UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Page 1
`
` ___________________
`
` BEFORE THE PATENT AND APPEAL BOARD
`
` ___________________
`
` APPLE INC.,
`
` Petitioner,
`
` v.
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` SCRAMOGE TECHNOLOGY LTD.,
`
` Patent Owner.
`
` __________________
`
` Case IPR2022-00118
`
` U.S. Patent No. 10,804,740
`
` REMOTE DEPOSITION OF
`
` JOSHUA PHINNEY, Ph.D., P.E.
`
` Wednesday, July 27, 2022
`
` 9:50 a.m. Pacific Time
`
`Stenographically Reported By:
`
`Lorie Rhyne, CSR No. 12905
`
`Job No. 5237
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Scramoge Technology Ltd.
`Ex. 2018 - Page 1
`
`

`

`Page 2
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`Page 3
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`APPEARANCES:
`
` APPEARING FOR PETITIONER:
` SCOTT JARRATT, ESQ.
` CALMANN J. CLEMENTS, ESQ.
` Haynes Boone, LLP
` 6000 Headquarters Drive, Suite 200
` Plano, Texas 75024
` (972) 739-8663
` scott.jarratt@haynesboone.com
` calmann.clements@haynesboone.com
`
` APPEARING FOR PATENT OWNER:
` ANTONIO PAPAGEORGIOU, ESQ.
` Lombard & Geliebter LLP
` 230 Park Avenue, 4th Floor West
` New York, New York 10169
` (212) 520-1172
` ap@lgtrademark.com
`
` Conducted Remotely
` 9:50 a.m. Pacific Time
`
`Page 5
`
` JOSHUA W. PHINNEY, Ph.D., P.E.,
` having first been duly sworn, was examined and
` testified as follows:
`
` EXAMINATION
` BY MR. PAPAGEORGIOU:
` Q. So, Dr. Phinney, please state your name for
` the record.
` A. My name is Joshua Phinney. Should I spell
` it?
` Q. No, that's okay.
` And you've been retained by the petitioner
` in this case, IPR 2022-0118; is that correct?
` A. Yes.
` Q. And that relates to U.S. Patent
` Number 10,804,740.
` A. Yes.
` Q. Can we refer to it as the "'740 patent"?
` A. Agreed.
` Q. Thanks. Great.
` (Exhibit 1003 was marked for identification.)
` //
`
`2 (Pages 2 to 5)
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`DEPOSITION OF: JOSHUA PHINNEY, Ph.D., P.E.
`
`DATE: Wednesday, July 27, 2022
`
`TIME: 9:50 a.m. Pacific Time
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`LOCATION: Conducted remotely with all
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` parties appearing via Zoom
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`Page 4
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` I N D E X
`WITNESS: EXAMINATION
`Joshua Phinney
` Mr. Papageorgiou 5
` Mr. Jarratt 63
`
` EXHIBIT(S) MARKED
`EXHIBIT PAGE
`Exhibit 1001 U.S. Patent 10,804,740 5
`Exhibit 1002 U.S. Patent 10,804,740
` File History 6
`Exhibit 1003 '740 Phinney Declaration 6
`Exhibit 1004 Phinney CV 7
`Exhibit l005 Patent Application Pub. No.:
` US 2009/0021212 A1 (Hasegawa) 7
`Exhibit 1006 Patent Application Pub. No.:
` US 2007 /0069961 Al (Akiho) 7
`Exhibit 1007 Patent Application Pub. No.:
` US 2014/0306656 Al (Tabata) 7
`Exhibit 1008 U.S. Patent US 8,384,263
` (Hiramatsu) 8
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Scramoge Technology Ltd.
`Ex. 2018 - Page 2
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`

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` BY MR. PAPAGEORGIOU:
` Q. The -- so you prepared a declaration marked
` Exhibit 1003; is that correct?
` A. Yes.
` Q. Okay. And this is the document on screen
` right now; is that correct?
` A. Yes, that looks like it.
` Q. Okay, great.
` (Exhibit 1001 was marked for identification.)
` BY MR. PAPAGEORGIOU:
` Q. And in addition to Exhibit 1003, there's
` also Exhibit 1001.
` (Calmann Clements joins proceedings.)
