throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00118
`U.S. Patent No. 10,804,740
`_____________________
`
`DECLARATION OF DR. JOSHUA PHINNEY,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
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`1
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`Phinney Declaration
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`Inter Partes Review of U.S. 10,804,740
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`TABLE OF CONTENTS
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`
`
`Introduction ...................................................................................................... 3
`I.
`Qualifications and Professional Experience .................................................... 4
`II.
`III. Level of Ordinary Skill in the Art ................................................................... 8
`IV. Relevant Legal Standards ................................................................................ 9
`V.
`Background .................................................................................................... 11
`VI. Overview of the ’740 Patent .......................................................................... 13
`VII. Claim Construction ........................................................................................ 16
`VIII. Identification of how the Claims are Unpatentable ....................................... 17
`A. Ground 1: Claims 6, 7, 16, 17, 19, 20 are obvious under 35
`U.S.C. § 103(a) over Hasegawa. ......................................................... 18
`1.
`Summary of Hasegawa .................................................. 18
`2.
`Claim 6 ........................................................................... 23
`3.
`Claim 7 ........................................................................... 51
`4.
`Claim 16 ......................................................................... 52
`5.
`Claim 17 ......................................................................... 55
`6.
`Claim 19 ......................................................................... 55
`7.
`Claim 20 ......................................................................... 58
`IX. Conclusion ..................................................................................................... 60
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`Phinney Declaration
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`I, Joshua Phinney, do hereby declare as follows:
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`I.
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`INTRODUCTION
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`Inter Partes Review of U.S. 10,804,740
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`
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`1.
`
`I am making this declaration at the request of Apple Inc. in the matter
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`of the Inter Partes Review of U.S. Patent No. 10,804,740 (“the ’740 Patent”) to An
`
`et al.
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the outcome of this matter or the specifics of my testimony.
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`3.
`
`I have been asked to provide my opinions regarding whether claims 6,
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`7, 16, 17, 19, and 20 (“the Challenged Claims”) of the ’740 Patent are unpatentable
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`as they would have been obvious to a person having ordinary skill in the art
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`(“POSITA”) at the time of the alleged invention, in light of the prior art. It is my
`
`opinion that all of the limitations of the challenged claims would have been
`
`obvious to a POSITA.
`
`4.
`
`a.
`
`b.
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`Ex.1002;
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`
`
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`In the preparation of this declaration, I have studied:
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`the ’740 Patent, Ex.1001;
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`the prosecution history of the ’740 Patent (“’740 File History”),
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`Inter Partes Review of U.S. 10,804,740
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`c.
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`U.S. Patent Application Publication No. US 2009/0021212 to
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`Hasegawa et al. (“Hasegawa”), Ex.1005;
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`d.
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`U.S. Patent Application Publication 2007/0069961 to Akiho et al.; Ex.
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`1006;
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`e.
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`U.S. Patent Application Publication 2014/0306656 Tabata et al.;
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`Ex.1007;
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`f.
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`5.
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`U.S. Patent 8,384,263 to Hiramatsu et al; Ex.1008;
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`In forming the opinions expressed below, I have considered:
`
`the documents listed above;
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`the relevant legal standards, including the standard for obviousness,
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`and any additional authoritative documents as cited in the body of this
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`declaration; and
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`my own knowledge and experience based upon my work in the field
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`of networking as described below.
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`6.
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`Unless otherwise noted, all emphasis in any quoted material has been
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`added.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`7. My complete qualifications and professional experience are described
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`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
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`8.
