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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00118
`U.S. Patent No. 10,804,740
`
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`TABLE OF CONTENTS
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`PETITIONER’S EXHIBIT LIST .............................................................................. 4
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 5
`
`GROUNDS FOR STANDING ........................................................................ 5
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`III. NOTE ............................................................................................................... 5
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`IV. SUMMARY OF THE ’740 PATENT ............................................................. 6
`
`V.
`
`PROSECUTION HISTORY ........................................................................... 8
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`VI. LEVEL OF ORDINARY SKILL IN THE ART ............................................. 9
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`VII. CLAIM CONSTRUCTION ..........................................................................10
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`VIII. RELIEF REQUESTED AND THE REASONS FOR THE
`REQUESTED RELIEF .................................................................................10
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`IX. DISCRETIONARY DENIAL WOULD BE INAPPROPRIATE .................11
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`A. Discretionary denial under the Fintiv factors is not appropriate ........ 11
`
`1.
`
`2.
`
`3.
`
`4.
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`5.
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`6.
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`No evidence regarding a stay ................................................... 11
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`Parallel proceeding trial date ................................................... 11
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`Investment in the parallel proceeding ...................................... 12
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`Overlapping issues with the parallel proceeding ..................... 13
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`Petitioner is a defendant ........................................................... 13
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`Other circumstances ................................................................. 13
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`The Fintiv Framework Should Be Overturned................................... 13
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`Discretionary denial under General Plastic is not appropriate .......... 14
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`B.
`
`C.
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`2
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`D. Discretionary denial under 35 U.S.C. § 325(d) is not appropriate .... 14
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`
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`X.
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`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE ....15
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`A.
`
`B.
`
`C.
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`Challenged Claims ............................................................................. 15
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`Statutory Grounds for Challenges ...................................................... 15
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`Ground 1: Claims 6, 7, 16, 17, 19, and 20 are obvious under 35
`U.S.C. § 103(a) over Hasegawa ......................................................... 15
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`1.
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`2.
`
`3.
`
`4.
`
`5.
`
`6.
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`7.
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`Summary of Hasegawa ............................................................ 15
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`Claim 6 ..................................................................................... 20
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`Claim 7 ..................................................................................... 37
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`Claim 16 ................................................................................... 38
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`Claim 17 ................................................................................... 42
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`Claim 19 ................................................................................... 42
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`Claim 20 ................................................................................... 45
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`XI. CONCLUSION ..............................................................................................46
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`XII. MANDATORY NOTICES ...........................................................................47
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`A.
`
`B.
`
`C.
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`Real Party-in-Interest ......................................................................... 47
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`Related Matters ................................................................................... 47
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`Lead and Back-up Counsel and Service Information ........................ 47
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`CERTIFICATE OF WORD COUNT ......................................................................49
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`CERTIFICATE OF SERVICE ................................................................................50
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`3
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`PETITIONER’S EXHIBIT LIST
`
`U.S. 10,804,740
`
`Prosecution History of U.S. 10,804,740
`
`Declaration of Dr. Joshua Phinney under 37 C.F.R. § 1.68
`Curriculum Vitae of Dr. Joshua Phinney
`
`U.S. Patent Application Publication 2009/0021212 (Hasegawa)
`U.S. Patent Application Publication 2007/0069961
`
`U.S. Patent Application Publication 2014/0306656 A1 Tabata et al
`
`U.S. Patent 8,384,263 B2 to Hiramatsu et al
`Reserved
`
`Reserved
`
`Reserved
`Reserved
`Reserved
`Reserved
`Scheduling Order, Scramoge Technology Limited v. Apple Inc.,
`WDTX-6-21-cv-00579 (filed Sept. 28, 2021)
`Plaintiff’s Preliminary Disclosure of Asserted Claims and
`Infringement Contentions to Apple Inc., Scramoge Technology
`Limited v. Apple Inc., WDTX-6-21-cv-00579 (served Sept. 7, 2021)
`
`
`
`
`Ex.1001
`
`Ex.1002
`
`Ex.1003
`Ex.1004
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`Ex.1005
`Ex.1006
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`Ex.1007
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`Ex.1008
`Ex.1009
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`Ex.1010
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`Ex.1011
`Ex.1012
`Ex.1013
`Ex.1014
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`Ex.1015
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`Ex.1016
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`4
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`
`
`I.