` BY MR. PAPAGEORGIOU:
` Q. Let me get the front page there.
` Do you recognize that document?
` A. Yes. It's the '740 patent.
` Q. Great.
` (Exhibit 1002 was marked for identification.)
` BY MR. PAPAGEORGIOU:
` Q. Exhibit -- this is Exhibit 1002 shown on the
` screen right now.
` Do you recognize that document?
` A. Yes, the -- the file history for the
` '740 patent.
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` (Exhibit 1004 was marked for identification.)
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` BY MR. PAPAGEORGIOU:
`
` Q. And Exhibit 1004, that is your CV; is that
`
` correct?
`
` A. Yes.
`
` (Exhibit 1005 was marked for identification.)
`
` BY MR. PAPAGEORGIOU:
`
` Q. Do you recognize Exhibit 1005?
`
` A. Yes, this is Hasegawa, which is the --
`
` the -- the reference for the -- the ground in the
`
` petition.
`
` Q. Okay.
`
` (Exhibit 1006 was marked for identification.)
`
` BY MR. PAPAGEORGIOU:
`
` Q. And this document shown on the screen right
`
` now is marked Exhibit 1016 [sic].
`
` Do you recognize this?
`
` A. I do. I -- I call it Akiho.
`
` Q. That's fair enough.
`
` (Exhibit 1007 was marked for identification.)
`
` BY MR. PAPAGEORGIOU:
`
` Q. And there's a -- also Exhibit 1007 shown on
`
` screen now.
`
` Do you recognize this?
`
` A. Yes. I -- I call this Tabata.
`
`Page 9
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`Page 8
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` (Exhibit 1008 was marked for identification.)
` BY MR. PAPAGEORGIOU:
` Q. And, finally, there is Exhibit 1008.
` Do you recognize this?
` A. Yes. I call that Hiramatsu.
` Q. Okay, great.
` Did you review your declaration,
` Exhibit 1003, in preparation of this deposition?
` A. I did.
` Q. Did you review any other documents?
` A. Just the documents cited in my declaration.
` Q. Great.
` A. Oh, and I should say I -- I also did see an
` institution decision, and I saw patent owner's
` preliminary response.
` Q. Thank you.
` Now, you're currently employed with
` Exponent, Inc.; is that correct?
` A. Yes.
` Q. What is your role with the company?
` A. I'm a principal engineer, and my role is
` to -- to lead technical investigations I would call,
` like, failure analysis, trying to figure out what went
` wrong with something. And about half the time, I'm
` involved in -- in intellectual property case of some
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` type that could be trade secrets or patents.
`
` Q. Have you been retained for this particular
`
` petitioner in other matters? I know there's a few IPRs
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` going on. Are you working on those as well?
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` A. There should be -- I -- I -- perhaps a
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` testimony list that you saw, and, yeah, I have been
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` retained by petitioner in other matters that I've
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` already testified on.
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` Q. Okay. The matters related to the same
`
` patent owner? Have there been any other patent
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` owners -- let me rephrase that.
`
` Have you worked on any matters for Apple
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` that do not involve this particular patent owner?
`
` A. Yes, I have.
`
` Q. Okay. And those are on your list?
`
` A. Those -- yeah, they should all be on -- on
`
` the -- the list. Those are publications, but my
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` testimony list should have that.
`
` Q. So you indicated that you've provided
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` testimony in other patent cases as well. The
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` approximate number, more than 10, more than 20?
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` A. Yeah, it's probably more than 20, could be
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` more than 30.
`
` Q. Do you recall that in any of those cases
`
` whether you've given opinions on anticipation in the
`
`3 (Pages 6 to 9)
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`Scramoge Technology Ltd.
`Ex. 2018 - Page 3
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` 35 U.S.C. 102?
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` A. I -- I have.
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` Q. How did you become aware of the standard for
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` anticipation? Did you read any cases, for example?
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` A. No, I -- I don't read cases. I tend to have
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` a -- a section of any report I do on a patent matter, a
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` section I usually just call Legal Understanding and,
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` you know, it just has a lot of paragraphs that say,
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` I've been informed by counsel that, and that just
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` reflects what I -- what I learned in the course of
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` doing this type of work about anticipation and
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` obviousness.
