UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`Case IPR2022-00118
`U.S. Patent No. 10,804,740
`
`________________
`
`SUPPLEMENTAL DECLARATION OF JOSHUA PHINNEY, PH.D.,
`UNDER 37 C.F.R. § 1.68
`
`Ex.1018 / IPR2022-00118 / Page 1 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`Case IPR2022-00118
`U.S. Patent No. 10,804,740
`
`________________
`
`SUPPLEMENTAL DECLARATION OF JOSHUA PHINNEY, PH.D.,
`UNDER 37 C.F.R. § 1.68
`
`Ex.1018 / IPR2022-00118 / Page 1 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`TABLE OF CONTENTS
`
`A.
`
`Introduction ...................................................................................................... 3
`
`B.
`
`C.
`
`Substitute claims 21 and 22 fail to inform with reasonable certainty,
`those skilled in the art about the scope of the invention. ................................ 4
`
`POSITAs would have found substitute claims 21-23 obvious under 35
`U.S.C. § 103 over Kato. ................................................................................... 6
`
`a.
`
`b.
`
`Summary ............................................................................................... 6
`
`Detailed Analysis ................................................................................ 11
`
`D. Declaration ..................................................................................................... 33
`
`
`
`
`
`
`
`
`2
`
`Ex.1018 / IPR2022-00118 / Page 2 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`I, Joshua Phinney, Ph.D., declare:
`
`A.
`
`Introduction
`
`1.
`
`I am making this supplemental declaration at the request of Apple Inc.
`
`in the matter of the Inter Partes Review IPR2022-00118 of U.S. Patent No.
`
`10,804,740 (the “’740 Patent”) to An et al. The terms of my engagement, my
`
`background and qualifications, prior testimony, and the legal standards and claim
`
`constructions that I am applying are set forth in my previous CV and declaration.
`
`See Ex.1003; Ex.1004.
`
`2.
`
`In the preparation of this declaration, I have studied the materials
`
`noted in my previous declaration, as well as the following additional materials:
`
`(1) Ex.1016 – Plaintiff’s Preliminary Disclosure of Asserted Claims and
`
`Infringement Contentions to Apple Inc.
`
`(2)
`
` Ex.1017 – U.S. Patent Publication No. 2008/0164840 to Kato et al.
`
`(“Kato”).
`
`(3) Ex.1019 – The Merriam-Webster Dictionary, Merriam-Webster, Inc.,
`
`1995.
`
`(4) Ex.1020 – The Wayback Machine, capture of “Separate | Define
`
`Separate at Dictionary.com” on February 7, 2012,
`
`https://web.archive.org/web/20120207103735/http://dictionary.referen
`
`
`
`3
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`Ex.1018 / IPR2022-00118 / Page 3 of 33
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`ce.com:80/browse/separate.
`
`3.
`
`In forming the opinions expressed below, I have considered:
`
`(1) The documents listed above, and
`
`(2) My own knowledge and experience, including my work experience in
`
`the field of wireless power, as described below.
`
`B. Substitute claims 21 and 22 fail to inform those skilled in the art about the
`scope of the invention with reasonable certainty.
`
`4.
`
`It is my opinion that substitute claims 21 and 22 in Patent Owner’s
`
`Motion to Amend fail to inform a person of ordinary skill in the art (“POSITA”)
`
`about the scope of the claimed invention with reasonable certainty. In particular,
`
`the new requirement of a “separate” connecting unit creates an internal
`
`contradiction. A POSITA would not have understood how the connecting unit is
`
`“separate from the coil, the first connection terminal, and the second connection
`
`terminal” in view of the originally claimed requirement that the “connecting unit
`
`comprises: a third connection terminal connected to the first connection terminal”
`
`and “a fourth connection terminal connected to the second connection terminal.”
`
`5.