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`I am a Principal Engineer in the Electrical Engineering and Computer
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`Science practice at Exponent, an engineering and scientific consulting firm
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`headquartered at 149 Commonwealth Drive, Menlo Park, California 94025. I
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`received a Ph.D. in Electrical Engineering from the Massachusetts Institute of
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`Technology (“MIT”) in 2005. I also earned S.M. and B.S. degrees in Electrical
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`Engineering from MIT and the University of Illinois, Chicago (“UIC”),
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`respectively.
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`9. My master’s thesis at MIT focused on the miniaturization of power
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`converters, by reducing the energy storage and improving the performance of
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`inductors. As part of this work, I designed, tested, and constructed ferrite, iron-
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`powder, and air-core inductors, while minimizing magnetic losses. During this
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`time, I invented with my advisor, Dr. David Perreault, an electrical component
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`with a capacitive impedance and an inductance-cancellation feature provided by
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`magnetically coupled windings. A filter having a capacitor with inductance
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`cancellation provides enhanced performance over frequency compared with
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`conventional capacitors. This work was later extended to a second patent, with
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`magnetically coupled windings used to improve EMI filters and common-mode
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`chokes.
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`10. My doctoral work at MIT centered on miniaturization of power
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`converters and magnetics. As part of my doctoral work, I constructed and modeled
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`planar magnetic systems, including magnetically coupled, printed magnetic coils.
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`By incorporating such compact, magnetic structures into power converters, the
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`resulting converter enjoyed multiple benefits, including waveform-shaping and
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`reduction of switch stresses. Through the modeling associated with this
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`dissertation, I become proficient in methods for analyzing the inductances of
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`packages and interconnects, especially planar or filamentous systems of
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`conductors.
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`11.
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` For my publications related to both my Master’s and Ph.D. thesis, I
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`received the William M. Portnoy Prize Paper Award (2003) and the IEEE Power
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`Electronics Society Transactions Prize Paper Award (2004).
`
`12. After earning my Ph.D., I joined Exponent and have led technical
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`investigations to portable electronic devices, microcomputers, as well as industrial
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`and consumer devices with embedded controllers. My job functions include
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`analyzing hardware and software of these devices to understand their modes of
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`failure, and testifying regarding these devices in legal matters involving patents
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`and trade secrets.
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`13. As part of my employment at Exponent, I have performed design,
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`design reviews, and failure analysis for wireless charging and communication
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`systems. The focus of this work has been (1) coupling between transmitter and
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`receiver coils from the standpoint of efficiency and magnetic-field exposure to
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`users, in particular for the Power Matters Alliance; (2) coupling of interrogators
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`and transponder coils in printed magnetic cards; and (3) integrated-circuit and coil
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`failures due to wear, dimensional changes, and triboelectric charging. In addition
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`to testifying regarding resonant and inductive wireless-power transfer, I have
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`consulted for industry regarding coil design, RFID and near-field communication
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`(NFC) integrated circuits, modulation methods, and on-metal RFID tags.
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`14.
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`I have testified regarding the software-defined features, internal
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`circuitry, and physical embodiments of electronic equipment. Regarding
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`electronics, I have testified regarding power electronics in communication systems,
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`wind turbines, grid-scale photovoltaic plants, and consumer electronics. In
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`addition, I have testified regarding control and compensation in industrial
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`controllers, voltage regulators, and switched-mode power converters. My
