UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`____________
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`APPLE INC.,
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`Petitioner,
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`v.
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`SCRAMOGE TECHNOLOGY LTD.,
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`Patent Owner.
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`____________
`
`Case IPR2022-00118
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`Patent 10,804,740
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`
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`_______________________________________________________________
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`REPLY TO PETITIONER’S OPPOSITION TO PATENT
`OWNER’S REVISED MOTION TO AMEND
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`
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`i
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`Table of Contents
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. Legal standard – 35 U.S.C. § 103 Obviousness .................................................. 1
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`III. Overview of the ’740 Patent. .............................................................................. 1
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`IV. U.S. Patent Pub. No. 2008/0164840 (“Kato”). ................................................... 2
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`V. PETITIONER HAS NOT SHOWN THAT PROPOSED CLAIMS 21-23 ARE
`UNPATENTABLE .................................................................................................... 3
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`a. Petitioner has not shown that Kato teaches or suggests a “discrete connecting
`unit” that “is otherwise separate from the first connection terminal, the second
`connection terminal, and the coil” of claims 21-23. ........................................... 3
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`i.Claim Construction. .................................................................................. 3
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`b. ........... Petitioner’s failure to construe essential claim limitations is fatal to its
`opposition of Patent Owner’s Motion to Amend. ............................................... 4
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`c. .... Kato does not disclose a connecting unit that is “otherwise separate” when
`this limitation of claims 21-22 is properly construed. ........................................ 5
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`d. .... Petitioner has not explained how or why a POSITA would modify Kato to
`achieve the invention of claims 21-22. ............................................................... 7
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`e.Petitioner has not shown that the Kato discloses or suggests the limitations of
`claim 23. .............................................................................................................. 7
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`i. Claim Construction. ................................................................................. 7
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`f. ................ Kato does not disclose the “receiving space” limitation of claim 23.
` ...........................................................................................................................10
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`VI. CONCLUSION .................................................................................................12
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`ii
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`
`
`
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`Cases
`Cases
`
`CasesCases
`
`Table of Authorities
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`Aqua Products Inc. v. Matal, 872 F.3d 1290 (Fed. Cir. 2017) (en banc) .................. 1
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`ARENDI SARL v. Apple Inc., 832 F. 3d 1355 (Fed. Cir. 2016) ................................ 1
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`DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469 F.3d 1005 (Fed. Cir.
`
`2006) ....................................................................................................................... 3
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`Graham v. John Deere Co., 383 US 1 (1966) ........................................................... 7
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`Jiawei Tech. (HK) Ltd. v. Richmond, IPR2014-00937 (PTAB Dec. 16, 2014) ........ 5
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`Oatey Co. v. IPS Corp., 14 F.3d 1271 (Fed. Cir. 2008) ............................................ 6
`
`
`
`Statutes
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`35 U.S.C. § 103(a) ..................................................................................................... 1
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`37 C.F.R. § 42.121(d)(2) ............................................................................................ 1
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`iii
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`I.
`
`INTRODUCTION
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`Petitioner argues that the substitute claims are obvious under 35 U.S.C. §
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`103 over a single reference, U.S. Patent Publication Application No. 2008/0164840
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`(“Kato”) without showing how or why one skilled in the art would modify Kato to
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`arrive at the claimed invention. The Board should therefore grant Patent Owner’s
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`contingent Revised Motion to Amend (Paper 28) and substitute original claims 6,
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`16, and 17 of U.S. Patent No. 10,804,740 (the “’740 Patent”) with substitute claims
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`21, 22, and 23, respectively, if the original claims of the ’740 Patent are found
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`unpatentable.
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`II.
