UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner
`
`v.
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`IPR2022-00118
`U.S. Patent No. 10,804,740
`
`________________
`
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`REVISED MOTION TO AMEND
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner
`
`v.
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`IPR2022-00118
`U.S. Patent No. 10,804,740
`
`________________
`
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`REVISED MOTION TO AMEND
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`TABLE OF CONTENTS
`Petitioner’s Exhibit List ........................................................................................... iii
`
`I.
`
`INTRODUCTION ................................................................................................ 1
`
`II. SUBSTITUTE CLAIMS 21-23 ARE UNPATENTABLE AS OBVIOUS
`UNDER 35 U.S.C. § 103 ........................................................................................... 1
`
`A. Kato Renders Obvious Substitute Claims 21-23 .......................................... 1
`
`1. Substitute Claim 21 ............................................................................... 1
`
`2. Substitute Claim 22 ............................................................................. 14
`
`3. Substitute Claim 23 ............................................................................. 16
`
`III. CONCLUSION ..................................................................................................22
`
`
`
`
`
`ii
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`
`
`Ex.1001
`
`Ex.1002
`
`Ex.1003
`Ex.1004
`
`Ex.1005
`
`Ex.1006
`
`Ex.1007
`
`Ex.1008
`
`Ex.1009
`
`Ex.1010
`Ex.1011
`
`Ex.1012
`
`Ex.1013
`Ex.1014
`
`Ex.1015
`
`Ex.1016
`
`Ex.1017
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`
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`PETITIONER’S EXHIBIT LIST
`
`U.S. Patent No. 10,804,740
`
`Prosecution History of U.S. Patent No. 10,804,740
`
`Declaration of Dr. Joshua Phinney under 37 C.F.R. § 1.68
`Curriculum Vitae of Dr. Joshua Phinney
`
`U.S. Patent Application Publication No. 2009/0021212 to
`Hasegawa et al.
`
`U.S. Patent Application Publication No. 2007/0069961 to Akiho et
`al.
`
`U.S. Patent Application Publication No. 2014/0306656 A1 Tabata
`et al.
`U.S. Patent No. 8,384,263 B2 to Hiramatsu et al.
`
`Reserved
`
`Reserved
`Reserved
`
`Reserved
`
`Reserved
`Reserved
`
`Scheduling Order, Scramoge Technology Limited v. Apple Inc.,
`WDTX-6-21-cv-00579 (filed Sept. 28, 2021)
`
`Plaintiff’s Preliminary Disclosure of Asserted Claims and
`Infringement Contentions to Apple Inc., Scramoge Technology
`Limited v. Apple Inc., WDTX-6-21-cv-00579 (served Sept. 7, 2021)
`
`U.S. Patent Publication Application No. 2008/0164840 to Kato et
`al.
`
`iii
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`
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`Ex.1018
`
`Supplemental Declaration of Dr. Joshua Phinney under 37 C.F.R.
`§ 1.68
`
`Ex.1019
`
`The Merriam-Webster Dictionary, Merriam-Webster, Inc., 1995.
`
`Ex.1020
`
`Ex.1021
`
`Ex.1022
`Ex.1023
`
`The Wayback Machine, capture of “Separate | Define Separate at
`Dictionary.com” on February 7, 2012,
`https://web.archive.org/web/20120207103735/http://dictionary.refe
`rence.com:80/browse/separate
`Second Supplemental Declaration of Dr. Joshua Phinney under
`37 C.F.R. § 1.68
`U.S. Patent No. 9,178,369
`U.S. Patent No. 8,421,574 to Suzuki et al.
`
`iv
`
`
`
`
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`
`I.
`
`INTRODUCTION
`Patent Owner filed a Revised Motion to Amend (“Revised Motion,” Paper
`
`28) with substitute claims 21, 22, and 23. The Revised Motion should be denied
`
`because Patent Owner’s substitute claims are no more novel than the original
`
`claims or the substitute claims in its original Motion to Amend. The Kato reference
`
`again renders obvious Patent Owner’s added limitations as well as the original
`
`limitations under 35 U.S.C. § 103.
`
`II. SUBSTITUTE CLAIMS 21-23 ARE UNPATENTABLE AS OBVIOUS
`UNDER 35 U.S.C. § 103
`The Board should deny Patent Owner’s Revised Motion because substitute
`
`claims 21-23 are obvious in view of Kato (Ex.1017).