`
`INTRODUCTION
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`U.S. Patent No. 10,804,740 (the “’740 patent,” Ex.1001) is generally
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`directed to wireless power reception via electromagnetic induction, a concept long
`
`known and applied in consumer devices. The claimed “wireless power receiver”
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`simply recites an obvious arrangement of the components commonly found in
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`these devices. For example, portable telephones already included wireless power
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`receivers with coils, adhesive layers, connection terminals, and connecting units—
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`all arranged as claimed—as illustrated in this petition.
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`Accordingly, pursuant to 35 U.S.C. §§ 311, 314(a), and 37 C.F.R. § 42.100,
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`Apple Inc. (“Petitioner”) respectfully requests that the Board review and cancel as
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`unpatentable under (pre-AIA) 35 U.S.C. §103(a) claims 6, 7, 16, 17, 19, and 20
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`(hereinafter, the “Challenged Claims”) of the ’740 patent.
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`II. GROUNDS FOR STANDING
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`Petitioner certifies that the ’740 patent is eligible for IPR and that Petitioner
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`is not barred or estopped from requesting IPR challenging the patent claims. 37
`
`C.F.R. § 42.104(a).
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`III. NOTE
`Petitioner cites to exhibits’ original page numbers. Emphasis in quoted
`
`material has been added. Claim terms are presented in italics.
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`5
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`
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`IV. SUMMARY OF THE ’740 PATENT
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`The ’740 patent generally relates to wireless power reception using
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`electromagnetic induction. Ex.1001, Abstract, 1:21-27, 4:26-29.
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`“[E]lectromagnetic induction refers to the generation of an electric current through
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`induction of a voltage when a magnetic field is changed around a conductor.”
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`Ex.1001, 1:37-40. The background of the ’740 Patent explains that the “principle
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`of electromagnetic induction has been extensively used” in devices since the
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`1880s. Ex.1001, 1:28-37. For example, “electrical toothbrushes or electrical razors,
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`which are frequently used in daily life, are charged based on the principle of
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`electromagnetic induction.” Ex.1001, 1:35-37.
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`The Challenged Claims of the ’740 patent simply recite an obvious
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`arrangement of components configured to carry out wireless power reception via
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`electromagnetic induction. The claimed “wireless power receiver” includes well-
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`known components such as a “coil,” an “adhesive layer,” and “connection
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`terminals” spatially arranged with respect to generic elements, such as a “receiving
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`space” in an adhesive layer and a “connecting unit.”
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`The specification of the ’740 patent offers few details about the components
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`recited in the Challenged Claims. For example, the embodiment of Fig. 26
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`(reproduced below) broadly describes a wireless power receiver 1000 of a
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`“portable terminal” having a receiving space 130 in an adhesive layer 710, as well
`
`6
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`
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`as coil 230, connecting unit 300, and various connection terminals. Ex.1001,
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`14:46-16:64.
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`Ex.1001, Fig. 26.
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`
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`The connecting unit 300 is generally described as having several different
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`components, including first, second, third, and fourth connection terminals and a
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`wiring layer, that together “transfer the power received from the coil unit 200 to a
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`load (not shown) through the receiver circuit.” Ex.1001, 15:38-60, Figs. 27, 28. In
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`particular, the first and second connection terminals of the connecting unit 300
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`respectively connect to the outer end and inner end of the coil 230, as illustrated in
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`7
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`
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`Fig. 27.
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`Ex.1001, Fig. 27.
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`
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`The Challenged Claims recite that the connecting unit is either “overlapping
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`the receiving space in a vertical direction perpendicular to the adhesive layer”
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`(claim 6) or “disposed corresponding to the receiving space” (claim 16). The text
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`of ’740 specification does not provide additional details with respect to these
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`spatial relationships between the connecting unit and the receiving space in the
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`adhesive layer 710.
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`As explained below, the concept of a wireless power receiver having these
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`common components broadly arranged as claimed was not new as of the earliest
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`alleged priority date of the ’740 patent.
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`V.
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`PROSECUTION HISTORY
`
`The ’740 patent was filed January 31, 2019 as U.S. Application No.