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`Legal standard – 35 U.S.C. § 103 Obviousness
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`Petitioner has the burden of showing that the amended claims are
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`unpatentable over the prior art by a preponderance of the evidence. 37 C.F.R. §
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`42.121(d)(2); Aqua Products Inc. v. Matal, 872 F.3d 1290, 1324 (Fed. Cir. 2017)
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`(en banc). When alleging that claims of a patent are obviousness over a single prior
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`art reference, Petitioner must explain how and why one skilled in the art would
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`“modify that reference to arrive at the claimed invention.” ARENDI SARL v. Apple
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`Inc., 832 F. 3d 1355, 1361 (Fed. Cir. 2016) (citing K/S Himpp v. Hear-Wear
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`Techs., LLC, 751 F.3d 1362 (Fed. Cir. 2014)).
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`III.
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`Overview of the ’740 Patent.
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`As explained in Patent Owner’s Response (Paper 17 at p. 2-5), the ’740
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`Patent teaches a wireless power receiver that uses a discrete connecting unit to
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`interconnect the coil of the wireless power receiver to a separate circuit. Ex. 1001,
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`5:30-33, see, e.g., Figs. 26-28. The ’740 Patent provides that the overall thickness
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`1
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`of the wireless power receiver (1000) can be reduced by as much as the thickness
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`of the connecting unit (300) with an adhesive layer (710) having a receiving space
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`(130) configured to receive at least a portion of the thickness of connecting unit.
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`Id., 1:20-2:53; 8:50-54; 16:4-13; 18:46-53; Figs. 26-28. 1:20-2:53. As shown in,
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`e.g., Fig. 28, the adhesive layer (710) has an upper surface and a lower surface (top
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`planer surface and opposite bottom planer surfaces) that generally define the
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`thickness of the adhesive layer. The adhesive layer (710) has a portion cut out
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`therefrom, which is identified as the receiving space (130), that disrupts the
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`otherwise continuous adhesive layer (710). The receiving space (130) extends
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`outward from the inside of the coil (220/320) so that the interconnection at the
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`outside of the coil (at 210/310) falls within the boundary of the receiving space
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`when viewed from the top. See id., Fig. 26-27.
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`IV.
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`U.S. Patent Pub. No. 2008/0164840 (“Kato”).
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`Kato is directed to a “noncontact power-transmission coil [that] includes a
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`planar coil and a printed-circuit board. The planar coil is formed by spirally
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`winding a linear conductor made of a single or twisted wire in a substantially same
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`plane.” Ex. 1017, Abstract. Kato’s disclosure provides only for the planar coil to
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`be adhered to the flexible printed-circuit board when the noncontact power-
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`transmission coil is fully assembled. Id. at [0034], [0043], [0065-66], [0080-82],
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`[0097] (all explaining that the planar coil is “stuck” to the flexible circuit board).
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`Kato consistently teaches that the adhesion sheets 41, 42, 43 cover the entirety of
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`the planar portion of the coil to which the adhesion sheets are attached. Id., [0065],
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`2
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`Figs. 2, 6, 19-20, 26. There is no instance in Kato of a noncontact power-
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`transmission coil where the coil is not entirely adhered to the circuit board. See,
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`Prelim. Guidance, Paper 26 at p. 9-10.
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`V.
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`PETITIONER HAS NOT SHOWN THAT PROPOSED CLAIMS 21-23
`ARE UNPATENTABLE
`
`a. Petitioner has not shown that Kato teaches or suggests a “discrete
`connecting unit” that “is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil” of claims 21-23.
`i. Claim Construction.
`
`Claims 21 and 22 expressly require that the wireless power receiver has a
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`discrete connecting unit that has a circuit board with third and fourth connection
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`terminals, as well as a wiring layer thereon. Claims 21 and 22 also require that the
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`connecting unit terminals are connected to the first and second connection
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`terminals of the coil, respectively, but the connection unit “is otherwise separate
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`from the first connection terminal, the second connection terminal, and the coil”
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`(the “otherwise separate” limitation). In this respect, the claimed wireless power
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`receiver requires a coil and a connecting unit that are connected to each other only
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`via the first-third and second-forth connection terminal interconnections.
