 of Kato, reproduced and annotated above, illustrates a mobile
`
`phone unit 2 having a “secondary power-transmission coil 21” that wirelessly
`
`receives power from “primary power-transmission coil 10” within a cradle 1. Id. at
`
`
`
`5
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`Ex.1021 / IPR2022-00118 / Page 5 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`[0049]-[0052], [0058].
`
`9.
`
`The coil 21 in the mobile phone unit 2 includes the same common
`
`components as the ’740 Patent’s wireless power receiver, arranged in the same
`
`way. Id. at [0080]-[0084] and Figs. 17-20. For example, with reference to Figure
`
`19, reproduced and annotated below, Kato explains that its noncontact power-
`
`transmission coil includes a planar coil 21 on an adhesion sheet (adhesive layer)
`
`42, a receiving space in the adhesive layer, and a flexible printed circuit board 90,
`
`which acts as a connecting unit. Id. at [0080]-[0081].
`
`10. Kato also discloses a second coil contact portion (first connection
`
`terminal) 35 and a first coil contact portion (second connection terminal) 36
`
`connected to an outer and an inner end of the coil 21, respectively. Id. at [0082]. In
`
`particular, Kato discloses: “the first coil contact portion 36 arranged in the inner
`
`peripheral portion 37 of the planar coil, the second coil contact portion 35 arranged
`
`near the outside of the outer peripheral portion 38 of the planar coil.” Id. Figure 17
`
`has been reproduced below and annotated to highlight the first connection terminal
`
`35 and the second connection terminal 36.
`
`
`
`6
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`Ex.1021 / IPR2022-00118 / Page 6 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`
`
`11. As a result, it is my opinion that a POSITA would have found
`
`Substitute Claims 21, 22, and 23 obvious.
`
`Detailed Analysis
`b.
`12. The following claim chart describes how the Kato reference discloses
`
`the new Substitute Claims 21, 22, and 23 in the Revised Motion.
`
`Prior Art
`Claim 21
`Challenge: Substitute Claim 21 is unpatentable under 35 U.S.C. § 103 over Kato.
`
`[21.0] A
`wireless
`power
`receiver,
`comprising:
`
`
`
`
`
`
`
`Kato discloses a wireless power receiver.
`
`“[A] noncontact power-transmission coil for use in power
`transmission in a noncontact manner using electromagnetic
`induction.” Ex.1017, [0003].
`
`
`
`7
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`Ex.1021 / IPR2022-00118 / Page 7 of 32
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`secondary power-transmission coil 21 (wireless power receiver)
`(wireless power receiver)
`
`mobile phone
`unit 2
`
`cradle 1
`
`
`
`Ex.1017, Fig. 3 (annotated)
` (annotated)
`
`
`
`As shown above in Fig. 3, a mobile phone unit 2 is
`illustrated having a “secondary power-transmission coil 21”.
`
`The secondary transmission coil 21 (wireless power receiver)
`wirelessly receives power from the “primary power transmission
`coil 10 within a cradle 1. Id. at [0049]-[0052].
`
`“[W]hen an alternating voltage is induced in the secondary
`power-transmission coil 21 with the alternating voltage from the
`primary power-transmission coil 10 of the cradle 1, the mobile
`phone unit 2 rectifies the induced alternating voltage and then
`converts it into a direct current voltage, followed by charging the
`battery 22 with the direct current voltage.” Id. at [0058] (emphasis
`added).
`
`Figs. 17-20 of Kato illustrate one example of a power transmission
`coil 21 WD for reception of power in a mobile phone like shown in
`Fig. 3 above. The power transmission coil 21 WD used as shown
`below in Fig. 17, the power transmission coil 21WD is an
`assembly of elements, including a coil 40 on the surface on the
`
`
`
`8
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`Ex.1021 / IPR2022-00118 / Page 8 of 32
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`surface of a flexible printed-circuit board 90 that includes a wiring
`layer 33/34. Id. at [0081]-[0083].
`
`
`
`secondary power-
`transmission coil 21WD
`(wireless power
`receiver)
`
`flexible
`printed-circuit
` board 90
`
`
`
`[21.1] an
`adhesive layer
`comprising a
`receiving
`space;
`
`
`
`planar coil 40
`
`
`
`Ex.1017, Fig. 17 (annotated)
` (annotated)
`Kato discloses “an adhesive layer comprising a receiving space.”