`
`Substitute claims 21 and 22 recite “a discrete connecting unit separate
`
`from the coil, the first connection terminal, and the second connection terminal”
`
`(underlining denoting newly added claim language). The added requirement that
`
`
`
`4
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`Ex.1018 / IPR2022-00118 / Page 4 of 33
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`the connecting unit be “separate” from the first and second connection terminals
`
`contradicts the originally claimed requirement that the connecting unit be
`
`“connected” to the first and second connection terminals. For example, the
`
`“connecting unit comprises: a third connection terminal connected to the first
`
`connection terminal” and also comprises “a fourth connection terminal connected
`
`to the second connection terminal.” The amended claim requires the connecting
`
`unit to be both (i) “connected” to the first and second connection terminals (via the
`
`third and fourth connection terminals) and (ii) “separate” from the first and second
`
`connection terminals.
`
`6.
`
`I note that the specification of the ’740 patent does not use the term
`
`“separate” with respect to the connecting unit. For example, the ’740 patent does
`
`not recite that the connecting unit is “separate” from any other element in the
`
`wireless power receiver. In fact, the term “separate” does not appear at all in the
`
`’740 patent specification. The specification instead describes the connection
`
`terminals of the connecting unit as being “connected” to the other connection
`
`terminals by a solder. Ex.1001, 5:46-60, 6:34-39, 7:14-19,13:7-12. For example,
`
`Ex.1001, 5:46-60 states:
`
`In detail, the first connection terminal 210 of the coil unit 200
`
`may be connected to the first connection terminal 310 of the
`
`connecting unit 300 through a first solder 10 and the second
`
`
`
`5
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`Ex.1018 / IPR2022-00118 / Page 5 of 33
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`connection terminal 220 of the coil unit 200 may be connected to
`
`the second connection terminal 320 of the connecting unit 300
`
`through a second solder 20.
`
`7.
`
`I also note that the commonly understood meaning of “separate” is
`
`“not connected.” See, e.g., Ex. 1019 (Merriam-Webster), p. 473; Ex.1020, 2
`
`(defining “separate” as “detached, disconnected, or disjoined”). It is my opinion
`
`that a POSITA would not have understood how the connecting unit can be both
`
`“connected to” the first and second connection terminals and not connected to the
`
`first and second connection terminals.
`
`8.
`
`Therefore, it is my opinion that a POSITA would be unable to
`
`ascertain the scope of substitute claims 21 and 22 with reasonable certainty.
`
`C. A POSITA would have found substitute claims 21-23 obvious over Kato.
`
`9.
`
`I have been asked to provide my opinion as to whether Substitute
`
`Claims 21-23 in Patent Owner’s Motion to Amend would have been obvious in
`
`view of prior art. The discussion below provides a detailed analysis of how U.S.
`
`Patent Publication No. 2008/0164840 to Kato et al. renders obvious the limitations
`
`of the substitute claims.
`
`a. Summary
`
`10. Like the’740 Patent, Kato relates to a “non-contact power
`
`transmission coil for use in power transmission in a noncontact manner ... when
`
`
`
`6
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`Ex.1018 / IPR2022-00118 / Page 6 of 33
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`charging a rechargeable battery incorporated in a small-size, thin portable terminal
`
`such as a mobile phone unit.” Ex.1017, [0003]. Therefore, Kato describes a “coil”
`
`in a mobile phone unit for wireless power reception via electromagnetic induction:
`
`This invention relates to a noncontact power-transmission coil
`
`for use in power transmission in a noncontact manner using
`
`electromagnetic induction, when charging a rechargeable
`
`battery incorporated in a small-size, thin portable terminal such
`
`as a mobile phone unit.
`
`Ex.1017, [0003] (emphasis added).
`
`secondary power-transmission coil 21 (wireless power receiver)
`(wireless power receiver)
`
`mobile phone 2
`
`cradle 1
`
`Ex.1017, Fig. 3 (annotated)
` (annotated)
`
`
`
`11. Fig. 3 of Kato, reproduced and annotated above, illustrates a mobile
`
`phone unit 2 having a “secondary power-transmission coil 21” that wirelessly
`
`receives power from “primary power-transmission coil 10” within a cradle 1.