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`This interpretation is consistent with both the intrinsic and the extrinsic
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`evidence in the record. DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469
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`F.3d 1005, 1014 (Fed. Cir. 2006). Specifically, the claimed “otherwise separate”
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`requirement refers back to the preceding limitations relating to the first-third and
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`second-forth interconnections in both claims 21-22, which means the coil and the
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`connecting unit have no other connections. See Ex. 2024 (defining “otherwise” as
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`3
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`“something to the contrary”). As such, the express language of the claims requires
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`that the discreet connecting unit is not connected to the coil, except at the
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`interconnection of the first-third and second-fourth terminal connections. The
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`specification supports this interpretation by consistently referring to the connecting
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`unit as a discrete unit that is not connected to the coil, except at the connection
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`terminal interconnections, as discussed in Section III supra. Finally, this
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`interpretation is supported by dictionary definitions: Ex. 1019, Ex. 1020, and Ex.
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`2023. See also, Prelim. Guidance, Paper 26, pp. 7-8.
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`The Board should apply Patent Owner’s interpretation for the “otherwise
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`separate” limitation of claims 21-22, which requires that the connecting unit and
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`the coil are not connected, except at the interconnection of the first-third and
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`second-fourth terminal connections.
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`b. Petitioner’s failure to construe essential claim limitations is fatal to
`its opposition of Patent Owner’s Motion to Amend.
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`Petitioner did not expressly construe any terms of claims 21-22. Petitioner
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`instead argues with respect to claim element [21.8] that “Kato also renders
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`obvious, under any interpretation, that the circuit board 90 (connecting unit) is
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`otherwise separate from the first connection terminal, the second connection
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`terminal, and the coil.” Paper 34, Opp. at p. 13 (citing Fig. 18). Because Petitioner
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`has not provided any construction or analysis of the “otherwise separate”
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`limitation, which is critical to the understanding of the scope of proposed claims
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`21-22, the Board must find that Petitioner has failed to satisfy its burden of
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`persuasion. See Jiawei Tech. (HK) Ltd. v. Richmond, IPR2014-00937, Paper 24 at
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`4
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
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`7-8 (PTAB Dec. 16, 2014).
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`c. Kato does not disclose a connecting unit that is “otherwise separate”
`when this limitation of claims 21-22 is properly construed.
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`As discussed above, Kato’s power transmission coil (21WS) is, in contrast to
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`claims 21-22, a unitary assembly that includes a spirally wound coil (40) that is
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`“stuck” at one of the planer portions to the flexible circuit board (30) via adhesion
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`sheet (42). See Section IV, supra. The flexible circuit board (30) cannot therefore
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`be a discrete connecting unit, that is not connected to the coil, except at the claimed
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`interconnections, because once the coil (40) is “stuck” to the circuit board (30), the
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`circuit board (30) ceases to be “discrete” and “otherwise separate” from the coil, as
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`required by claims 21-22.
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`Petitioner argues with respect to element [21.5] that Kato at “Fig. 18 also
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`illustrates that Kato’s flexible printed-circuit board (connecting unit) is discrete.”
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`Paper 34, Opp. at p. 8 (quoting Ex.1017, [0034]). Even if true, Petitioner ignores
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`the contextual limitations of claims 21-22 that require the connecting unit to be
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`connected to the coil via the first-third and second-fourth terminal connections.
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`The circuit board of Fig. 18 is clearly not connected to the spiral coil at all, as
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`discussed above, and Fig. 18 therefore fails to meet the first-third and second-
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`fourth terminal interconnection requirements of claims 21-22.
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`When the circuit board shown in Fig. 18 is assembled together with the
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`spiral coil 40, as shown in Fig. 19, the coil is “stuck” in its entirety to the circuit
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`board 90. Ex. 1017, [0080], [0065]. As a result, Kato’s assembled unit fails to meet
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`the requirement that the connecting unit is discrete and not connected to the coil,
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`5
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
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`except at the first-third and second-fourth terminal interconnections, as required.