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`8
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`
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`16/264,360, and issued October 13, 2020. It claims priority to a string of
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`continuations, the earliest of which was filed October 29, 2012. It also claims
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`priority to foreign applications KR 10-2012-0029987 and KR10-2012-0079004,
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`respectively filed March 23, 2012 and July 19, 2012. It is unnecessary to determine
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`whether the ’740 Patent is entitled to its earliest alleged priority date because the
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`prior art relied upon herein pre-dates the earliest alleged priority date.
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`During a brief prosecution, the Examiner issued a notice of allowance
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`without ever issuing an office action or rejecting the claims. Ex.1002, 21-27. The
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`Examiner’s reasons for allowance stated only that: “the prior art of record does not
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`disclose or suggest a wireless power receiver, comprising, inter alia, a connecting
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`unit as claimed.” Ex.1002, 26.
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`VI. LEVEL OF ORDINARY SKILL IN THE ART
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`A Person of Ordinary Skill in The Art (“POSITA”) in 2012 would have had
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`a working knowledge of the wireless power art that is pertinent to the ’740 patent.
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`That person would have a bachelor’s degree in electrical engineering, or equivalent
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`training, and approximately two years of experience working in the field of
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`wireless power transmission. Lack of work experience can be remedied by
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`additional education, and vice versa. Ex.1003, ¶¶ 18-20.
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`9
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`VII. CLAIM CONSTRUCTION
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`In an inter partes review, claims “shall be construed using the same claim
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`construction standard that would be used to construe the claim in a civil action
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`under 35 U.S.C. 282(b), including construing the claim in accordance with the
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`ordinary and customary meaning of such claim as understood by one of ordinary
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`skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. §
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`42.100(b). The Board only construes the claims to the extent necessary to resolve
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`the underlying controversy. Nidec Motor Corp. v. Zhongshan Broad Ocean Motor
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`Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017). Petitioner submits that for the purposes
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`of this proceeding, the terms of the Challenged Claims should be given their plain
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`and ordinary meaning, and no terms require specific construction.1
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`VIII. RELIEF REQUESTED AND THE REASONS FOR THE
`REQUESTED RELIEF
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`Petitioner asks that the Board institute a trial for inter partes review and
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`cancel the Challenged Claims in view of the analysis below.
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`1 Petitioner does not concede that any term in the challenged claims meets the
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`statutory requirements of 35 U.S.C. § 112, or that the challenged claims recite
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`patentable subject matter under 35 U.S.C. § 101.
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`10
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`IX. DISCRETIONARY DENIAL WOULD BE INAPPROPRIATE
`A. Discretionary denial under the Fintiv factors is not appropriate
`
`The six factors considered for § 314 denial strongly favor institution. See
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`Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020)
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`(precedential). The district court case is at an early stage and no trial date has been
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`set despite the court issuing a scheduling order. Petitioner has diligently prepared
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`and filed this petition within 8 weeks of being served Patent Owner’s infringement
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`contentions. Ex.1016, 1-2, 7. The petition is also well within the one-year
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`timeframe allowed by Congress.
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`1. No evidence regarding a stay
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`No motion to stay has been filed, so the Board should not infer the outcome
`
`of such a motion. Sand Revolution II LLC v. Continental Intermodal Group –
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`Trucking LLC, IPR2019-01393, Paper 24 at 7 (PTAB June 16, 2020)
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`(informative); see also Dish Network L.L.C. v. Broadband iTV, Inc., IPR2020-
`
`01359, Paper 15 at 11 (Feb. 12, 2021) (“It would be improper to speculate, at this
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`stage, what the Texas court might do regarding a motion to stay…”). Thus, this
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`factor is neutral on discretionary denial.
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`2. Parallel proceeding trial date
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`The co-pending litigation is at an early stage. The district court recently
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`issued a scheduling order but did not set a trial date. Ex.1015, 4. Instead, the court
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`11
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`“expects to set this date” at the conclusion of the Markman hearing, scheduled for
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`March 8, 2022. Ex.1015, 3, 4. Without a trial date, this factor weighs heavily
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`against discretionary denial. See Sand Revolution II at 8-10, 14 (uncertainty over
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`district court’s trial date weighed against discretionary denial).