`
`
`
`7
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`Ex.1017, [0049]-[0052], [0058].
`
`12. The coil 21 in the mobile phone unit 2 includes the same common
`
`components as the ’740 Patent’s wireless power receiver, arranged in the same
`
`way. Ex.1017, [0080]-[0084] and Figs. 17-20. For example, with reference to
`
`Figure 19, reproduced and annotated below, Kato explains that its noncontact
`
`power-transmission coil includes a planar coil 21 on an adhesion sheet (adhesive
`
`layer) 42, a receiving space in the adhesive layer, and a flexible printed circuit
`
`board 90, which acts as a connecting unit. Ex.1017, [0080]-[0081].
`
`
`
`13. Kato also discloses a second coil contact portion (first connection
`
`terminal) 35 and a first coil contact portion (second connection terminal) 36
`
`connected to an outer and an inner end of the coil 21, respectively. In particular,
`
`Kato discloses: “the first coil contact portion 36 arranged in the inner peripheral
`
`portion 37 of the planar coil, the second coil contact portion 35 arranged near the
`
`
`
`8
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`outside of the outer peripheral portion 38 of the planar coil.” Ex.1017, [0082].
`
`Figure 17 has been reproduced below and annotated to highlight the first
`
`connection terminal 35 and the second connection terminal 36.
`
`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`14. Moreover, Kato explains that the planar coil 21 is separable from the
`
`flexible printed circuit board 90. In particular, Figure 18 of Kato illustrates “a
`
`schematic front view of the noncontact power-transmission coil in which the planar
`
`coil shown in Figure 17 is not stuck on the flexible printed-circuit board.” Ex.1017,
`
`[0034]. Additionally, the flexible printed circuit board 90 overlaps a gap in the
`
`adhesion sheet 42 in the vertical direction perpendicular to the adhesion sheet, as
`
`shown in Figure 19, annotated and reproduced below.
`
`
`
`
`
`9
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`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`15. Additionally, Kato illustrates that a first connection terminal 35 and a
`
`second connection terminal 36 contact the third and fourth connection terminals
`
`located on the flexible printed circuit board 90, respectively, as shown in Figure
`
`19, reproduced and annotated below. The printed circuit board 90 further includes
`
`a first inner conductor pattern 33 and a second inner conductor pattern 34.
`
`Ex.1017, [0079]. An exposed end of the conductor pattern 34 is connected to the
`
`second coil contact portion (first connection terminal) 35, whereas an exposed end
`
`of the conductor pattern 33 is connected to the coil contact portion (second
`
`connection terminal) 36 at the inner end of the coil 40. Kato describes:
`
`Furthermore, the first coil contact portion 36 is electrically
`
`connected to the first external connection terminal portion 31
`
`
`
`10
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`Ex.1018 / IPR2022-00118 / Page 10 of 33
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`through the first inner conductor pattern 33 formed under the
`
`surface insulating layer. In addition, the second coil contact
`
`portion 35 is electrically connected to the second external
`
`connection terminal portion 32 through the second inner
`
`conductor pattern 34 formed under the surface insulating layer.
`
`Ex.1017, [0082].
`
`Ex.1017, Fig. 19 (annotated)
`
`
`
`
`16. As a result, it is my opinion that a POSITA would have found
`
`Substitute Claims 21, 22, and 23 obvious.
`
`b. Detailed Analysis
`
`17. The following claim chart describes how the Kato reference renders
`
`obvious the Substitute Claims 21, 22, and 23.
`
`Claim 21
`
`Prior Art
`
`[21.0] A
`wireless
`power
`receiver,
`
`
`
`Kato discloses a wireless power receiver.
`
`
`11
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`Ex.1018 / IPR2022-00118 / Page 11 of 33
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`comprising:
`
`
`
`“[A] noncontact power-transmission coil for use in power
`transmission in a noncontact manner using electromagnetic
`induction.” Ex.1017, [0003].