`
`A. Kato Renders Obvious Substitute Claims 21-23
`Substitute Claim 21
`1.
`
`[21.0] A wireless power receiver, comprising:
`
`To the extent the preamble is limiting, Kato discloses a wireless power
`
`receiver. Like the ’740 patent, Kato discloses “a noncontact power-transmission
`
`coil for use in power transmission in a noncontact manner using electromagnetic
`
`induction.” Ex.1017, [0003]. Fig. 3 of Kato, annotated below, illustrates a mobile
`
`phone unit 2 having a “secondary power-transmission coil 21” (wireless power
`
`receiver) that wirelessly receives power from “primary power-transmission coil
`
`10” within a cradle 1. Ex.1017, [0049]-[0052], [0058] (“[W]hen an alternating
`
`1
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`
`
`
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`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.”).
`
`secondary power-transmission coil 21 (wireless power receiver)
`
`
`
`
`mobile phone 2
`
`cradle 1
`
`Ex.1017, Fig. 3 (annotated); Ex.1021, 8.
`
`
`
`
`
`Figs. 17-20 of Kato show one example of a power transmission coil 21WD
`
`used for reception of power in a mobile phone like that illustrated in Fig. 3 above.
`
`Ex.1017, [0062], [0079]-[0084]. As shown in annotated Fig. 17 below, the power
`
`transmission coil 21WD is an assembly of elements, including a coil 40 on the
`
`surface of a flexible printed-circuit board 90 that includes a wiring layer 33/34.
`
`Ex.1017, [0081]-[0083].
`
`2
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`secondary power-
`transmission coil 21WD
`(wireless power receiver)
`
`flexible
`printed-circuit
` board 90
`
`planar coil 40
`
`Ex.1017, Fig. 17 (annotated); Ex.1021, 9.
`
`
`
`[21.1] an adhesive layer comprising a receiving space;
`
`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.”) 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. Ex.1017,
`
`[0082].
`
`3
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`Ex.1017, Fig. 19 (annotated); Ex.1021, 10.
`
`
`
`Ex.1017, Fig. 17 (annotated); Ex.1021, 10.
`
`
`
`Although Kato does not utilize the term “receiving space,” a POSITA would
`
`have found it obvious 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. Ex.1021, 10.
`
`This gap allows the first coil contact portion 36 to electrically connect the coil to
`
`the wiring layer of the flexible printed circuit board 90. Ex.1021, 10.
`
`[21.2] a coil on the adhesive layer;
`
`4
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`As shown in annotated Fig. 19 below, 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.” Ex.1017, [0081].
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 11.
`
`
`
`[21.3] a first connection terminal connected to an outer end of the coil;
`
`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. Ex.1017, [0082] (“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.”)
`
`
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`5
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`
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`Ex.1017, Fig. 17 (annotated); Ex.1021, 12.
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 12.
`
`[21.4] a second connection terminal connected to an inner end of the coil;
`
`As shown in annotated Figs. 17 and 19 below, Kato discloses a coil contact
`
`portion 36 (second connection terminal) that is connected to an inner end of the
`
`coil 40. Ex.1017, [0082] (“[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.”)
`
`6
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`
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`Ex.1017, Fig. 17 (annotated); Ex.1021, 13.
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 13.
`
`[21.5] 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
`
`First, as shown in annotated Fig. 18 below, Kato discloses a “flexible
`
`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”
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`7
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`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, as
`
`shown in Fig. 18. Ex.1017, [0082].
`
`inner
`conductors
`33, 34
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`Ex.1017, Fig. 18 (annotated); Ex.1021, 14.
`
`
`
`Fig. 18 also illustrates that Kato’s flexible printed-circuit board (connecting
`
`unit) is discrete. Ex.1017, [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.”). As an aspect of this, Kato
`
`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.” Ex.1017, [0082]. 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,
`
`8
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`such as coil contact portion 35 (first connection terminal) and the coil contact
`
`portion 36 (second connection terminal). Ex.1021, 15.
`
`Second, 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 the adhesion
`
`sheet. Ex.1021, 15.
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 15.