`
`In particular, Kato discloses that the power transmission coil
`21WD shown in annotated Fig. 19 below includes an “adhesion
`sheet 42” (adhesive layer) that is used to adhere the coil 40 to the
`flexible printed circuit board 90. Ex. 1017, [0081].
`
`“One flat surface of the planar coil formed of the wound electric
`wire 40 is stuck on the surface of the flexible printed-circuit
`board 90 though an adhesion sheet 42.” Id. (Emphasis added).
`
`As shown in annotated Figs. 19 and 17 below, the adhesive layer
`42 includes a gap (receiving space) corresponding to the “inner
`peripheral portion 37” of the coil 40 to accommodate (i.e., receive)
`the first coil contact portion 36. Id. at [0082].
`
`
`
`
`9
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`Ex.1021 / IPR2022-00118 / Page 9 of 32
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`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`Ex.1017, Fig. 17 (annotated)
` (annotated)
`
`
`
`
`The gap allows the first coil contact portion 36 to electrically
`connect the coil to the wiring layer of the flexible printed board 90.
`
`While the term “receiving space” is not used in Kato, it would be
`obvious for a person of ordinary skill in the art to find that the gap
`in Kato’s adhesion sheet is a receiving space because it is a space
`that receives the first coil contact portion 36.
`
`
`
`
`
`10
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`Ex.1021 / IPR2022-00118 / Page 10 of 32
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`[21.2] a coil on
`the adhesive
`layer;
`
`
`
`Kato discloses “a coil on the adhesive layer.”
`
`Kato teaches that a “planar coil formed of the wound electric wire
`40 is stuck on the surface of the flexible printed-circuit board 90
`through an adhesion sheet 42,” as shown in Fig. 19. Ex.1017,
`[0081].
`
`
`
`[21.3] a first
`connection
`terminal
`connected to
`an outer end
`of the coil;
`
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
`
` (annotated)
`Kato teaches “a first connection terminal connected to an outer end
`of the coil.”
`
`“The second coil contact portion 35 is electrically connected to the
`electric wire end at the end of the winding of the outer peripheral
`portion 38 of the planar coil.” Ex.1017, [0082].
`
`As shown in annotated Figs. 17 and 19 below, Kato discloses a coil
`contact portion 35 (first connection terminal) that is connected to
`an outer end of the coil 40. Id.
`
`
`
`
`
`11
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`Ex.1021 / IPR2022-00118 / Page 11 of 32
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`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
`
` (annotated)
`Kato discloses: “a second connection terminal connected to an inner
`end of the coil.”
`
`“[T]he first coil contact portion 36 is electrically connected to the
`electric wire end at the start of the winding of inner peripheral
`portion 37 of the planar coil.” Ex.1017, [0082].
`
`As shown in annotated Figs. 17 and 19 below, Kato discloses a coil
`contact portion 36 (second connection terminal) that is connected to
`
`12
`
`[21.4] a second
`connection
`terminal
`connected to
`an inner end
`of the coil;
`
`
`
`
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`Ex.1021 / IPR2022-00118 / Page 12 of 32
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`an inner end of the coil 40. Id.
`
`
`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`Kato discloses: “a discrete connecting unit, the connecting unit
`overlapping the receiving space and disposed in a vertical direction
`perpendicularly above or below the adhesive layer and connected to
`a circuit separate from the connecting unit.”
`
`As shown in annotated Fig. 18 below, Kato discloses a “flexible
`
`13
`
`[21.5] a
`discrete
`connecting
`unit, the
`connecting
`unit
`
`
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`Ex.1021 / IPR2022-00118 / Page 13 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`overlapping
`the receiving
`space and
`disposed in a
`vertical
`direction
`perpendicularl
`y above or
`below the
`adhesive layer
`and connected
`to a circuit
`separate from
`the connecting
`unit,
`
`
`
`printed-circuit board 90” (discrete connecting unit) “with an
`insulating layer and formed so as to substantially fit to the shape of
`the flat surface of the planar coil.” Ex.1017, [0082].
`
`The circuit board 90 includes “first inner conductor pattern 33” and
`“second inner conductor pattern 34” that are “formed under the
`surface insulating layer” to electrically connect the coil to the
`connections 31 and 32. Id.
`
`
`inner
`conductors
`33, 34
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`“FIG. 18 is a schematic front view of the noncontact power-
`transmission coil in which the planar coil shown in FIG. 17 is not
`stuck on the flexible printed-circuit board.” Ex.1017, [0034].
`
`As shown above in Fig. 18, shows that Kato’s flexible printed-
`circuit board 90 (connecting unit) is discrete. Id.