`
`
`
`
`
`
`secondary power-transmission coil 21 (wireless power receiver)
`(wireless power receiver)
`
`mobile phone 2
`
`cradle 1
`
`
`
`Ex.1017, Fig. 3 (annotated)
` (annotated)
`
`
`
`As shown above in Fig. 3, a mobile phone unit 2 is
`illustrated having a “secondary power-transmission coil 21”.
`
`The secondary transmission coil 21 (wireless power receiver)
`wirelessly receives power from the “primary power transmission
`coil 10 within a cradle 1. Ex.1017, [0049]-[0052].
`
`“[W]hen an alternating voltage is induced in the secondary
`power-transmission coil 21 with the alternating voltage from the
`primary power-transmission coil 10 of the cradle 1, the mobile
`phone unit 2 rectifies the induced alternating voltage and then
`converts it into a direct current voltage, followed by charging the
`battery 22 with the direct current voltage.” Ex. 1017, [0058]
`(emphasis added).
`
`
`
`
`12
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`Figs. 17-20 of Kato illustrate one example of a power transmission
`coil 21 WD for reception of power in a mobile phone like shown in
`Fig. 3 above. The power transmission coil 21 WD used as shown
`below in Fig. 17, the power transmission coil 21WD is an assembly
`of elements, including a coil 40 on the surface on the surface of a
`flexible printed-circuit board 90 that includes a wiring layer 33/34.
`Ex. 1017, [0081]-[0083].
`
`
`
`secondary power-
`transmission coil 21WD
`(wireless power
`receiver)
`
`flexible
`printed-circuit
` board 90
`
`
`
`[21.1] an
`adhesive
`layer
`comprising a
`receiving
`space;
`
`
`
`planar coil 40
`
`
`
`Ex.1017, Fig. 17 (annotated)
` (annotated)
`Kato discloses “an adhesive layer comprising a receiving space.”
`
`In particular, Kato discloses that the power transmission coil 21WD
`shown in annotated Fig. 19 below includes an “adhesion sheet 42”
`(adhesive layer) that is used to adhere the coil 40 to the flexible
`printed circuit board 90. Ex. 1017, [0081].
`
`“One flat surface of the planar coil formed of the wound electric
`wire 40 is stuck on the surface of the flexible printed-circuit board
`90 though an adhesion sheet 42.” Id. (Emphasis added).
`
`
`
`
`13
`
`Ex.1018 / IPR2022-00118 / Page 13 of 33
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`As shown in annotated Figs. 19 and 17 below, the adhesive layer 42
`includes a gap (receiving space) corresponding to the “inner
`peripheral portion 37” of the coil 40 to accommodate (i.e., receive)
`the first coil contact portion 36. Ex.1017, [0082].
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`Ex.1017, Fig. 17 (annotated)
` (annotated)
`
`
`
`
`The gap allows the first coil contact portion 36 to electrically
`connect the coil to the wiring layer of the flexible printed board 90.
`
`
`
`
`
`14
`
`Ex.1018 / IPR2022-00118 / Page 14 of 33
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`While the term “receiving space” is not used in Kato, it would be
`obvious for a person of ordinary skill in the art to find that the gap
`in Kato’s adhesion sheet is a receiving space because it is a space
`that receives the first coil contact portion 36.
`
`Kato discloses “a coil on the adhesive layer.”
`
`Kato teaches that a “planar coil formed of the wound electric wire
`40 is stuck on the surface of the flexible printed-circuit board 90
`through an adhesion sheet 42,” as shown in Fig. 19. Ex.1017,
`[0081].
`
`
`
`[21.2] a coil
`on the
`adhesive
`layer;
`
`
`
`[21.3] a first
`connection
`terminal
`connected to
`an outer end
`of the coil;
`
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`Kato teaches “a first connection terminal connected to an outer end
`of the coil.”
`
`“The second coil contact portion 35 is electrically connected to the
`electric wire end at the end of the winding of the outer peripheral
`portion 38 of the planar coil.” Ex.1017, [0082] (emphasis added).