`
`
`
`Third, 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 and charges the phone’s battery. Ex.1017, [0055] (“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-
`
`9
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`transmission coil 21.”), [0049] (“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.”); Ex.1021, 15.
`
`[21.6] 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], Kato’s connecting unit is a “circuit board 90” that
`
`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); Ex.1021, 16.
`
`
`
`As illustrated in Fig. 19 below, the exposed end of the conductor pattern 34 (third
`
`connection terminal) on the circuit board 90 is connected to the coil contact portion
`
`35 (first connection terminal).
`
`10
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`Ex.1017, Fig. 19 (annotated); Ex.1021, 17.
`
`
`
`[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;
`
`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)
`
`Ex.1017, Fig. 18 (annotated); Ex.1021, 17.
`
`
`
`As illustrated in Fig. 19 below, the exposed end of the conductor pattern 33
`
`(fourth connection terminal) on the circuit board 90 is connected to the coil contact
`
`11
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`portion 36 (second connection terminal) at the inner end of the coil 40.
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 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 terminal, and the coil.
`
`As discussed 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]. The
`
`conductor patterns 33 and 34 are respectively connected to their exposed end
`
`portions (third and fourth connection terminals). Ex.1017, [0082]; Ex.1021, 19.
`
`12
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
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`Ex.1017, Fig. 18 (annotated); Ex.1021, 18.
`
`
`Kato also 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. Ex.1017, [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.”). As noted above, 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.” Ex.1017, [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
`
`13
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`terminals to which they might connect, such as coil contact portion 35 (first
`
`connection terminal) and the coil contact portion 36 (second connection terminal).
`
`Ex.1021, 19.
`
`Additionally, Fig. 19 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. Ex.1021, 19.
`
`Coil separated from circuit
`board by adhesive layer 42
`
`Adhesive layer
`Ex.1017, Fig. 19 (annotated); Ex.1021, 20.
`
`
`
`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. Ex.1021, 20.
`
`2.
`
`Substitute Claim 22
`
`[22.0] A wireless power receiver, comprising:
`
`As discussed in [21.0], Kato renders obvious this limitation. Ex.1021, 20.
`
`[22.1] an adhesive layer comprising a receiving space;
`
`14
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`As discussed in [21.1], Kato renders obvious this limitation. Ex.1021, 20.
`
`
`
`[22.2] a coil on the adhesive layer;
`
`
`
`As discussed in [21.2], Kato renders obvious this limitation. Ex.1021, 21.
`
`[22.3] a first connection terminal connected to one end of the coil;
`
`
`
`As discussed in [21.3], Kato renders obvious this limitation. Ex.1021, 21.
`
`[22.4] a second connection terminal connected to another end of the coil; and
`
`As discussed in [21.4], Kato teaches that coil contact portion 36 (second
`
`connection terminal) is connected to another end (i.e., the inner end) of the coil 40.
`
`Ex.1017, [0082] (“[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, Fig. 17 (annotated); Ex.1021, 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;
`15
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`First, as discussed 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. Second, 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]; Ex.1021, 22.
`
`[22.6] wherein the connecting unit comprises: a circuit board; a third connection
`terminal on the circuit board connected to the first connection terminal;
`
`
`
`As discussed in [21.6], Kato renders obvious this limitation. Ex.1021, 22.
`
`[22.7] [wherein the connecting unit comprises:] a fourth connection terminal on
`the circuit board connected to the second connection terminal; and
`
`
`
`As discussed in [21.7], Kato renders obvious this limitation. Ex.1021, 23.
`
`[22.8] [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 terminal, and the coil.
`
`
`
`As discussed in [21.8], Kato renders obvious this limitation. Ex.1021, 23.
`
`3.
`
`Substitute Claim 23
`
`[23.0] The wireless power receiver of claim 22,
`
`See claim 22.
`
`[23.1] wherein the receiving space extends from inside the coil to outside the coil,
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`16
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`As discussed in [21.1], Kato teaches that the adhesive layer includes an inner
`
`
`
`gap (receiving space) corresponding to the “inner peripheral portion 37” of the
`
`coil. Ex.1017, [0082]. 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. 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.”).
`
`Outer
`portion of
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 25.
`
`
`
`Further, the adhesive layer also includes a receiving space where the coil is
`
`received and “stuck” on, as illustrated in Fig. 19 annotated below. Ex.1017, [0081];
`
`Ex.1021, 26 (describing the receiving space for the coil extending along and into
`
`the adhesive layer).