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`experience with wireless RF circuitry includes failure analysis of amplifiers, power
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`supplies, matching networks, and multiplexers in satellites, semiconductor-
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`processing equipment, and medical devices.
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`15. Regarding the mechanical elements of electronic equipment, I have
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`testified regarding buttons and touch interfaces, connectors, linear and rotary
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`actuators, position-measuring devices, and the design and construction of modular
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`housings for computerized equipment and peripherals. In particular, I have
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`testified regarding detachable components as they are constructed in relation to the
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`
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`housing and underlying electronic assemblies, including printed circuit boards, flex
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`printed circuits, and other connector assemblies within the housing of electronic
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`equipment.
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`16.
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`In addition to the forgoing, I perform electromagnetic assessment of
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`utility and communication infrastructure. These issues include permitting,
`
`interference, and environmental impact of radar, AC and HVDC transmission
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`lines, substations, photovoltaic installations, generators, broadcast antennas, and
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`electrified mass transit systems.
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`17.
`
`I am being compensated for my work associated with this case plus
`
`reimbursement of reasonable expenses. My compensation is not contingent on my
`
`opinions or the outcome of the case, and I have no other interest in this case or the
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`parties thereto.
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`III. LEVEL OF ORDINARY SKILL IN THE ART
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`18.
`
`I understand there are multiple factors relevant to determining the
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`level of ordinary skill in the pertinent art, including (1) the levels of education and
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`experience of persons working in the field at the time of the invention; (2) the
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`sophistication of the technology; (3) the types of problems encountered in the field;
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`and (4) the prior art solutions to those problems.
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`19. A person of ordinary skill in the art (“POSITA”) in the field of the
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`’740 Patent, as of its earliest possible filing date of March 23, 2012, would have
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`been someone knowledgeable and familiar with the wireless power arts that are
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`pertinent to the ’740 Patent. That person would have a bachelor’s degree in
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`electrical engineering, or equivalent training, and approximately two years of
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`experience working in the electrical engineering field. Lack of work experience
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`can be remedied by additional education, and vice versa.
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`20. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the earliest
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`possible priority date of the ’740 Patent (i.e., March 23, 2012). Unless otherwise
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`stated, when I provide my understanding and analysis below, it is consistent with
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`the level of a POSITA prior to the alleged priority date of the ’740 Patent.
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`IV. RELEVANT LEGAL STANDARDS
`
`21.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’740 Patent, I am relying on certain basic
`
`legal principles that counsel have explained to me. These principles are discussed
`
`below.
`
`22.
`
`I understand that prior art to the ’740 Patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the alleged
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`invention recited in the ’740 Patent. For purposes of this Declaration, I am
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`applying March 23, 2012 as the earliest possible priority date of the ’740 Patent.
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`23.
`
`I have been informed that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the
`
`invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains. I have also been informed by counsel that the obviousness analysis
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`takes into account factual inquiries including the level of ordinary skill in the art,
`
`the scope and content of the prior art, and the differences between the prior art and
`
`the claimed subject matter.
`
`24.
`
`I have been informed by counsel that the Supreme Court has
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
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`obtain predictable results; (c) use of a known technique to improve a similar device
`
`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
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`in the prior art that would have led one of ordinary skill to modify the prior art
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`reference or to combine prior art reference teachings to arrive at the claimed
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`invention.
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`25.
`
`I further understand that certain factors may support or rebut the
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`obviousness of a claim. I understand that such secondary considerations include,