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`Petitioner argues that Kato discloses the “otherwise separate” limitation with
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`reference again to Fig. 18, stating that Fig. 18 “illustrates that the circuit board 90
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`is a separate element and separable from the other elements of Kato’s device,
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`including the planar coil.” Paper 34, Opp. at p. 13 (citing Ex.1017, [0034]).
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`Petitioner does not explain how the component shown in Fig. 18 is “separable”,
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`and, even if separable, how a separable/separated coil would meet the limitations
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`of claims 21-22 any more than the pre-assembled circuit board of Fig. 18.
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`Petitioner alleges further that “Fig. 19 illustrates that the circuit board 90
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`(connecting unit) is physically separated from the coil by the adhesive layer ….”
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`Paper 34, Opp. at p. 14 (citing Ex.1021, 19). Petitioner does not provide any
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`explanation to support an interpretation in which a coil and a circuit board, which
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`are “spaced apart” from each other by the adhesive sheet that fully adheres the two
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`together, could meet the “discreet” and “otherwise separate” claim limitations.
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`This “spaced apart” interpretation finds no support in any of the evidence of record
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`and violates several principles of claim construction, including the rule against
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`excluding embodiments. Oatey Co. v. IPS Corp., 514 F.3d 1271, 1276–77 (Fed.
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`Cir. 2008). For instance, the “spaced apart” interpretation by Petitioner would
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`exclude embodiments shown in Figs. 3, 8-9, 16, and 21, in which the discrete
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`connecting unit 330 and the coil 230 are not spaced apart. Petitioner’s
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`interpretation would also frustrate the purpose of the ’740 Patent because stacking
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`the coil 230 and the circuit board 300 with the adhesive layer 710 defeats the
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`express purpose of the ’740 Patent to reduce the thickness of the power receiver
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`6
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`thickness by as much as the thickness of the connecting unit, as discussed above.
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`
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`Accordingly, Petitioner has not shown that Kato discloses or otherwise
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`suggests all limitations of substitute claims 21-22.
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`d. Petitioner has not explained how or why a POSITA would modify
`Kato to achieve the invention of claims 21-22.
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`Petitioner has taken an unorthodox approach in its effort to show that claims
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`21-22 are obvious over Kato. For instance, Petitioner repeatedly argues that each
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`of the limitations are “obvious”, but never explains how the invention “as a whole
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`is obvious”. See, e.g., Paper 34, Opp. at 1, 13-16 (alleging how Kato renders an
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`individual limitation obvious). The fundamental first step in any obviousness
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`analysis is to identify the differences between the prior art and the claimed
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`invention, but Petitioner made no effort in this regard either. Graham v. John
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`Deere Co., 383 US 1, 17-18 (1966).
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`Petitioner apparently tries to show that Kato teaches all of the individual
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`claim limitations of claims 21-22, under any interpretation (see Paper 34, Opp. at
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`p. 13), but this is not enough to show that these claims would have been obvious.
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`Petitioner must proffer evidence showing how and why one skilled in the art would
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`modify Kato “to arrive at the claimed invention.” ARENDI SARL, 832 F. 3d at
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`1361. Petitioner makes no effort in this regard and has therefore failed to show that
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`claims 21-22 are unpatentable.
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`e. Petitioner has not shown that the Kato discloses or suggests the
`limitations of claim 23.
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`
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`i.
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`Claim Construction.
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`7
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`Claim 23 recites: “[1] wherein the third connection terminal is connected to
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`the first connection terminal horizontally within a boundary defining the receiving
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`space …, and [2] wherein the receiving space extends between the upper surface
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`and lower surface of the adhesive layer continually from inside the coil to outside
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`the coil.” Petitioner has not expressly construed any of these limitations. Petitioner
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`does not even use the terms of claims 23 consistently so the Board could glean the
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`Petitioner’s proposed construction. For example, Petitioner first argues that the
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`Kato teaches the receiving space limitation with reference to the “inner gap” and
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`the “outer gap” in the adhesive layer. Paper 34 at 17. Second, Petitioner argues that
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`Kato teaches the receiving space with reference to the planer portion of the
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`adhesion sheet 47 to which the coil is “stuck”, where there clearly is no “gap”. Id.