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`3. Investment in the parallel proceeding
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`The co-pending litigation is in its early stages, and the investment in it has
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`been minimal. As mentioned above, a claim construction hearing has not yet
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`occurred, fact discovery will not close until September 2022, and expert discovery
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`will not close until November 2022. Ex.1015, 3; see PEAG LLC v. Varta
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`Microbattery GmbH, IPR2020-01214, Paper 8 at 17 (Jan. 6, 2021). This lack of
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`investment favors institution.
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`Moreover, Petitioner only learned which claims were being asserted on
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`September 7, 2021. See Ex.1016 (infringement contentions). In the intervening 8
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`weeks, Petitioner has worked expeditiously to file this petition. Under Fintiv,
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`Petitioner’s prompt filing “weigh[s] against exercising the authority to deny
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`institution.” Fintiv, Paper 11 at 11 (“If the evidence shows that the petitioner filed
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`the petition expeditiously, such as promptly after becoming aware of the claims
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`being asserted, this fact has weighed against exercising the authority to deny
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`institution under NHK.”).
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`12
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`4. Overlapping issues with the parallel proceeding
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`There is no present overlap of prior art issues due to the early stage of
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`district court litigation. For example, Petitioner has not served its preliminary
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`invalidity contentions in the district court proceeding. Consequently, this factor
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`favors institution.
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`5. Petitioner is a defendant
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`Petitioner is a defendant in the litigation. That is true of most Petitioners in
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`IPR proceedings. Accordingly, this factor should not be a basis for denying
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`institution.
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`6. Other circumstances
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`The prior art presented in this Petition renders the Challenged Claims
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`unpatentable as obvious. The merits of Petitioner’s arguments are strong, and this
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`factor weighs against discretionary denial.
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`As such, because the Fintiv factors are either neutral or weigh against
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`discretionary denial, and because this Petition was filed more than six months
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`before the statutory bar date, institution should not be denied on discretionary
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`factors.
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`B.
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`The Fintiv Framework Should Be Overturned
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`Apart from Petitioner’s showing that the Fintiv factors favor institution, the
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`Fintiv framework should be overturned because it (1) exceeds the Director’s
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`13
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`authority, (2) is arbitrary and capricious, and (3) was adopted without notice-and-
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`comment rulemaking. See Apple, Inc. et al. v. Iancu, No. 5:20-cv-06128-EJD
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`(N.D. Cal.), Dkt. No. 65.
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`C. Discretionary denial under General Plastic is not appropriate
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`The ’740 patent has not been challenged in any prior IPR petition, so none of
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`the General Plastic discretionary institution factors apply to this Petition. See
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`General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper 19
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`at 16 (PTAB Sept. 6, 2016) (Section II.B.4.i. precedential).
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`D. Discretionary denial under 35 U.S.C. § 325(d) is not appropriate
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`Denial under § 325(d) is not warranted because the challenges presented in
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`this petition are neither cumulative of nor redundant to the prosecution of the ’740
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`patent. The Examiner did not consider any of the references relied upon in this
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`petition. Moreover, the challenges in this petition are non-cumulative because they
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`rely upon prior art that teach the specific limitations the Examiner found lacking in
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`the prior art of record during prosecution. Compare Ex.1002, 26 (allowance based
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`upon wireless power receiver with connecting unit as claimed) with Ex.1005,
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`[0062], [0074], [0079], Figs. 3A, 4 (teaching a wireless power-receiving coil unit
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`with connecting unit as claimed).
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`14
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`X.
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
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`A. Challenged Claims
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`Petitioner challenges claims 6, 7, 16, 17, 19, and 20, which correspond to the
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`claims asserted in the plaintiff’s infringement contentions in the co-pending
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`litigation. Ex.1016, 1.
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`B.
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`Statutory Grounds for Challenges
`
`Grounds
`#1
`
`Basis
`Claims
`6, 7, 16, 17, 19, 20 § 103 (Pre-AIA) over Hasegawa
`
`
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`U.S. Patent Application Publication No. US 2009/0021212 to Hasegawa et
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`al. (“Hasegawa,” Ex.1005) was published on January 22, 2009. Hasegawa is prior
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`art under 35 U.S.C. § 102(b).