`
`Kato further explains that the board’s insulating layer is not formed
`at the inner or outer portion of the coil such that “the inner
`conductor of the flexible printed-circuit board 90 is exposed to the
`outside.” Id. at [0082] (emphasis added).
`
`
`
`
`14
`
`Ex.1021 / IPR2022-00118 / Page 14 of 32
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`Because the board’s inner conductor is exposed to the outside (at
`least at some point during manufacture), it may be considered
`discrete from any connection terminals to which they might
`connect, such as coil contact portion 35 (first connection terminal)
`and the coil contact portion 36 (second connection terminal).
`
`Additionally, as shown in annotated Fig. 19 below, the flexible
`printed circuit board 90 (connecting unit) overlaps the gap in the
`adhesion sheet 42 (receiving space) and is disposed in a vertical
`direction perpendicularly below to the adhesion sheet.
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`Moreover, Kato teaches that the circuit board 90 of the secondary
`power-transmission coil 21WD is connected to a separate “charging
`control circuit” in the mobile phone that detects a voltage change in
`the secondary power-transmission coil:
`
`
`
`“The charging control circuit of the mobile phone unit 2 according
`to the embodiment is allowed to detect a voltage change in response
`to a change in magnetic field of the secondary power-transmission
`coil 21.” Id. at [0055].
`
`
`
`15
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`Ex.1021 / IPR2022-00118 / Page 15 of 32
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`[21.6]
`wherein the
`connecting
`unit
`comprises: a
`circuit board;
`a third
`connection
`terminal on
`the circuit
`board
`connected to
`the first
`connection
`terminal;
`
`
`
`
`
`“The electronic circuits include a charging control circuit that
`charges the battery 22 by supplying the received power to the
`battery 22 through the secondary power-transmission coil 21.” Id. at
`[0049].
`
`Kato discloses: “ wherein the connecting unit comprises: a circuit
`board; a third connection terminal on the circuit board connected to
`the first connection terminal.”
`
`As described in [21.5], the circuit board 90 (connecting unit)
`includes a second inner conductor pattern 34 with an “exposed” end
`at the outer end of the coil 40. Ex.1017, [0082].
`
`inner
`conductor
`34 with
`exposed
`end
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`As illustrated in Fig. 19 below, the exposed end of the conductor
`pattern 34 (third connection terminal) is connected to the coil
`contact portion 35 (first connection terminal).
`
`
`
`
`
`
`16
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`Ex.1021 / IPR2022-00118 / Page 16 of 32
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`Ex.1017, Fig. 19 (annotated)
`
`
`
`
`Kato discloses: “a fourth connection terminal on the circuit board
`connected to the second connection terminal at the inner end of the
`coil.”
`
`As described in [21.5], the circuit board 90 (connecting unit)
`includes a first inner conductor pattern 33 with an “exposed” end at
`the inner end of the coil 40. Ex.1017, [0082].
`
`inner
`conductor
`33 with
`exposed end
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`[21.7]
`[wherein the
`connecting
`unit
`comprises:] a
`fourth
`connection
`terminal on
`the circuit
`board
`connected to
`the second
`connection
`terminal at the
`inner end of
`the coil;
`
`Ex.1017, Fig. 18 (annotated)
`As illustrated in Fig. 19 below, the exposed end of the conductor
`pattern 33 (fourth connection terminal) is connected to the coil
`
`
`
`
`
`17
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`Ex.1021 / IPR2022-00118 / Page 17 of 32
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`contact portion 36 (second connection terminal) at the inner end of
`the coil 40.
`
`
`Ex.1017, Fig. 19 (annotated)
`
`
`
`Kato discloses: “a wiring layer on the circuit board connected to the
`third connection terminal and the fourth terminal, wherein the
`connecting unit is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil.”
`
`As described in [21.5], and as shown in Fig. 18 below, the printed
`circuit board 90 (connecting unit) includes first inner conductor
`pattern 33 and second inner conductor pattern 34 (together the
`wiring layer). Ex.1017, [0082].
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`
`
`18
`
`[21.8]
`[wherein the
`connecting
`unit
`comprises:] a
`wiring layer
`on the circuit
`board
`connected to
`the third
`connection
`terminal and
`the fourth
`terminal,
`wherein the
`connecting
`unit is
`otherwise
`separate from
`the first
`connection
`terminal, the
`second
`connection
`
`
`
`Ex.1021 / IPR2022-00118 / Page 18 of 32
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`
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`terminal, and
`the coil.