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` A. That all of the elements would be obvious to
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` a -- a person of ordinary skill at the time of the
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` invention.
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` Q. Right. So it's -- it's a combination of --
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` of references plus a rational basis for combining those
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` references to yield the claimed invention; is that
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` correct?
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` A. Well, if I could look at my --
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` Q. Sure.
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` A. -- Legal Understanding section here.
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` I'll just -- so I -- I think you asked a
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` question about obviousness, and then you asked if
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` your -- your way you said it was -- was correct, I
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` Q. So it's fair to say that, basically, you've
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` A. Yeah, I think that's -- that's a fair way to
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` put it.
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` Q. Okay. Now, in this particular case here in
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` your declaration, we're principally concerned with
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` obviousness; is that correct?
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` A. Correct.
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` Q. Now, what -- in terms of obviousness, you
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` understand that, in essence, that the requirement to
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` show that the -- the claim is obvious requires that all
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` of the elements be in the prior art; is that correct?
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` believe.
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` Q. Okay. That's fine.
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` Now, would you agree that it's not enough to
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` merely show that components are in the prior art to
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` prove obviousness.
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` Would you agree?
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` A. Well, I -- I tried to end the -- end my
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` analysis in each -- of each claim element with a
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` concluding sentence that would say -- it would say
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` something to the effect of, you know, Thus, this
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` teaching would render -- would render obvious the claim
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` element.
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` And, so, yeah, I -- I basically would show
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` some, you know, reasons from -- from Hasegawa and then
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` conclude with that type of sentence, that that
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` element's obvious in view of that.
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` Q. Okay. Are you -- has the -- the concept of
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` impermissible hindsight ever been explained to you?
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` A. It has.
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` Q. Okay. What is your understanding of that
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` concept?
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` A. My -- my understanding is that using the --
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` using the -- the patent itself as a template for
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` arranging the prior art would be an example of
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` impermissible hindsight.
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` statement. That's that concluding statement that I
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` have at the end of every claim element.
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` Q. Okay. So to confirm, you did not conclude
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` that the '740 patent is anticipated by Hasegawa or any
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` of the other references?
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` A. I -- I really handled this as an obviousness
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` analysis, a single -- what I would maybe call a single
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` reference obvious anal- -- obviousness analysis.
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` Q. Okay. At paragraph 27 of your declaration,
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` you have an excerpt pulled from the '740 patent, it --
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` (Stenographer clarification.)
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` MR. PAPAGEORGIOU: Sorry. Give me one
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` Q. Okay. Now, the -- as we discussed briefly
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` earlier, the -- you cite a number of patent references
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` in your declaration. Did you do the search and locate
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` those references or were they provided to you?
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` A. So Hasegawa -- I can't recall where Hasegawa
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` came from. I did search and find Hiramatsu, Akiho and
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` then Tabata.
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` Q. Okay. Now, in your declaration, it is your
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` position that the '740 patent, at least the claims that
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` are at issue, are obvious in view of Hasegawa,
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` Exhibit 1005; is that correct?
`
` A. Yeah, I think that's a -- that's a fair
`
` second.
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` BY MR. PAPAGEORGIOU:
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` Q. Okay. So back to -- to paragraph 27.
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` Do you see that -- the -- the quote from the
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` 7- --
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` A. I -- it -- it -- it dropped out on my side.
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` I -- I think I heard the last sentence -- the last
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` words, but I'm not sure.
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` Q. All right. Sorry. Let me repeat. Can you
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` hear me?
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` A. Yes.
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` Q. Okay. Now, I'm referring to paragraph 27 of
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` your declaration, you have an -- an excerpt from the
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`TransPerfect Legal Solutions
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`4 (Pages 10 to 13)
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`Scramoge Technology Ltd.
`Ex. 2018 - Page 4
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` '740 patent.
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` Do you see that?
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` A. Yes.
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` Q. All right. You understand that this
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` paragraph is not prior art; is that correct?
`
` MR. JARRATT: Objection. Form.
`
` BY MR. PAPAGEORGIOU:
`
` Q. Let me rephrase.
`
` So that paragraph that you quote from the
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` '740 patent, do you understand that that passage is not
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` prior art?