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`at 17-18. Petitioner’s apparent dual interpretations finds no support in the record
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`and ignore the purpose of having an adhesive layer with a receiving space
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`configured to reduce the thickness of the wireless power receiver by as much as the
`
`thickness of the connecting unit. Ex. 1001, 1:20-2:53; 8:50-54; 16:4-13, 18:46-53.
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`The intrinsic evidence supports an interpretation for “receiving space” that
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`means “a discontinuity that reduces the thickness of a portion of the adhesive
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`layer.” Claim 23 requires that receiving space “extends between the upper surface
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`and lower surface of the adhesive layer continually from inside the coil to outside
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`the coil.” Petitioner argues that the designation of “upper” and “lower” are
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`arbitrary (Paper 34 at 19), but Petitioner is mistaken. Claim 23 establishes a frame
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`of reference for the terms “upper” and “lower” by reciting that the receiving space
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`is defined by a horizontal boundary. The term “horizontal boundary” refers to the
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`8
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`periphery of the receiving space in a horizontal plane. See, Ex. 1001, Figs. 3-9, 13,
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`16-21, 28-37 (showing in all instances the wireless power receiver oriented
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`horizontally); see Ex. 2025. Notably, the horizontal boundary does not extend
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`beyond the periphery of the adhesive layer, as shown, for example, in Fig. 26
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`(annotated in green below). The “upper surface” and “lower surface” relative to
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`this horizontal reference frame therefore refer to the planer surfaces of the adhesive
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`layer separated vertically from each other which form the thickness of the adhesive
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`layer. The use of the term “in a vertical direction perpendicularly above or below
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`the adhesive layer” in claim 21 also confirms that use of the terms “upper” and
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`“lower” are not arbitrary, as Petitioner suggests.
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`Patent Owner’s construction is supported by the specification, particularly
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`with reference to the exemplary embodiment shown in Figs. 26-28. That is,
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`consistent with Patent Owner’s interpretation, the adhesive layer 710 has
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`horizontal upper and lower surfaces that make up the thickness of the adhesive
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`layer 710, and the receiving space extends continually between these horizontal
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`9
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
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`surfaces to provide the discontinuity to receive the connecting unit. See Ex. 1001,
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`Fig. 28. In this respect, the “receiving space” limitation of claim 23 requires: (1) a
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`discontinuity that reduces the thickness of a portion of the adhesive layer, and that
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`(2) the discontinuity extends between upper and the lower horizontal surfaces of
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`the adhesive layer (3) continually from the inside of the coil to the outside of the
`
`coil.
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`In view thereof and Petitioner’s failure to construe this limitation, the Board
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`should apply Patent Owner’s interpretation for the “receiving space” limitation.
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`f. Kato does not disclose the “receiving space” limitation of claim 23.
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`Petitioner argues that Kato discloses the receiving space limitation of claim
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`23 with reference to annotated Fig. 19 reproduced below. Petitioner argues “Kato
`
`teaches that the adhesive layer includes an inner gap (receiving space)
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`corresponding to the “inner peripheral portion 37” of the coil. Kato also teaches
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`that the adhesive layer includes an outer gap (receiving space) corresponding to the
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`“outer peripheral portion 38” of the coil to avoid the second coil contact portion
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`35. Further, the adhesive layer also includes a receiving space where the coil is
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`received and “stuck” on.” Paper 34, Opp. at p. 17. Petitioner’s contorted assembly
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`of disparate portions of Kato’s receiver unquestionably shows that Petitioner is
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`using claim 23 as a roadmap to reconstruct the claimed invention, the sine qua non
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`of impermissible hindsight.
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`10
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`
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`As discussed above, the “receiving space” limitation of claim 23 requires:
`
`(1) a discontinuity that reduces the thickness of a portion of the adhesive layer, and
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`that (2) the discontinuity extends between upper and the lower horizontal surfaces
`
`of the adhesive layer (3) continually from the inside of the coil to the outside of the
`
`coil. Kato fails to disclose or suggest all three of these requirements.