`
`
`
`
`As shown in Fig. 18 above, the conductor patterns 33 and 34 are
`respectively connected to their exposed end portions (third and
`fourth connection terminals). Id.
`
`Moreover, Kato renders obvious, under any interpretation, that the
`circuit board 90 (connecting unit) is otherwise separate from the
`first connection terminal, the second connection terminal, and the
`coil.
`
`For example, Fig. 18 above illustrates that the circuit board 90 is a
`separate element and separable from the other elements of Kato’s
`device, including the planar coil. Id. at [0034].
`
`“FIG. 18 is a schematic front view of the noncontact power-
`transmission coil in which the planar coil shown in FIG. 17 is not
`stuck on the flexible printed-circuit board.” Id. at [0034].
`
`Kato further explains that the board’s insulating layer is not formed
`at the inner or outer portion of the coil such that “the inner
`conductor of the flexible printed-circuit board 90 is exposed to the
`outside.” Id. at [0082].
`
`Because the board’s inner conductor is exposed to the outside (at
`least at some point during manufacture), it may be considered
`separate from any connection terminals to which they might
`connect, such as coil contact portion 35 (first connection terminal)
`and the coil contact portion 36 (second connection terminal).
`
`Fig. 19 below illustrates that the circuit board 90 (connecting unit)
`is physically separated from the coil by the adhesive layer and also
`from first and second connection terminals other than where they
`connect to the circuit board’s third and fourth connection terminals.
`
`
`
`19
`
`Ex.1021 / IPR2022-00118 / Page 19 of 32
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`Coil separated from circuit
`board by adhesive layer 42
`
`Adhesive layer
`
`Ex.1017, Fig. 19 (annotated)
`
`Accordingly, under any interpretation, the circuit board 90
`(connecting unit) is:
`
` (i) a separate element,
`
`(ii) separable, and
`
`(iii) physically separated from the from the coil and the first and
`second connection terminals beyond their connections to the third
`and fourth connection terminals.
`
`Prior Art
`Claim 22
`Challenge: Substitute Claim 22 is unpatentable under 35 U.S.C. § 103 over Kato.
`
`[22.0] A
`wireless
`power
`receiver,
`comprising:
`
`
`[22.1] an
`adhesive layer
`comprising a
`
`
`
`
`
`
`
`Kato discloses “[a] wireless power receiver,” as described above in
`[21.0].
`
`
`
`
`Kato discloses “an adhesive layer comprising a receiving space,”
`as described above in [21.1].
`
`
`20
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`Ex.1021 / IPR2022-00118 / Page 20 of 32
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`receiving
`space;
`
`
`[22.2] a coil
`on the
`adhesive
`layer;
`
`[22.3] a first
`connection
`terminal
`connected to
`one end of the
`coil;
`
`[22.4] a
`second
`connection
`terminal at
`another end of
`the coil; and
`
`
`
`
`
`
`
`Kato discloses “a coil on the adhesive layer,” as described above in
`[21.2].
`
`
`Kato discloses “a first connection terminal connected to one end of
`the coil,” as described in [21.3].
`
`
`
`
`
`
`Kato discloses “a second connection terminal at another end of the
`coil,” as described below and in [21.4].
`
`“[T]he first coil contact portion 36 is electrically connected to the
`electric wire end at the start of the winding of inner peripheral
`portion 37 of the planar coil.” Ex.1017, [0082].
`
`Kato teaches that coil contact portion 36 (second connection
`terminal) is connected to another end (i.e., the inner end) of the coil
`40.
`
`
`
`21
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`Ex.1021 / IPR2022-00118 / Page 21 of 32
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`Ex.1017, Fig. 17 (annotated)
`
`
`Kato discloses: “a discrete connecting unit, the connecting unit
`disposed corresponding to the receiving space and connected to a
`circuit separate from the connecting unit,” as described below and
`above in [21.5].
`
`Kato renders obvious a “discrete connecting unit” that is “connected
`to a circuit separate from the connecting unit.” Ex.1017, [0055],
`[0082], [0034], [0049], Figs. 17, 18.
`
`With respect to “the connecting unit disposed corresponding to the
`receiving space,” the flexible printed circuit board (connecting unit)
`is disposed corresponding to the gap in the adhesion sheet 42
`(receiving space) because the circuit board is specifically positioned
`beneath the gap to expose circuit board’s inner conductor pattern 33.
`Ex.1017, [0082].