`
`As shown in annotated Figs. 17 and 19 below, Kato discloses a coil
`contact portion 35 (first connection terminal) that is connected to an
`outer end of the coil 40. Id.
`
`
`
`
`
`
`
`15
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`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`Kato discloses: “a second connection terminal connected to an inner
`end of the coil.”
`
`“[T]he first coil contact portion 36 is electrically connected to the
`electric wire end at the start of the winding of inner peripheral
`portion 37 of the planar coil.” Ex.1017, [0082] (emphasis added).
`
`As shown in annotated Figs. 17 and 19 below, Kato discloses a coil
`contact portion 36 (second connection terminal) that is connected to
`
`16
`
`[21.4] a
`second
`connection
`terminal
`connected to
`an inner end
`of the coil;
`
`
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`Ex.1018 / IPR2022-00118 / Page 16 of 33
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`an inner end of the coil 40. Id.
`
`
`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`
`
`
`Kato discloses: “a discrete connecting unit separate from the coil, the
`first connection terminal, and the second connection terminal, the
`connecting unit overlapping the receiving space in a vertical
`direction perpendicular to the adhesive layer and connected to a
`
`17
`
`[21.5] a
`discrete
`connecting
`unit separate
`from the coil,
`
`
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`Ex.1018 / IPR2022-00118 / Page 17 of 33
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`circuit separate from the connecting unit.”
`
`As shown in annotated Fig. 18 below, Kato discloses a “flexible
`printed-circuit board 90” (discrete connecting unit) “with an
`insulating layer and formed so as to substantially fit to the shape of
`the flat surface of the planar coil.” Ex.1017, [0082].
`
`The circuit board 90 includes “first inner conductor pattern 33” and
`“second inner conductor pattern 34” that are “formed under the
`surface insulating layer” to electrically connect the coil to the
`connections 31 and 32. Id.
`
`
`inner
`conductors
`33, 34
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`the first
`connection
`terminal, and
`the second
`connection
`terminal, the
`connecting
`unit
`overlapping
`the receiving
`space in a
`vertical
`direction
`perpendicular
`to the
`adhesive
`layer and
`connected to
`a circuit
`separate from
`the
`connecting
`unit,
`
`
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`
`
`FIG. 18 is a schematic front view of the noncontact power-
`transmission coil in which the planar coil shown in FIG. 17 is not
`stuck on the flexible printed-circuit board. Ex.1017, [0034].
`
`As shown above in Fig. 18, under any interpretation, the circuit
`board 90 (connecting unit) is separate and separable from the coil.
`Id.
`
`Kato further explains that the board’s insulating layer is not formed
`
`
`
`18
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`at the inner or outer portion of the coil such that “the inner conductor
`of the flexible printed-circuit board 90 is exposed to the outside.”
`Ex.1017, [0082] (emphasis added).
`
`Because the board’s inner conductor is exposed to the outside (at
`least at some point during manufacture), they are separate from any
`connection terminals to which they might connect, such as coil
`contact portion 35 (first connection terminal) and the coil contact
`portion 36 (second connection terminal).
`
`Additionally, as shown in annotated Fig. 19 below, the flexible
`printed circuit board 90 (connecting unit) overlaps the gap in the
`adhesion sheet 42 (receiving space) in the vertical direction
`perpendicular to the adhesion sheet.
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`Moreover, Kato teaches that the circuit board 90 of the secondary
`power-transmission coil 21WD is connected to a separate “charging
`control circuit” in the mobile phone that detects a voltage change in
`the secondary power-transmission coil:
`
`“The charging control circuit of the mobile phone unit 2 according to
`
`
`
`19
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`the embodiment is allowed to detect a voltage change in response to
`a change in magnetic field of the secondary power-transmission coil
`21.” Ex.1017, [0055].
`
`
`
`Kato discloses: “wherein the connecting unit comprises: a third
`connection terminal connected to the first connection terminal.”
`
`As described in [21.5], the circuit board 90 (connecting unit)
`includes a second inner conductor pattern 34 with an “exposed” end
`at the outer end of the coil 40. Ex.1017, [0082].
