Apple Inc.
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00118, U.S. Patent No. 9,806,740
`
`Patent Owner’s Demonstrative Exhibits
`
`March 9, 2023
`
`Ex. 2026
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 1
`
`
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00118, U.S. Patent No. 9,806,740
`
`Patent Owner’s Demonstrative Exhibits
`
`March 9, 2023
`
`Ex. 2026
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 1
`
`
`
`Ground 1: No Connecting Unit in Hasegawa
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 2
`
`
`
`Why Petition Fails
`
`lead line to inner coil end
`
`lead line to outer coil end
`
`• Hasegawa has no “connecting unit”
`
`• Lead lines cannot be BOTH the
`“terminals” AND the “connecting unit”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`Hasegawa:‘212 Patent Appl., Fig. 2
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 3
`
`
`
`Hasegawa: No “Connecting Unit”
`
`lead line to inner coil end
`
`lead line to outer coil end
`
`first connection terminal
`
`second connection terminal
`
`connecting unit
`
`Hasegawa:‘212 Patent Appl., Fig. 2
`
`Patent Owner: ‘740 Patent, Fig. 11
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 4
`
`
`
`“Connecting Unit” Presumed Separate and Distinct
`
`6. A wireless power receiver, comprising:
`[6.1] an adhesive layer comprising a receiving space;
`[6.2] a coil on the adhesive layer;
`[6.3] a first connection terminal connected to an outer end of the coil;
`[6.4] a second connection terminal connected to an inner end of the coil; and
`[6.5] a connecting unit overlapping the receiving space in a vertical direction perpendicular to the adhesive layer,
`[6.6] wherein the connecting unit comprises: a third connection terminal connected to the first connection
`terminal;
`[6.7] a fourth connection terminal connected to the second connection terminal; and
`[6.8] a wiring layer connected to the third connection terminal and the fourth terminal.
`
`Patent Owner: ’740 Patent, Claim 6; see also Claim 16.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 5
`
`
`
`Specification: Separate “Connecting Unit”
`
`connection terminal 320
`to be connected to
`connection terminal 220
`
`connection terminal 310
`to be connected to
`connection terminal 210
`
`connecting unit
`
`connection terminal 220
`connected to inner end
`of coil 230
`
`connection terminal 210
`connected to outer end
`of coil 230
`
`coil 230
`
`Patent Owner:‘740 Patent, Fig. 11; 5:46-60; see also 4:61-65; 5:22-26; 15:57-64.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 6
`
`
`
`Specification: Separate “Connecting Unit”
`
`Patent Owner: ‘740 Patent at 8:30-39 see also 16:51-58.
`
`Scramoge Technology Ltd.
`
`Patent Owner: ‘740 Patent at 2:49-53; see also 8:50-54, 16:4-13, 18:46-53.
`Ground 1
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 7
`
`
`
`File History: Separate “Connecting Unit”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Ex. 2019, Application Serial No. 13/663,012. at 9-10.
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 8
`
`
`
`Facially Nonsensical
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Becton Dickenson v Tyco Healthcare Group, 616 F.3d 1249, 1255 (Fed. Cir. 2010)
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 9
`
`
`
`“Connected” means previously separate
`
`Regents of the Univ. of Minn. V. AGA Med., 717 F.3d 929, 938 (Fed. Cir. 2013)
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 10
`
`
`
`Petitioner’s Caselaw
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`IPR2019-00233 (Apple v. Kilbourne), Paper 40 at 34
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 11
`
`
`
`Motion to Amend
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 12
`
`
`
`Substitute Claims
`
`21. (Proposed substitute for claim 6) A wireless power receiver, comprising:
`an adhesive layer comprising a receiving space;
`a coil on the adhesive layer;
`a first connection terminal connected to an outer end of the coil;
`a second connection terminal connected to an inner end of the coil; and
`a discrete connecting unit, the connecting unit overlapping the receiving space
`and disposed in a vertical direction perpendicularly above or below [[to]] the adhesive
`layer and connected to a circuit separate from the connecting unit, wherein the
`connecting unit comprises:
`a circuit board;
`a third connection terminal on the circuit board connected to the first connection
`terminal;
`a fourth connection terminal on the circuit board connected to the second
`connection terminal at the inner end of the coil; and
`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.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 13
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 16) A wireless power receiver, comprising:
`22.