`
`Kato discloses: “ wherein the connecting unit comprises: a circuit
`board; a third connection terminal on the circuit board connected to
`the first connection terminal,” as described above in [21.6].
`
`
`
`22
`
`[22.5] a
`discrete
`connecting
`unit, the
`connecting
`unit disposed
`corresponding
`to the
`receiving
`space and
`connected to a
`circuit
`separate from
`the connecting
`unit;
`
`[22.6]
`wherein the
`connecting
`unit
`comprises: a
`circuit board;
`
`
`
`Ex.1021 / IPR2022-00118 / Page 22 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`a third
`connection
`terminal on
`the circuit
`board
`connected to
`the first
`connection
`terminal;
`
`
`
`[22.7]
`[wherein the
`connecting
`unit
`comprises:] a
`fourth
`connection
`terminal on
`the circuit
`board
`connected to
`the second
`connection
`terminal; and
`
`
`
`
`
`[22.8] ]
`[wherein the
`connecting
`unit
`comprises:] a
`wiring layer
`on the circuit
`
`
`
`
`
`Kato discloses: “a fourth connection terminal on the circuit board
`connected to the second connection terminal,” as discussed above in
`[21.7].
`
`
`
`
`
`Kato discloses: “a wiring layer on the circuit board connected to the
`third connection terminal and the fourth terminal, wherein the
`connecting unit is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil,” as described
`above in [21.8].
`
`23
`
`Ex.1021 / IPR2022-00118 / Page 23 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`board
`connected to
`the third
`connection
`terminal and
`the fourth
`terminal,
`wherein the
`connecting
`unit is
`otherwise
`separate from
`the first
`connection
`terminal, the
`second
`connection
`terminal, and
`the coil.
`
`
`
`Claim 23
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Challenge: Substitute Claim 23 is unpatentable under 35 U.S.C. § 103 over Kato.
`
`[23.0] The
`wireless
`power
`receiver of
`claim 22,
`
`[23.1]
`wherein the
`receiving
`space extends
`
`
`
`Kato renders obvious the wireless power receiver of claim 22. See
`claim 22.
`
`Kato discloses: “the receiving space extends from inside the coil to
`outside the coil.”
`
`As discussed in [21.1], Kato teaches that the adhesive layer includes
`
`24
`
`Ex.1021 / IPR2022-00118 / Page 24 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`from inside
`the coil to
`outside the
`coil,
`
`
`
`an inner gap (receiving space) corresponding to the “inner
`peripheral portion 37” of the coil. Ex.1017, [0082].
`
`“That is, a surface insulating layer is not formed on any of the first
`coil contact portion 36 arranged in the inner peripheral portion 37 of
`the planar coil, the second coil contact portion 35 arranged near the
`outside of the outer peripheral portion 38 of the planar coil.” Id.
`
`Kato also teaches that the adhesive layer includes an outer gap
`(receiving space) corresponding to the “outer peripheral portion 38”
`of the coil to avoid the second coil contact portion 35. See, id.
`
`
`Outer
`portion of
`Receiving Space
`
`
`
`Ex.1017, Fig. 19 (annotated)
`
`
`
`Further, the adhesive layer also includes a receiving space on its
`surface where the coil is received and adhered, as illustrated in Fig.
`19 annotated below.
`
`
`
`
`
`
`25
`
`Ex.1021 / IPR2022-00118 / Page 25 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`Outer
`portion of
`Receiving
`Space
`
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`As an aspect of this, a POSITA would understand that the receiving
`space for the coil along the adhesive layer would extend into the
`adhesive layer to some extent. For example, when the coil is “stuck”
`on the adhesive layer 42, as described by Kato (Ex.1017, [0081]),
`the pressing of the coil into the adhesive would cause the adhesive
`to deform and bear an impression of the coil. I note this was
`common in the wireless power receiver field. See, e.g., Ex.1023,
`Fig. 3, 8:8-12, 8:66-9:1 (describing a wireless power coil being
`“stuck on” a magnetic layer with “pressure sensitive adhesive” by a
`method of “pressing”).
`
`Accordingly, the receiving space of the adhesive layer 42 extends
`from inside the coil 40 to outside the coil 40.
`Kato discloses that “the third connection terminal is connected to
`the first connection terminal horizontally within a boundary
`defining the receiving space.”