`
`17
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`Outer
`portion of
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 26.
`
`
`
`Accordingly, the receiving space of the adhesive layer 42 extends from inside the
`
`coil 40 to outside the coil 40. Ex.1021, 26.
`
`[23.2] wherein the third connection terminal is connected to the first connection
`terminal horizontally within a boundary defining the receiving space, and
`
`
`
`As illustrated in Fig. 19, annotated below, 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.
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 27.
`
`
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`18
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`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`[23.3] wherein the fourth connection terminal is connected to the second
`connection terminal horizontally within the boundary defining the receiving
`space;
`
`
`
`As illustrated in Fig. 19, annotated below, Kato teaches that the exposed end
`
`of the conductor pattern 33 (fourth connection terminal) is connected to the coil
`
`contact portion 36 (second connection terminal) horizontally within a boundary
`
`defining the receiving space at the inner end of the coil.
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 27.
`
`
`
`[23.4] wherein 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].
`
`[23.5] wherein the adhesive layer has an upper surface and a lower surface
`opposite the upper surface, and;
`
`
`
`As illustrated in Fig. 19, annotated below, Kato’s adhesive layer 42 has an
`
`upper surface and a lower surface opposite the upper surface. Ex.1021, 29. As an
`
`aspect of this, Petitioner notes that the labels “upper” and “lower” are arbitrary
`
`19
`
`
`
`
`
`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`because there is no claimed spatial relationship relative to the other elements in the
`
`wireless power receiver. The only claimed restriction with respect to the two
`
`surfaces is that the lower surface must be “opposite” the upper surface. Ex.1021,
`
`29.
`
`Upper surface
`
`Adhesive layer
`
`Lower surface
`
`Ex.1017, Fig. 19 (annotated);
`Ex.1021, 29.
`
`
`
`
`
`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 POSITA would understand that it was well known
`
`that wireless power receivers in mobile devices were often utilized in vertical
`
`charging orientations, such as in cup holders. Ex.1021, 29-30 (citing Ex.1022,
`
`Figs. 37, 38, 51:63-52:39).
`
`20
`
`
`
`
`
`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`
`Ex.1022, Fig. 38; Ex.1021, 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.
`
`
`
`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]; Ex.2021, 26, 30.
`
`Accordingly, 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. Ex.1021, 30.
`
`21
`
`
`
`
`
`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`
`Upper surface
`
`Adhesive layer
`
`Lower surface
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 31.
`
`
`
`
`
`III. CONCLUSION
`For the reasons discussed above, Patent Owner’s Revised Motion should be
`
`denied.
`
`
`
`
`
`
`
`
`
`
`Dated: January 26, 2023
`
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`Telephone: 972-739-8663
`Facsimile: 214-200-0853
`
`
`
`
`
`Respectfully submitted,
`
`/Scott T. Jarratt/
`Scott T. Jarratt
`Registration No. 70,297
`Counsel for Petitioner
`
`
`
`
`
`
`
`
`22
`
`
`
`
`
`Petitioner’s Opposition to Revised Motion to Amend
`IPR2022-00118 / U.S. Patent No. 10,804,740
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
`
`service was made on the Patent Owner as detailed below.
`
`Date of service January 26, 2023
`
`Persons served
`
`
`
`Manner of service Electronic Mail: bcooper@bc-lawgroup.com;
`jpetrsoric@bc-lawgroup.com; ap@lombardip.com;
`ehuang@lombardip.com; Scramoge_Counsel@b-clg.com
`
`Documents served Petitioner’s Opposition to Patent Owner’s Revised Motion
`to Amend; Exhibits Ex.1021 - Ex.1023
`
`Brett Cooper
`John Petrsoric
`BC Law Group, P.C.
`200 Madison Avenue, 24th Floor
`New York, NY 10016
`
`Antonio Papageorgiou
`Eric Huang
`Lombard & Geliebter LLP
`230 Park Avenue, 4th Floor West
`New York, NY 10169
`
`
`
`
`
`
`
`
`/Scott T. Jarratt/
`Scott T. Jarratt
`Registration No. 70,297
`Counsel for Petitioner
`
`
`23
`
`
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