`
`
`inner
`conductor
`34 with
`exposed end
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`[21.6]
`wherein the
`connecting
`unit
`comprises: a
`third
`connection
`terminal
`connected to
`the first
`connection
`terminal;
`
`
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`
`
`
`As illustrated in Fig. 19 below, the exposed end of the conductor
`pattern 34 (third connection terminal) is connected to the coil contact
`portion 35 (first connection terminal).
`
`
`
`
`20
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`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`
`
`Kato discloses: “a fourth connection terminal connected to the
`second connection terminal at the inner end of the coil.”
`
`As described in [21.5], the circuit board 90 (connecting unit)
`includes a first inner conductor pattern 33 with an “exposed” end at
`the inner end of the coil 40. Ex.1017, [0082].
`
`
`inner
`conductor
`33 with
`exposed end
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`[21.7]
`[wherein the
`connecting
`unit
`comprises:]
`a fourth
`connection
`terminal
`connected to
`the second
`connection
`terminal at
`the inner end
`of the coil;
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`
`As illustrated in Fig. 19 below, the exposed end of the conductor
`
`
`
`
`
`21
`
`Ex.1018 / IPR2022-00118 / Page 21 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`pattern 33 (fourth connection terminal) is connected to the coil
`contact portion 36 (second connection terminal) at the inner end of
`the coil 40.
`
`
`Ex.1017, Fig. 19 (annotated)
`
`
`
`Kato discloses: “[wherein the connecting unit comprises:] a wiring
`layer connected to the third connection terminal and the fourth
`terminal.”
`
`As described in [21.5], and as shown in Fig. 18 below, the printed
`circuit board 90 (connecting unit) includes first inner conductor
`pattern 33 and second inner conductor pattern 34 (together the wiring
`layer). Ex.1017, [0079].
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`[21.8]
`[wherein the
`connecting
`unit
`comprises:] a
`wiring layer
`connected to
`the third
`connection
`terminal and
`the fourth
`terminal.
`
`
`
`
`
`22
`
`Ex.1018 / IPR2022-00118 / Page 22 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`
`
`
`As shown in Fig. 18 above, the conductor patterns 33 and 34 are
`respectively connected to their exposed end portions (third and
`fourth connection terminals). Ex.1017, [0082].
`
`
`Claim 22
`
`Prior Art
`
`[22.0] A
`wireless
`power
`receiver,
`comprising:
`
`
`
`[22.1] an
`adhesive
`layer
`comprising a
`receiving
`space;
`
`
`
`
`
`Kato discloses “[a] wireless power receiver,” as described above in
`[21.0].
`
`
`Kato discloses “an adhesive layer comprising a receiving space,” as
`described above in [21.1].
`
`
`
`
`23
`
`Ex.1018 / IPR2022-00118 / Page 23 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`[22.2] a coil
`on the
`adhesive
`layer;
`
`
`
`[22.3] a first
`connection
`terminal
`connected to
`one end of
`the coil;
`
`
`
`[22.4] a
`second
`connection
`terminal at
`another end
`of the coil;
`and
`
`
`
`Kato discloses “a coil on the adhesive layer,” as described above in
`[21.2].
`
`
`Kato discloses “a first connection terminal connected to one end of
`the coil,” as described in [21.3].
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Kato discloses “a second connection terminal at another end of the
`coil,” as described below and above in [21.4].
`
`“[T]he first coil contact portion 36 is electrically connected to the
`electric wire end at the start of the winding of inner peripheral
`portion 37 of the planar coil.” Ex.1017, [0082] (emphasis added).
`
`As shown in annotated Figs. 17 and 19 below, Kato discloses a coil
`contact portion 36 (second connection terminal) that is connected to
`another end of the coil 40. Id.
`
`
`
`
`24
`
`Ex.1018 / IPR2022-00118 / Page 24 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`Ex.1017, Fig. 17 (annotated)
`
`
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`Kato discloses: “a discrete connecting unit separate from the coil, the
`first connection terminal, and the second connection terminal, the
`connecting unit disposed corresponding to the receiving space and
`connected to a circuit separate from the connecting unit,” as
`described below and above in [21.5].