`
`
`26
`
`[23.2]
`wherein the
`third
`connection
`terminal is
`connected to
`the first
`connection
`terminal
`horizontally
`within a
`boundary
`
`
`
`Ex.1021 / IPR2022-00118 / Page 26 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`defining the
`receiving
`space, and
`
`
`
`
`
`[23.3]
`wherein the
`fourth
`connection
`terminal is
`connected to
`the second
`connection
`terminal
`horizontally
`within the
`boundary
`defining the
`receiving
`space;
`
`
`
`
`
`
`
`As shown in Fig. 19, which is annotated above, Kato teaches that
`the exposed end of the conductor pattern 34 (third connection
`terminal) is connected to the coil contact portion 35 (first
`connection terminal) horizontally within a boundary defining the
`receiving space at the outer end of the coil.
`
`Kato discloses: “the fourth connection terminal is connected to the
`second connection terminal horizontally within the boundary
`defining the receiving space.”
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`As shown in Fig. 19, which is annotated above, Kato teaches that
`the exposed end of the conductor pattern 33 (fourth connection
`terminal) is connected to the coil contact portion 36 (second
`
`
`
`
`
`27
`
`Ex.1021 / IPR2022-00118 / Page 27 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`connection terminal) horizontally within a boundary defining the
`receiving space at the inner end of the coil.
`Kato discloses: “the connecting unit circuit board comprises at least
`one of a flexible circuit board and a tape substrate.”
`
`As discussed in [21.5], Kato’s connecting unit is a “flexible printed-
`circuit board.” Ex.1017, [0082].
`
`Kato discloses: “the adhesive layer has an upper surface and a lower
`surface opposite the upper surface.”
`
`[23.4]
`wherein the
`connecting
`unit circuit
`board
`comprises at
`least one of a
`flexible circuit
`board and a
`tape substrate;
`
`[23.5] wherein
`the adhesive
`layer has an
`upper surface
`and a lower
`surface
`opposite the
`upper surface,
`and
`
`
`
`
`
`28
`
`Ex.1021 / IPR2022-00118 / Page 28 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`Upper surface
`
`Adhesive layer
`
`Lower surface
`
`Ex.1017, Fig. 19 (annotated)
`
`
`
`
`As illustrated in Fig. 19, annotated above, Kato’s adhesive layer 42
`has an upper surface and a lower surface opposite the upper surface.
`
` A
`
` person of ordinary skill in the art would view the labels “upper”
`and “lower” as arbitrary with respect to other elements in the
`claimed wireless power receiver. The only claimed restriction with
`respect to the two surfaces is that the lower surface must be
`“opposite” the upper surface.
`
`To the extent it is argued that “upper” and “lower” have some
`inherent meaning with respect to the environment outside of the
`claimed wireless power receiver (which they do not), a person of
`ordinary skill in the art would understand that it was well known
`that wireless power receivers in mobile devices were often utilized
`in vertical charging orientations. For example, mobile devices were
`
`
`
`29
`
`Ex.1021 / IPR2022-00118 / Page 29 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`often oriented in a vertical orientation to wirelessly charge when
`placed in a cup holder with a charging coil:
`
`Ex.1022, Fig. 38
`
`
`
`Ex.1022, Figs. 37, 38, 51:63-52:39.
`
`Kato discloses: “the receiving space extends between the upper
`surface and lower surface of the adhesive layer continually from
`inside the coil to outside the coil.”
`
`As discussed in [23.1], the adhesive layer includes a portion of the
`receiving space where the coil is received and “stuck” on. Ex.1017,
`[0081].
`
`And, as illustrated in Fig. 19 below, the receiving space extends at
`least between the upper surface and lower surface of the adhesive
`layer 42 continually from inside the coil 40 to outside the coil 40.
`
`30
`
`[23.6] wherein
`the receiving
`space extends
`between the
`upper surface
`and lower
`surface of the
`adhesive layer
`continually
`from inside
`the coil to
`outside the
`coil.
`
`
`
`Ex.1021 / IPR2022-00118 / Page 30 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Upper surface
`
`Adhesive layer
`
`Lower surface
`
`Ex.1017, Fig. 19 (annotated)
`
`
`
`31
`
`Ex.1021 / IPR2022-00118 / Page 31 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`C. Declaration
`13.
`
`I declare that all statements made herein on my own knowledge are
`
`true and that all statements made on information and belief are believed to be true,
`
`and further, that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`Date: ___________
`
`
`
`
`
`Executed:
`
`
`
`
`
`
`
`Joshua Phinney, Ph.D.
`
`
`
`
`
`32
`
`Ex.1021 / IPR2022-00118 / Page 32 of 32
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
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