`
`C. Ground 1: Claims 6, 7, 16, 17, 19, and 20 are obvious under 35
`U.S.C. § 103(a) over Hasegawa
`
`1.
`
`Summary of Hasegawa
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`Like the ’740 patent, Hasegawa relates to “non-contact power transmission”
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`in an electronic device such as a “portable telephone.” Ex.1005, [0002], [0062],
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`Fig. 1. Hasegawa describes a “coil unit 22” in the telephone for wireless power
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`reception via “electromagnetic induction.” Ex.1005, [0062]. The coil unit 22
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`includes a coil that corresponds to a coil in a “coil unit 12” of a charger. Ex.1005,
`
`[0062]. Specifically, the portable telephone is charged “by non-contact power
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`15
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`transmission utilizing electromagnetic induction that occurs between a coil of a
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`coil unit 12 of the charger 10 and a coil of a coil unit 22 of the portable telephone
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`20.” Ex.1005, [0062].
`
`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); Ex.1003, ¶ 41
`
`
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`
`
`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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`16
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`Inter Partes Review of U.S. 10,804,740
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`Planar coil 30
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`Lead lines 34, 35
`
`Adhesive spacer 60
`with slit 62
`
`Magnetic sheet 40
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`Ex.1005, Fig. 2 (annotated); Ex.1003, ¶ 42
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`
`
`Hasegawa explains that the purpose of the slit 62 is “to avoid at least 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
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`40 by utilizing the spacer member 60.” Ex.1005, [0073]. In other words, when the
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`planar coil 30 is adhered to the magnetic sheet 40, the inner end lead line 34 is
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`disposed within the slit 62 of the adhesive layer. Ex.1003, ¶ 43.
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`17
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`
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`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); Ex.1003, ¶ 43
`
`
`
`Hasegawa also explains that the lead lines 34 and 35 connect to coil
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`connection pads 103 (Fig. 3A above) on a substrate 100, which includes a wiring
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`pattern that connects the coil unit to the portable telephone, as illustrated in Fig. 4
`
`below. Ex.1005, [0074], [0079].
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`18
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`Coil connection
`pads 103
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`Wiring pattern
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`IPR2022-00118 Petition
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`Substrate 100
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`Contacts for
`connection to
`portable phone
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`Ex.1005, Fig. 4 (annotated); Ex.1003, ¶ 44
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`
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`As illustrated in the figures above, the lead lines 34 and 35, the coil
`
`connection pads 103, and the substrate 100 wiring pattern together electrically
`
`connect the power-receiving planar coil 30 to the portable telephone. Ex.1005,
`
`[0062], [0068], [0074], [0079], Figs. 1, 3A, 4. That is, the electric connection
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`created by these components carries the power inductively received by the coil 30
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`to a load, such as a battery, in the portable telephone 20 to charge it. Ex.1005,
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`[0062] (referring to the portable telephone as a “charging target” that is “charged”
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`using the “electromagnetic induction that occurs between a coil of a coil unit 12 of
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`the charger 10 and a coil of a coil unit 22 of the portable telephone 20”); Ex.1003,
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`19
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`
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`¶ 45.
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`2.
`[6.0] A wireless power receiver, comprising:
`
`Claim 6
`
`The preamble of claim 6 is not limiting. However, to the extent the preamble
`
`is limiting, Hasegawa renders the preamble obvious. Hasegawa discloses a “coil
`
`unit 22” (wireless power receiver) within a portable telephone 20 that wirelessly
`
`receives power via “electromagnetic induction” from a coil unit 12 within a
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`charger 10, as shown in Fig. 1 below. Ex.1005, [0062], [0063].
`
`Portable telephone 20
`
`Wireless charger 10 with
`coil unit 12
`
`Coil unit 22
`
`Ex.1005, Fig. 1 (annotated); Ex.1003, ¶ 46
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`
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`Hasegawa notes that the examples in its figures and specification apply to
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`20
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`
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`both the coil unit 12 in the charger and the coil unit 22 in the portable telephone.
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`IPR2022-00118 Petition
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`Ex.1005, [0065] (“The configurations of the coil units 12 and 22 are described
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`below with reference to FIGS. 2, 3A, and 3B taking the coil unit 12 as an example.