`
`among other things, commercial success of the patented invention, skepticism of
`
`those having ordinary skill in the art at the time of invention, unexpected results of
`
`the invention, any long-felt but unsolved need in the art that was satisfied by the
`
`alleged invention, the failure of others to make the alleged invention, praise of the
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`alleged invention by those having ordinary skill in the art, and copying of the
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`alleged invention by others in the field. I understand that there must be a nexus—a
`
`connection—between any such secondary considerations and the alleged invention.
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`I also understand that contemporaneous and independent invention by others is a
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`secondary consideration tending to show obviousness.
`
`26.
`
`I am not aware of any allegations by the named inventor of the ’740
`
`Patent or any assignee of the ’740 Patent that any secondary considerations are
`
`relevant to the obviousness analysis of any Challenged Claim of the ’740 Patent.
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`V. BACKGROUND
`
`27. Mobile devices such as smart phones provide users with a wide
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`variety of communication mechanisms such as phone calls, text messages, internet
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`access, as well as providing other features. Mobile devices typically include a
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`built-in or detachable battery pack that is chargeable. Some types of devices may
`
`be charged wirelessly using the principle of electromagnetic induction.
`
`“[E]lectromagnetic induction refers to the generation of an electric current through
`
`induction of a voltage when a magnetic field is changed around a conductor.”
`
`Ex.1001, 1:37-40. The ’740 Patent explains that the principle of electromagnetic
`
`induction has been extensively used in devices since the 1880s:
`
`A wireless power transmission or a wireless energy transfer refers to a
`technology of wirelessly transferring electric energy to desired devices.
`In the 1800's, an electric motor or a transformer employing the principle
`of electromagnetic induction has been extensively used and then a
`method of transmitting electrical energy by irradiating electromagnetic
`waves, such as radio waves or lasers, has been suggested. Actually,
`electrical toothbrushes or electrical razors, which are frequently used in
`daily life, are charged based on the principle of electromagnetic
`induction. The electromagnetic induction refers to the generation of an
`electric current through induction of a voltage when a magnetic field is
`changed around a conductor. The electromagnetic induction scheme
`has been successfully commercialized for electronic appliances having
`small sizes, but represents a problem in that the transmission distance
`of power is too short.
`
`Ex.1001, 1:28-43.
`
`28.
`
`In the context of more recent portable devices, the principle of
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`electromagnetic induction has been applied to enable charging of a portable device
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`as it rests on a charging pad. Typically, a coil in the wirelessly chargeable device is
`
`inductively coupled with a coil in the charging pad, and current is generated in the
`
`device’s coil and transferred to its battery. The coil in the wirelessly chargeable
`
`device is one component of several that are common to most wireless power
`
`receivers. Other common components include a magnetic layer adjacent to the coil
`
`to reduce the amount of the magnetic field leaked to the outside, an adhesive layer
`
`to attach the coil to the magnetic layer, and several components that together
`
`electrically connect the coil to the load (e.g., a battery) in the chargeable device.
`
`29. As will be described in more detail below, the ’740 Patent describes
`
`and claims no more than what was already known in the art with regard to the
`
`components of common wireless power receivers.
`
`VI. OVERVIEW OF THE ’740 PATENT
`
`30. The ’740 patent generally relates to wireless power reception using
`
`electromagnetic induction. Ex.1001, Abstract, 1:21-27, 4:26-29.
`
`31.
`
`It is my opinion that the Challenged Claims of the ’740 Patent recite
`
`an obvious arrangement of components configured to carry out wireless power
`
`reception via electromagnetic induction. For example, claim 6 recites:
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`6. A wireless power receiver, comprising:
`
`an adhesive layer comprising a receiving space;
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`a coil on the adhesive layer;
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`a first connection terminal connected to an outer end of the coil;
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`a second connection terminal connected to an inner end of the coil; and
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`a connecting unit overlapping the receiving space in a vertical direction
`perpendicular to the adhesive layer,
`
`wherein the connecting unit comprises:
`
`a third connection terminal connected to the first connection terminal;
`
`a fourth connection terminal connected to the second connection
`terminal; and
`
`a wiring layer connected to the third connection terminal and the fourth
`terminal.
`
`32. The claimed “wireless power receiver” includes well-known
`
`components such as a “coil,” an “adhesive layer,” and “connection terminals”
`
`spatially arranged with respect to generic elements, such as a “receiving space” in
`
`an adhesive layer and a “connecting unit.”
`
`33.
`
`I’ve reviewed the specification of the ’740 patent and it does not
`
`provide many details about the components recited in the Challenged Claims. For
`
`example, the embodiment of Fig. 26 (reproduced below) broadly describes a
`
`wireless power receiver 1000 of a “portable terminal” having a receiving space 130
`
`in an adhesive layer 710, as well as coil 230, connecting unit 300, and various
`
`connection terminals. Ex.1001, 14:46-16:64.
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`Ex.1001, Fig. 26.
`34. The connecting unit 300 is generally described as having several
`
`different components, including first, second, third, and fourth connection