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` A. I guess I'm not quite sure how to answer
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` is -- at least your statement is not prior art?
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` A. I -- I guess in the sense of being a
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` reference that I'm relying on affirmatively defined
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` claim elements, I -- I guess I'd agree with you that
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` way.
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` Q. Okay. At paragraph 32, you indicate that
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` the listed elements there are well-known components; is
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` that correct?
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` A. Yes, that's what I say there.
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` Q. Okay. Now, again, in terms of obviousness,
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` it's not enough that the components themselves are
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` well-known; is that correct?
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` A. That makes sense to me, that it's not just
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` because I have heard something called Apple can --
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` admitted prior art where statements that a patent owner
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` might make talking about the state of the art at the
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` time, sort of, are -- are taken to reflect in a way
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` what was the prior art.
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` So I'm not -- I guess I'm not quite sure how
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` to answer your question.
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` Q. Okay. Well, we'll move on to the next
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` paragraph.
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` In that paragraph 28, you refer to more
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` recent devices?
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` A. Yes.
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` Q. All right. And that's not prior art either
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` finding certain things in isolation is, in a way, not
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` enough. The -- the -- so at least in that sense.
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` Q. Okay. Going a little further down to
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` paragraph 35, you note that The specification does not
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` provide additional details with respect to these
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` spatial relationships between the connecting unit and
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` the receiving space in the adhesive layer 710.
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` Do you see that?
`
` A. Yes.
`
` Q. Okay. You -- do you understand that the
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` specification itself is not the only part of the patent
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` disclosure?
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` A. Yes. My understanding is that the
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` disclosure also includes the file history as an
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` example.
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` Q. Do you understand that the drawings
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` themselves are part of the disclosure?
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` A. Yeah. My understanding is that -- that the
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` drawings are -- are part of what I call a
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` specification. Maybe -- maybe I'm wrong if they're
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` distinct from that. But I'd always thought of things
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` before the claim as being the specification, including
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` a written description and the drawings.
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` Q. Okay, yeah. Generally, they're considered
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` A. Yeah, that's my memory. I can check if we
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` want to be sure.
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` Q. Okay. No, that -- that is correct.
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` And 130 is the receiving space. Do you see
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` that?
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` A. That is my -- that is my recollection. I'm
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` just looking in the patent. Yes, that -- that makes --
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` that makes sense.
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` Q. Okay. Now, reference numbers 210 and 220
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` are the connecting terminals, and they are located at
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` the ends of the coil 200.
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` Do you see that? So 210, 220 and those are
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` the ends of 200.
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` separately, but as long as your understanding is that,
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` you know, they do -- the drawings are part of the
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` disclosure, that's fine.
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` Now, at paragraph 33, you include Figure 26
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` from Exhibit 1001. That's the '740 patent; is that
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` correct?
`
` A. Yeah. Did you say I include Figure 26?
`
` Q. Twenty-six, um-hum.
`
` A. Yes, that's what's shown here in
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` paragraph 33.
`
` Q. Now, I just want to go through a few of the
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` components shown there. So 710, that's the adhesive
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` layer; is that correct?
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` A. Yes. 210 and 220, I believe, are called the
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` first connection terminal and the second connection
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` terminal. Yeah, it may appear to be shown at the ends
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` of that -- of 200.
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` Q. Okay. And that's consistent in the other
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` drawings as well. So I'm -- I'm displaying Figure 1 in
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` Exhibit 1001 now. That's the same configuration in
`
` Figure 1; is that correct?
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` A. Yeah. Just looking at that coil, it --
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` it -- it pretty much looks like we saw in Figure 26.
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` Q. Okay. And I'll just go a little lower to
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` Figure 11. And that is a similar configuration as
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`5 (Pages 14 to 17)
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` well; is that correct?
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` A. I would agree that it's -- that it's similar
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` as it depicts 200, 210, 220.
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` Q. Okay. And finally, we're looking at
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` Figure 14 in Exhibit 1001, and that too has the same
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` configuration?
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` A. I think I'd agree with that where it shows
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` 200 and 210 and 220 the same way.
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` Q. Okay. Let's take a look at the -- the
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` figures again, except this time Figure 2.