`an adhesive layer comprising a receiving space;
`a coil on the adhesive layer;
`a first connection terminal connected to one end of the coil;
`a second connection terminal connected to another end of the coil; and
`a discrete connecting unit, the connecting unit disposed corresponding to the
`receiving space and connected to a circuit separate from the connecting unit, wherein
`the connecting unit comprises:
`a circuit board;
`a third connection terminal on the circuit board connected to the first connection
`terminal;
`a fourth connection terminal on the circuit board connected to the second
`connection terminal; and
`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.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 14
`
`
`
`Substitute Claims – Interpretation – “Otherwise Separate”
`
`Claims 21 and 22:
`
`...the connecting unit comprises:
`
`…a
`
` third connection terminal on the circuit board connected to the first connection
`terminal;
`a fourth connection terminal on the circuit board connected to the second
`connection terminal; and
`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.
`
`P.O. Interpretation of “otherwise separate”:
`
`“the connecting unit and the coil are not connected, except at the
`interconnection of the first-third and second-fourth terminal connections.”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 15
`
`
`
`Support for PO’s Interpretation
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Patent Owner: ‘740 Patent, Fig. 28
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 16
`
`
`
`Petitioner’s Citations to Kato, Ex. 1017
`
`Op. at p.8 (citing Kato,
`Ex.1017, Fig. 18 (annotated))
`
`Op. at p.4 (citing Kato,
`Ex.1017, Fig. 19 (annotated))
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 17
`
`
`
`Kato Does Not Teach assembled Components with
`“Otherwise Separate” Connecting Unit
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Kato, Ex.1017
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 18
`
`
`
`Kato Does Not Teach assembled Components with
`“Otherwise Separate” Connecting Unit
`
`Patent Owner: ‘740 Patent, Fig. 28
`
`Ex.1017, Fig. 19
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 19
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 17) The wireless power receiver of claim
`23.
`16 22, wherein the receiving space extends from inside the coil to outside the coil,
`wherein the third connection terminal is connected to the first connection
`terminal horizontally within a boundary defining the receiving space, and wherein
`the fourth connection terminal is connected to the second connection terminal
`horizontally within the boundary defining the receiving space,
`wherein the connecting unit circuit board comprises at least one of a flexible
`circuit board and a tape substrate,
`wherein the adhesive layer has an upper surface and a lower surface
`opposite the upper surface, and
`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.
`
`22.
`
`(Proposed substitute for claim 16) A wireless power receiver, comprising:
`
`…a
`
` first connection terminal connected to one end of the coil;
`a second connection terminal connected to another end of the coil; and
`…
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 20
`
`
`
`“Within Receiving Space”
`
`Patent Owner: ‘740 Patent, Fig. 26
`
`Patent Owner: ‘740 Patent, Fig. 27
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 21
`
`
`
`“Within Receiving Space”
`
`Patent Owner: ‘740 Patent, Fig. 28
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 22
`
`
`
`Petitioner’s Citations to Kato, Ex. 1017
`
`Op. at p.18 (citing Kato,
`Ex.1017, Fig. 19 (annotated))
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 23
`
`
`
`Kato Does Not Teach “Within Receiving Space”
`
`Kato, Ex.1017
`
`Kato, Ex.1017
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 24
`
`
`
`Kato Does Not Teach “Within Receiving Space”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`Kato, Ex.1017, Fig. 17
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 25
`
`
`
`“Extends Continually”
`
`Patent Owner: ‘740 Patent, Fig. 26
`
`Patent Owner: ‘740 Patent, Fig. 27
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 26
`
`
`
`Support for PO’s Interpretation – “Extends Continually”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`Patent Owner: ‘740 Patent, Fig. 28
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 27
`
`
`
`Kato Does Not Teach “Extends Continually”
`
`Op. at p.18 (citing Kato,
`Ex.1017, Fig. 19 (annotated))
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`Scramoge Technology Ltd.
`Ex. 2026 - Page 28
`
`
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