`
`terminals and a wiring layer, that together “transfer the power received from the
`
`coil unit 200 to a load (not shown) through the receiver circuit.” Ex.1001, 15:38-
`
`60, Figs. 27, 28. The first and second connection terminals of the connecting unit
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`300 respectively connect to the outer end and inner end of the coil 230, as
`
`illustrated in Fig. 27.
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`Ex.1001, Fig. 27.
`I note that the Challenged Claims recite that the connecting unit is
`
`
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`35.
`
`either “overlapping the receiving space in a vertical direction perpendicular to the
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`adhesive layer” (claim 6) or “disposed corresponding to the receiving space”
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`(claim 16). The text of ’740 Patent specification does not provide additional details
`
`with respect to these spatial relationships between the connecting unit and the
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`receiving space in the adhesive layer 710.
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`36. As I explain below, the concept of a wireless power receiver having
`
`these common components broadly arranged as claimed was not new as of the
`
`earliest alleged priority date of the ’740 Patent.
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`VII. CLAIM CONSTRUCTION
`
`37.
`
`It is my understanding that in order to properly evaluate the ’740
`
`Patent, the terms of the claims must first be interpreted. It is my understanding that
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`for the purposes of this inter partes review, the claims are to be construed under
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`the so-called Phillips standard, under which claim terms are given their ordinary
`
`and customary meaning as would be understood by one of ordinary skill in the art
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`in light of the specification and prosecution history, unless the inventor has set
`
`forth a special meaning for a term. It is my opinion that none of the claim terms
`
`require a specific construction for the purposes of this declaration, and all will be
`
`given their plain and ordinary meaning.
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`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`
`38.
`
`I have been asked to provide my opinion as to whether the Challenged
`
`Claims of the ’740 Patent would have been obvious in view of the prior art. The
`
`discussion below provides a detailed analysis of how the prior art reference
`
`identified below teaches the limitations of the Challenged Claims of the ’740
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`Patent.
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`39. As part of my analysis, I have considered the scope and content of the
`
`prior art and any differences between the alleged invention and the prior art. I
`
`describe in detail below the scope and content of the prior art, as well as any
`
`differences between the alleged invention and the prior art, on an element-by-
`
`element basis for each Challenged Claims of the ’740 Patent.
`
`40. As described in detail below, the alleged invention of the Challenged
`
`Claims would have been obvious in view of the teachings of the identified prior art
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`references as well as the knowledge of a POSITA.
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`A. Ground 1: Claims 6, 7, 16, 17, 19, 20 are obvious under 35 U.S.C.
`§ 103(a) over Hasegawa.
`
`1.
`
`Summary of Hasegawa
`
`
`
`41. Like the ’740 Patent, Hasegawa relates to “non-contact power
`
`transmission” in an electronic device such as a “portable telephone.” Ex.1005,
`
`[0002], [0062], Fig. 1. Hasegawa describes a “coil unit” in the telephone for
`
`wireless power reception via electromagnetic induction:
`
`A secondary-side electronic instrument (e.g., portable telephone 20) is
`charged using a primary-side electronic instrument (e.g., charger 10) by
`non-contact power transmission utilizing electromagnetic induction
`that occurs between a coil of a coil unit 12 of the charger 10 and a coil
`of a coil unit 22 of the portable telephone 20.
`
`Ex.1005, [0062].
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`Portable telephone 20
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`Coil unit 22
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`Wireless charger 10 with
`coil unit 12
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`Ex.1005, Fig. 1 (annotated)
`
`42. The coil unit in the portable telephone includes the same common
`
`components as the ’740 Patent’s wireless power receiver, arranged in the same
`
`way. Ex.1005, [0062], [0063], [0065], [0066]. For example, with reference to Fig.
`
`2, reproduced below, Hasegawa explains that its coil unit includes a planar coil 30
`
`attached to a magnetic sheet 40 with an adhesive spacer 60. Ex.1005, [0067],
`
`[0068], [0072]. The adhesive spacer 60 includes a slit 62 to accommodate a lead
`
`line 34 connected to the inner end of the planar coil. Ex.1005, [0068], [0072].
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`Planar coil 30
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`Lead lines 34, 35
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`Adhesive spacer 60
`with slit 62
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`Magnetic sheet 40
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`Ex.1005, Fig. 2 (annotated)
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`43. Hasegawa explains that the purpose of the slit 62 is “to avoid at least
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`
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`the inner end lead line 34” when the coil unit is assembled, as illustrated in Fig. 3A
`
`below. Ex.1005, [0072]. Specifically, due to the slit, “the non-transmission side 32
`
`of the planar coil 30 can be made flat and caused to adhere to the magnetic sheet
`
`40 by utilizing the spacer member 60.” Ex.1005, [0073]. In other words, when the
`
`planar coil 30 is adhered to the magnetic sheet 40, the inner end lead line 34 is
`
`disposed within the slit 62 of the adhesive layer, as I have shown in the annotated
`
`figure below.
`
`
`
`
`20
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`
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`