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` Is it fair to say that the -- that the
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` connections terminals 210 and 220 are connected -- only
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` those portions of the coil, those reference numbers 210
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` A. -- can be helpful to sort of look at that.
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` Q. Okay, yeah. So if we're looking at that
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` cross-section at Figure 3, for example, you'll see that
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` 220 and 210 are at the opposite ends there, and those
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` are the -- the points that are connected to 300 -- or
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` 330 in this instance.
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` Do you see that?
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` A. And if I could just hear the last part of
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` your question. After you said 210 and 220, those are
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` the parts that, and I just -- if you just repeat that
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` part, please.
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` Q. Right. So it's -- those connection
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` and 220 are connected to the terminals on reference
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` 300, which is the connecting units? So looking at
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` Figure 2.
`
` MR. JARRATT: Objection. Form.
`
` BY MR. PAPAGEORGIOU:
`
` Q. If you understand the question, Dr. Phinney,
`
` you can answer it.
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` A. I guess I'm not quite sure what you're
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` looking at, and I would also just say that some of the
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` side -- the side views so, like, along that -- along
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` that cross-section, line AA --
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` Q. Yeah.
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` terminals 210 and 220 where the coil connects to the
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` connecting unit, and I think the -- the connecting unit
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` is 330 in Figure 3.
`
` Do you see that? Maybe I could zoom in a
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` little for you.
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` A. Yeah. I -- I -- yeah, so there's this -- I
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` believe it's called solder 10 and 20 that is -- goes
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` down through a via and it -- that connects sort of
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` to -- to the 220 and 210 and --
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` Q. Okay.
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` A. -- is then, in turn, connected to 320 and
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` 310.
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` Q. All right. Yeah. So the -- if I'm not
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`Page 21
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`Page 20
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` mistaken, so 220, connecting terminal 220 is connected
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` to terminal 320 on the connecting unit in Figure 3; is
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` that correct?
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` A. Yeah, that, I think, is correct. They're --
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` they're connected through that solder connection. So
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` through sort of a filler metal, you might say, in
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` between the two.
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` Q. Got it. And that's the same with 210,
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` reference number 210 and 310 at the right side of
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` Figure 3; is that correct?
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` A. Yeah. I would give the same answers for
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` those.
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` A. With respect to the -- sort of that aspect,
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` yeah, I'd -- I'd agree. I think it's drafted, I think,
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` pretty much the same way with the same reference
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` numerals.
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` Q. Yeah. Let's take a look at Figure 16. Now,
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` that -- Figure 16 also has reference numbers 210 and --
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` and -- 310 and 220 and 320, and 210 and 310 are
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` connected via the solder, as you indicated previously,
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` and that's the same case with 220, connection to 320;
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` is that correct?
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` A. I'd say it's certainly quite similar. 220
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` and -- and 210 are -- are sort of buried in a trench.
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` Q. Okay. Let's take a look at another -- at
`
` You know, so they're made -- they're constructed a
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` Figure 8.
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` Similar configuration; is that correct?
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` MR. JARRATT: Objection. Form.
`
` THE WITNESS: You know, if we were looking
`
` at that -- the relationship of 220 to 320 through the
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` intermediate sort of solder connection, that aspect of
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` it, yeah, I'd say that those really show that -- the --
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` the same way in Figure 8 that we had just looked at.
`
` BY MR. PAPAGEORGIOU:
`
` Q. Okay. And then Figure 9, again, only
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` with -- in respect to 210, 310 and 220, 320, Figure 9
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` shows the same configuration; is that correct?
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` little differently, but I'd agree that as far as those
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` connection elements with the solder, I think it's
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` drafted the same way that we've been looking at and
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` with the same reference numerals.
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` Q. Okay. Figure 21, same question. We have
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` reference numbers 220 connected to 320 and 210
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` connected to 310. And, again, it appears as in the
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` previous figures that the connection occurs via some
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` solder; is that correct?
`
` A. Yes, I'd agree with that, the same type of
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` depiction of that connection that we've been
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` discussing.
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`6 (Pages 18 to 21)
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`Page 22
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`Page 23
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` Q. Okay. Let's take a look at Figure 28. Now,
` Figure 28 is -- is a little bit different
` configuration. But I'd like to bring your attention to
` reference number 300, which is the -- at the top right
` of the figure.