`
`
`
`As shown in annotated Fig. 18 below and described above in [21.5],
`Kato discloses a “flexible printed-circuit board 90” (discrete
`connecting unit) that is separate from the coil, the coil contact
`portion 35 (first connection terminal) and the coil contact portion 36
`
`25
`
`[22.5] a
`discrete
`connecting
`unit separate
`from the coil,
`the first
`connection
`terminal, and
`the second
`connection
`
`
`
`Ex.1018 / IPR2022-00118 / Page 25 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`(second connection terminal) and that is connected to a separate
`“charging control circuit.” Ex.1017, [0055], [0082].
`
`inner
`conductors
`33, 34
`
`
`flexible
`printed-circuit
` board 90
`(connecting unit)
`
`terminal, the
`connecting
`unit disposed
`correspondin
`g to the
`receiving
`space and
`connected to
`a circuit
`separate from
`the
`connecting
`unit;
`
`
`
`Ex.1017, Fig. 18 (annotated)
` (annotated)
`
`
`
`FIG. 18 is a schematic front view of the noncontact power-
`transmission coil in which the planar coil shown in FIG. 17 is not
`stuck on the flexible printed-circuit board. Ex.1017, [0034].
`
`As shown above in Fig. 18, under any interpretation, the circuit
`board 90 (connecting unit) is separate and separable from the coil.
`Id.
`
`Kato further explains that the board’s insulating layer is not formed
`at the inner or outer portion of the coil such that “the inner conductor
`of the flexible printed-circuit board 90 is exposed to the outside.”
`Ex.1017, [0082].
`
`Because the board’s inner conductor is exposed to the outside (at
`least at some point during manufacture), they are separate from any
`connection terminals to which they might connect, such as coil
`contact portion 35 (first connection terminal) and the coil contact
`portion 36 (second connection terminal).
`
`
`
`
`26
`
`Ex.1018 / IPR2022-00118 / Page 26 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`Additionally, as shown in annotated Fig. 19 below, the flexible
`printed circuit board 90 (connecting unit) overlaps the gap in the
`adhesion sheet 42 (receiving space) in the vertical direction
`perpendicular to the adhesion sheet.
`
`The flexible printed circuit board 90 is disposed corresponding to the
`gap in the adhesion sheet 42 (receiving space) because the circuit
`board is specifically positioned beneath the gap to expose circuit
`board’s inner conductor pattern 33. Ex.1017, [0082].
`
`The circuit board 90 includes “first inner conductor pattern 33” and
`“second inner conductor pattern 34” that are “formed under the
`surface insulating layer” to electrically connect the coil to the
`connections 31 and 32. Id.
`
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
`
`Moreover, Kato teaches that the circuit board 90 of the secondary
`power-transmission coil 21WD is connected to a separate “charging
`control circuit” in the mobile phone that detects a voltage change in
`the secondary power-transmission coil. Ex.1017, [0055].
`
`
`
`27
`
`Ex.1018 / IPR2022-00118 / Page 27 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`“The charging control circuit of the mobile phone unit 2 according to
`the embodiment is allowed to detect a voltage change in response to
`a change in magnetic field of the secondary power-transmission coil
`21.” Id.
`
`Kato discloses: “wherein the connecting unit comprises: a third
`connection terminal connected to the first connection terminal,” as
`described above in [21.6].
`
`
`
`Kato discloses: “a fourth connection terminal connected to the
`second connection terminal at the inner end of the coil,” as described
`above in [21.7].
`
`
`
`[22.6]
`wherein the
`connecting
`unit
`comprises: a
`third
`connection
`terminal
`connected to
`the first
`connection
`terminal;
`
`
`
`[22.7]
`[wherein the
`connecting
`unit
`comprises:]
`a fourth
`connection
`terminal
`connected to
`the second
`connection
`terminal; and
`
`
`
`[22.8]
`[wherein the
`
`Kato discloses: “[wherein the connecting unit comprises:] a wiring
`layer connected to the third connection terminal and the fourth
`
`
`
`28
`
`Ex.1018 / IPR2022-00118 / Page 28 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`terminal,” as described above in [21.8].