`

`Inter Partes Review of U.S. 10,804,740
`
`Phinney Declaration
`
`
`Planar coil 30 adhered to
`magnetic sheet with
`adhesive layer
`
`Lead line 34 disposed
`within slit 62 of
`adhesive layer
`
`
`
`
`
`Ex.1005, Fig. 3A (annotated)
`
`44. Hasegawa also explains that the lead lines 34 and 35 connect to coil
`
`connection pads 103 (Fig. 3A above) on a substrate 100, which includes a wiring
`
`pattern that connects the coil unit to the portable telephone, as I have illustrated in
`
`Fig. 4 below. Ex.1005, [0074], [0079]. I note that the coil connections pads 103 are
`
`located on the front side 101 of the substrate 100, which is shown in both Fig. 3A
`
`and Fig. 4. However, it appears that the figures 3A and 4 are mirror images of one
`
`another with respect to the illustrated placement of the components on the front
`
`side 101. For example, the coil connection pads 103 are illustrated on the top right
`
`edge of the front side 101 in Fig. 3A, but are illustrated on the top left edge of the
`
`
`
`
`21
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`
`

`

`Phinney Declaration
`
`front side 101 in Fig. 4. Similarly, the line of eight contacts for connection to other
`
`Inter Partes Review of U.S. 10,804,740
`
`
`
`
`
`components in the portable telephone are illustrated on bottom left edge of the
`
`front side 101 in Fig. 3A, but are illustrated on the bottom right edge of the front
`
`side 101 in Fig. 4. These superficial differences do not affect my analysis of the
`
`teachings of Hasegawa.
`
`Coil connection
`pads 103
`
`Wiring pattern
`
`Substrate 100
`
`Contacts for
`connection to
`portable phone
`
`Ex.1005, Fig. 4 (annotated)
`
`45. As illustrated in Figs. 2, 3A, and 4 above, the lead lines 34 and 35, the
`
`coil connection pads 103, and the wiring pattern on substrate 100 together
`
`electrically connect the power-receiving planar coil 30 to the portable telephone.
`
`Ex.1005, [0062], [0068], [0074], [0079], Figs. 1, 3A, 4. The electric connection
`
`
`
`
`22
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`

`

`Phinney Declaration
`
`created by these components carries the power inductively received by the coil 30
`
`Inter Partes Review of U.S. 10,804,740
`
`to a load, such as a battery, in the portable telephone 20 to charge it, as explained
`
`by Hasegawa:
`
`A secondary-side electronic instrument (e.g., portable telephone 20) is
`charged using a primary-side electronic instrument (e.g., charger 10) by
`non-contact power transmission utilizing electromagnetic induction
`that occurs between a coil of a coil unit 12 of the charger 10 and a coil
`of a coil unit 22 of the portable telephone 20.
`
`Ex.1005, [0062].
`
`2.
`[6.0] A wireless power receiver, comprising:
`
`Claim 6
`
`46. Hasegawa discloses a coil unit 22 (wireless power receiver) within a
`
`portable telephone 20 that wirelessly receives power from a coil unit 12 within a
`
`charger 10, as shown in the annotated Fig. 1 below:
`
`FIG. 1 is a view schematically showing a charger 10 and a charging
`target 20. A secondary-side electronic instrument (e.g., portable
`telephone 20) is charged using a primary-side electronic instrument
`(e.g., charger 10) by non-contact power transmission utilizing
`electromagnetic induction that occurs between a coil of a coil unit
`12 of the charger 10 and a coil of a coil unit 22 of the portable
`telephone 20.
`
`Opposite sides of the coil units 12 and 22 when performing non-contact
`power transmission as shown in FIG. 1 are referred to as transmission
`
`
`
`
`23
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`