` Do you see that?
` A. Yes.
` Q. And that's the connecting unit; is that
` correct?
` A. Yeah. If you don't mind, I'm going to just
` look at the -- the name given to it.
` Q. Sure.
` A. And yes, I'd agree with you. It's --
` it's -- and just to be clear, you -- are you referring
` just to the --
` Q. Just to 300 for -- for this question or
` right now.
` A. Okay. Yeah, so the reason I'm pointing that
` out is just that the -- the terminals 310, 320, 340,
` 350 that --
` Q. I -- so we'll get to those parts in a
` minute, but I just want to confirm that 300 is the
` connecting unit?
` A. Yes, it is called the connecting unit.
` I'm -- I'm just saying that it's frequently discussed
`
`Page 24
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` Maybe that helps you.
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` Can you see that okay?
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` A. Sorry. And -- and your specific question
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` as being a collection of things --
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` Q. Right.
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` A. -- in both the claims and how it -- how it
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` describes 300 as encompassing several other parts.
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` So I just -- I'm just trying to be clear
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` there's not necessarily just the -- the one empty
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` rectangle part that's there.
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` Q. Okay. But generally in the patent when
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` the -- we see the -- the term -- the reference
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` number 300, the word that precedes it or the words that
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` precede it is connection terminal -- or connecting
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` unit, excuse me?
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` A. Yes, that's -- that's -- that was my read.
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` I -- I think it was consistent that way.
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` Q. Okay. Now, 320 -- do you see that? That's
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` on the -- our left end of 300.
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` Do you see that?
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` A. I do.
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` Q. Okay. And then 340 is closer to 300.
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` Do you see that?
`
` A. Yes.
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` Q. And 340 and 320 are also referred to
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` connection terminals but those are the connection
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` terminals on the connecting unit; is that correct?
`
` Well, let me just show you both 27 and 28.
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`Page 25
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` A. Yeah, I would agree with that.
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` Q. Now, Figure 28, they -- it also includes
`
` reference number 220 and 210 and 310 -- let me get back
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` was -- oh, that 320 and 340 were connection terminals
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` on the connecting unit, I believe, is what your
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` question was.
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` Q. Yes, that is correct.
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` A. I'm just quickly looking at the text.
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` Q. Sure.
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` A. Yeah, I think that's -- that's right. In --
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` in the specification they're -- they're sometimes, you
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` know, enumerated so that 320 can be called the -- a
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` second connection terminal, and 340 can be called a
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` third connection terminal.
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` But, yes, they're both connection terminals,
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` which -- yeah.
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` Q. And those connection terminals are on the
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` connecting unit 300; correct?
`
` A. Yeah, I think that's -- that's -- that's
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` true. And -- and what we sometimes see as, like, the
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` 300 will be given a -- a brace, which will be shown to
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` subsume other sub-elements.
`
` Q. Um-hum. Yeah. I see that in some of the
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` other figures, but just those parts, it looks like
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` the -- you know, that 320 and 340 are on 300.
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` to the 310 here.
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` That is -- so 310 is another connecting unit
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` on the -- another connection terminal on the connecting
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` unit; is that correct? And that's the same case with
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` 350.
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` So in this Figure 27 and 28, there are
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` actually shown four connection terminals on connecting
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` unit 300; is that correct?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: I'm just going to take the
`
` last part that you asked there just in case there --
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` I'm only responding to that last part of the question,
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` which it was, I think, if there's four connection
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` terminals on this -- this connecting unit 300 as
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` depicted in Figure 27 and 28, for instance.
`
` BY MR. PAPAGEORGIOU:
`
` Q. Yes, yes.
`
` A. Yeah, I think I'd agree with that, and --
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` and they're -- they're actually called first, second,
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` third and fourth around -- in the specification around
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` column 15. I'm looking around line 57.
`
` Q. Okay. Now, back to 210 and 220.
`
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`7 (Pages 22 to 25)
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`

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`Page 26
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`Page 27
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` Do you see those in Figure 28, reference
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` numbers 220 and 210?
`
` A. Yes, I see those.