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`First, Fig. 19 shows the adhesive sheet 42 having a continuous thickness and
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`the circuit board 35 stuck to the bottom planer portion of the adhesive sheet 42. As
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`such, the adhesive sheet 42 does not have a discontinuity that reduces the thickness
`
`of the adhesive sheet 42, to accommodate the thickness of the circuit board 35
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`(which Petitioner alleges is a connecting unit) to meet this limitation of claim 23.
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`Second, assuming arguendo that the “inner gap” in the adhesive sheet at
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`“inner peripheral portion 37” of the coil is sufficient to meet the “receiving space”
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`limitation, in all embodiments Kato’s “inner gap” ends at the inner periphery of the
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`adhesive sheet. The “inner gap” does not extend between the top and bottom planer
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`surfaces of the adhesive sheet continually from the inside of the coil to the outside
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`of the coil so it can accommodate the circuit board. The “outer gap” suffers from
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`11
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`the same and additional problems. Specifically, the “outer gap” is outside of the
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`periphery of the adhesive layer (see, e.g., Kato at Fig. 19-20 (showing the adhesive
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`sheet 42 in the cross section dimensionally smaller than the coil 40) and is
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`therefore not within the receiving space defined by the horizontal boundary, per
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`claim 23, as discussed above.
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`Moreover, because the horizontal boundary of the adhesive sheet 42 ends at
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`the outside periphery of the adhesive sheet 42, the first-fourth interconnection at,
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`e.g., Kato at Fig. 19 ref. no. 35, occurs outside of the horizontal boundary of the
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`receiving space – which means that Kato also fails to disclose the “wherein the
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`third connection terminal is connected to the first connection terminal horizontally
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`within a boundary defining the receiving space” per claim 23.
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` Finally, as discussed above, Kato teaches in all instances that the coil 42 is
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`“stuck” onto the surface of the adhesive sheet. For this reason, the alleged
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`“receiving space where the coil is received and ‘stuck’ on” does not extend
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`between upper and lower horizontal surfaces, as required by claim 23.
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`Petitioner has not provided any explanation with respect to how or why a
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`POSITA would modify Kato with these deficiencies in mind to yield the claimed
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`invention.
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`VI.
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`CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests that the Board
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`grant its contingent Motion to Amend should claims 6, 16, and 17 the ’740 Patent
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`be found unpatentable.
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`12
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`
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`Dated: February 16, 2023
`
`Respectfully submitted,
`
`/Antonio Papageorgiou/
`Antonio Papageorgiou
` Reg. No. 53,431
`
`LOMBARD & GELIEBTER LLP
`230 Park Avenue, 4th Floor West
`New York, NY 10169
`(212) 520-1172 (telephone)
`(646) 349-5567 (facsimile)
`ap@lombardip.com
`
`
`Attorney for SCRAMOGE
`
`TECHNOLOGY LTD.
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`13
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`IPR2022-00118
`Reply to Opp. to Revised Motion to Amend
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
`
`that on February 16, 2023, a copy of this REPLY TO PETITIONER’S
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`OPPOSITION TO PATENT OWNER’S REVISED MOTION TO AMEND was
`
`served by filing this document through the Patent Trial and Appeal Case Tracking
`
`System (P-TACTS) system, as well as delivering a copy via electronic mail upon
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`the following attorneys of record for the Petitioner:
`
`
`
`Scott T. Jarratt (Reg No. 70,297)
`scott.jarratt.ipr@haynesboone.com
`Andrew S. Ehmke (Reg No. 50,271)
`andy.ehmke.ipr@haynesboone.com
`Calmann J. Clements (Reg No. 66,910)
`calmann.clements.ipr@haynesboone.com
`
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Dated: February 16, 2023
`
`Respectfully submitted,
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`/Antonio Papageorgiou/
`Antonio Papageorgiou
` Reg. No. 53,431
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