`
`
`
`connecting
`unit
`comprises:] a
`wiring layer
`connected to
`the third
`connection
`terminal and
`the fourth
`terminal.
`
`
`
`Claim 23
`
`
`
`[23.0] The
`wireless
`power
`receiver of
`claim 22,
`
`[23.1]
`wherein the
`receiving
`space extends
`from inside
`the coil to
`outside the
`coil,
`
`
`
`Kato renders obvious the wireless power receiver of claim 22. See
`claim 22.
`
`Kato discloses: “the receiving space extends from inside the coil to
`outside the coil.”
`
`
`The receiving space of the adhesive layer 42 extends from inside the
`coil 40 to outside the coil 40.
`
`In particular, as described above in [21.1], Kato discloses that the
`adhesive layer includes an inner gap (receiving space) corresponding
`to the “inner peripheral portion 37” of the coil. Ex.1017, [0082]
`(emphasis added).
`
`Kato also teaches that the adhesive layer includes an outer gap
`(receiving space) corresponding to the “outer peripheral portion
`38” of the coil to avoid the second coil contact portion 35. Id.
`(Emphasis added).
`
`
`
`29
`
`Ex.1018 / IPR2022-00118 / Page 29 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`
`“That is, a surface insulating layer is not formed on any of the first
`coil contact portion 36 arranged in the inner peripheral portion 37 of
`the planar coil, the second coil contact portion 35 arranged near the
`outside of the outer peripheral portion 38 of the planar coil.” Id.
`
`
`Outer
`portion of
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`
` As further illustrated in Fig. 19, which is annotated below, the
`adhesive layer also includes a receiving space on its top surface
`where the coil is received and adhered.
`
`
`
`
`Outer
`portion of
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`Accordingly, the receiving space of the adhesive layer 42 extends
`from inside the coil 40 to outside the coil 40.
`
`
`
`
`
`
`30
`
`Ex.1018 / IPR2022-00118 / Page 30 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`[23.2]
`wherein the
`third
`connection
`terminal is
`connected to
`the first
`connection
`terminal
`horizontally
`within a
`boundary
`defining the
`receiving
`space, and
`
`
`
`[23.3]
`wherein the
`fourth
`connection
`terminal is
`connected to
`the second
`connection
`terminal
`horizontally
`within the
`boundary
`defining the
`receiving
`space.
`
`
`
`Kato discloses that “the third connection terminal is connected to the
`first connection terminal horizontally within a boundary defining the
`receiving space.”
`
`
`As shown in Fig. 19, which is annotated above, Kato teaches that the
`exposed end of the conductor pattern 34 (third connection terminal)
`is connected to the coil contact portion 35 (first connection terminal)
`horizontally within a boundary defining the receiving space at the
`outer end of the coil.
`
`
`Kato discloses: “the fourth connection terminal is connected to the
`second connection terminal horizontally within the boundary
`defining the receiving space.”
`
`Ex.1017, Fig. 19 (annotated)
` (annotated)
`
`31
`
`
`
`
`
`
`
`Ex.1018 / IPR2022-00118 / Page 31 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`
`
`
`
`
`
`As shown in Fig. 19, which is annotated above, Kato teaches that the
`exposed end of the conductor pattern 33 (fourth connection terminal)
`is connected to the coil contact portion 36 (second connection
`terminal) horizontally within a boundary defining the receiving
`space at the inner end of the coil.
`
`
`
`
`
`32
`
`Ex.1018 / IPR2022-00118 / Page 32 of 33
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`
`D. Declaration
`
`18.
`
`I declare that all statements made herein on my own knowledge are
`
`true and that all statements made on information and belief are believed to be true,
`
`and further, that these statements were made with the knowledge that w
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