`
` Q. And 220 and 210 are connecting terminals, as
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` we discussed in the previous -- previously. Those are
`
` the connecting terminals on the coil; is that correct?
`
` A. That -- that makes sense to me, that even
`
` though they're not called out in Figure 27, they're
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` sort of right under them, right under the -- 320 and
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` 310 as an example.
`
` Q. Yep, okay.
`
` Now, in -- again, in Figure 28, it --
`
` Figure 28 depicts 320 connected to 220, and there's, it
`
` looks like, what is a solder joint at 30 in between
`
` them; is that correct?
`
` A. Yes, I think that's right. Solder 30 in
`
` each of those instances.
`
` Q. Okay. Now, in each of the figures that we
`
` discussed earlier, which is Figure 1, Figure 11,
`
` Figure 27, it appears that the connection occurs at
`
` the -- between these components, the -- the terminal
`
` connections 220 and 320 and 310 and 210. It occurs
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` mentioning?
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` Q. Yeah. Yes. Yes.
`
` A. So as an example, solder 30, in forming that
`
` solder joint between 220 and 320, it -- yes, appears to
`
` be at the -- the end of a coil as one example.
`
` Q. Okay. Yeah.
`
` Do you know if there's any other examples or
`
` do you recall if there are any other examples in the
`
` '740 patent where the connection is other than at the
`
` ends of the coil?
`
` A. As far as being depicted that way in
`
` figures, I don't -- I don't recall a situation like
`
` that where a -- a 220 connects to a 320 except as, you
`
` know, through a solder connection that -- that it
`
` appears to be at the -- near the end of a coil.
`
` Q. Okay. Now, referring back to Figure 28,
`
` there isn't a reference number in that Figure 130 for
`
` the receiving space, but is it fair to say that the
`
` receiving space would be approximately where the
`
` connecting terminals are located? So 320, 310, 350 or
`
` so.
`
` MR. JARRATT: Objection. Form.
`
` BY MR. PAPAGEORGIOU:
`
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` that that connection happens at the ends of the coil
`
` 200; is that correct?
`
` A. So referring back to that solder like I was
`
`Page 28
`
` Do you see that?
` A. Yes.
` Q. Yeah. And then when we look at 27, that's
` an unexploded view; is that correct?
` A. Yes.
` Q. Okay. And then -- so in Figure 27, it would
` appear that the connecting unit 300 is in the area of
` the receiving space.
` Do you see that?
` A. That's -- that's a -- a way to interpret it.
` Q. Well, is -- is there -- you know, can you --
` if you interpret it differently, you know, let us know.
` A. So one thing I would bring up is when we
` look at Figure 28, we have the adhesive layer, I
` believe, which is 710.
` Q. Um-hum.
` A. And so in our Claim 6, for instance, we're
` talking about a receiving space in an adhesive layer.
` Q. Correct.
` A. So -- so, you know, in that case, you know,
` I think it -- I think it could depend on -- on where
` precisely the receiving space should -- should be.
` So if we -- if we look in Figure 28 and now
` go to the right, that if the receiving space is only to
` have the width of the adhesive layer, in that case,
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` Q. Let me display Figure 26 for you, and you
`
` could see where 130 is.
`
`Page 29
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` only terminals 320 and 310 and 350 -- those are the --
`
` the things that enter that receiving space but not 300.
`
` Whereas if -- if the receiving space is to
`
` be taller or have more thickness or extend upward and
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` actually be the -- the -- the thickness of the entire
`
` magnetic substrate plus the adhesive layer, you know,
`
` then -- then you could say that that blank rectangle
`
` 300 --
`
` Q. Okay. Okay.
`
` So in Figure 28, is it then fair to say that
`
` the connecting unit 300 is vertically above the
`
` adhesive layer 710?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: I think there you could say
`
` that 300 would be -- overlap the receiving space in a
`
` vertical direction perpendicular to the adhesive layer.
`
` So I'm not sure if that answers your
`
` question.
`
` BY MR. PAPAGEORGIOU:
`
` Q. Yeah, that does. That does. Thank you.
`
` Now, referring back to Figure 28 again. The
`
` coil 230 is depicted on adhesive layer 700.
`
` Do you see that?
`
` A. Yes. It's o