`Phinney Declaration
`
`
`Inter Partes Review of U.S. 10,804,740
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`sides. In FIG. 1, the upper side of the coil unit 12 is the transmission
`side, and the lower side of the coil unit 22 is the transmission side. The
`side opposite to the transmission side is referred to as a non-
`transmission side.”
`
`Hasegawa, [0062]-[0063].
`
`Portable telephone 20
`
`Wireless charger 10 with
`coil unit 12
`
`Coil unit 22
`
`Ex.1005, Fig. 1 (annotated)
`
`47. Hasegawa notes that the examples in its figures and specification
`
`apply to both the coil unit 12 in the charger and the coil unit 22 in the portable
`
`telephone:
`
`The configurations of the coil units 12 and 22 are described below with
`reference to FIGS. 2, 3A, and 3B taking the coil unit 12 as an example.
`
`
`
`
`24
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`
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`

`

`Phinney Declaration
`
`
`Inter Partes Review of U.S. 10,804,740
`
`
`
`Note that the structure shown in FIG. 2 may also be applied to the
`coil unit 22.
`
`Ex.1005, [0065]. Accordingly, a reference to coil unit 12 in Hasegawa’s
`
`description is also applicable to coil unit 22.
`
`[6.1] an adhesive layer comprising a receiving space
`
`48. Hasegawa teaches that its coil unit 22 includes a spacer member 60
`
`that is a double-sided adhesive sheet, where the spacer member includes a slit 62
`
`(receiving space) to accommodate lead line 34 when coil 30 is adhered to magnetic
`
`sheet 40, as shown in the exploded oblique view of Fig. 2:
`
`FIG. 2 is an exploded oblique view showing the coil unit 12, FIG.
`3A is an oblique view showing the coil unit 12 from the front side, and
`FIG. 3B is an oblique view showing the coil unit 12 from the back side.
`
`Hasegawa, [0066].
`
`In this embodiment, a spacer member 60 having a thickness
`substantially equal to the thickness of the inner end lead line 34 is
`provided between the planar coil 30 and the magnetic sheet 40. The
`spacer member 60 is formed in the shape of a circle having almost the
`same diameter as that of the planar coil 30, and has a slit 62 so as to
`avoid at least the inner end lead line 34. The spacer member 60 is a
`double-sided adhesive sheet, for example. The spacer member 60
`bonds the planar coil 30 to the magnetic sheet 40.
`
`Hasegawa, [0072].
`
`
`
`
`25
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`

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`Phinney Declaration
`
`
`Inter Partes Review of U.S. 10,804,740
`
`
`
`Adhesive spacer 60
`with slit 62
`
`Ex.1005, Fig. 2 (annotated)
`
`49. Thus, Hasegawa’s teaching of an adhesive spacer member comprising
`
`a slit renders obvious “an adhesive layer comprising a receiving space,” as recited
`
`in the claim.
`
`[6.2] a coil on the adhesive layer;
`50. Hasegawa teaches that the coil unit 22 includes a planar coil 30 that is
`
`disposed on the adhesive spacer 60, such that the planar coil is bonded to the
`
`magnetic sheet 40:
`
`
`
`
`26
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`

`

`Phinney Declaration
`
`
`Inter Partes Review of U.S. 10,804,740
`
`In FIG. 2, the coil unit 12 is basically configured to include a planar
`coil (coil) 30 that has a transmission side 31 and a non-transmission
`side 32, a magnetic sheet 40 provided over the non-transmission side
`32 of the planar coil 30, and a heat sink/magnetic shield plate 50 stacked
`on the side of the magnetic sheet opposite to the side that faces the
`planar coil 30. The planar coil 30 is not particularly limited insofar
`as the planar coil 30 is a flat (planar) coil. For example, an air-core
`coil formed by winding a single-core or multi-core coated coil wire
`in a plane may be used as the planar coil 30. In this embodiment, the
`planar coil 30 has

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