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`Note that the structure shown in FIG. 2 may also be applied to the coil unit 22.”).
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`Accordingly, a reference to coil unit 12 in Hasegawa’s description is also
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`applicable to coil unit 22. Ex.1003, ¶ 47.
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` [6.1] an adhesive layer comprising a receiving space
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`Hasegawa teaches that its coil unit 22 includes a “spacer member 60”
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`(adhesive layer) that “is a double-sided adhesive sheet.” Ex.1005, [0072]. As
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`illustrated in Fig. 2 below, the adhesive spacer member 60 includes “a slit 62”
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`(receiving space) configured “to avoid at least the inner end lead line 34” when the
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`coil 30 is adhered to the magnetic sheet 40. Ex.1005, [0072].
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`Adhesive spacer 60
`with slit 62
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`Ex.1005, Fig. 2 (annotated); Ex.1003, ¶ 48
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`
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`Thus, Hasegawa’s teaching of an adhesive spacer member comprising a slit
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`renders obvious “an adhesive layer comprising a receiving space,” as recited in the
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`claim. Ex.1003, ¶ 49.
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`[6.2] a coil on the adhesive layer;
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`Hasegawa teaches that the coil unit 22 includes a “planar coil 30” on the
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`adhesive spacer member 60, as illustrated in Fig. 2 below. Ex.1005, [0067], [0068].
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`“The spacer member 60 bonds the planar coil 30 to the magnetic sheet 40.”
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`22
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`Ex.1005, [0072].
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`Planar coil 30
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`Adhesive spacer 60
`with slit 62
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`Ex.1005, Fig. 2 (annotated); Ex.1003, ¶ 50
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`
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`Figure 3A of Hasegawa illustrates the coil unit 22 when the planar coil is
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`bonded to the magnetic sheet with the adhesive spacer member—i.e., the coil is on
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`the adhesive spacer member:
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`Inter Partes Review of U.S. 10,804,740
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`Planar coil 30 disposed on
`adhesive space and bonded
`to magnetic sheet 40
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`Ex.1005, Fig. 3A (annotated); Ex.1003, ¶ 51
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`
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`Thus, Hasegawa’s teaching of a planar coil on the adhesive spacer member
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`renders obvious “a coil on the adhesive layer,” as recited in the claim. Ex.1003, ¶
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`52.
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`[6.3] a first connection terminal connected to an outer end of the coil;
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`Hasegawa teaches that its coil unit 22 includes an “outer end lead line 35”
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`(first connection terminal) that is “connected to the outer end of the [coil] spiral,”
`
`as illustrated in Fig. 2 below. Ex.1005, [0068] (describing an “an outer end lead
`
`line 35 connected to the outer end of the spiral”).
`
`
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`24
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`Planar coil 30
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`Outer end of coil 30
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`Outer end lead line 35 (first
`connection terminal) connected
`to outer end of coil
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`Ex.1005, Fig. 2 (annotated); Ex.1003, ¶ 53
`
`
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`As shown in Fig. 3A below, the purpose of the outer end lead line 35 (first
`
`connection terminal) is to electrically connect the outer end of the coil to a coil
`
`connection pad 103. Ex.1005, [0074] (describing “coil connection pads 103
`
`connected to the inner end lead line 34 and the outer end lead line 35”); Ex.1003, ¶
`
`54.
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`Inter Partes Review of U.S. 10,804,740
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`Lead line 35 connects
`outer end of coil
`to coil connection pad 103
`
`Ex.1005, Fig. 3A (annotated); Ex.1003, ¶ 54
`
`
`
`Accordingly, the outer end lead line 35 is a connection terminal because it
`
`electrically connects the outer end of the coil to the connection pad 103. Ex.1003,
`
`¶¶ 55-59 (citing Ex.1007 and Ex.1008 and explaining that it was common to refer
`
`to the lead lines that “connect” to the outer and inner ends of a planar charging coil
`
`as “terminals”).
`
`Thus, Hasegawa’s teaching of an outer end lead line connected to the outer
`
`end of the coil renders obvious “a first connection terminal connected to an outer
`
`end of the coil,” as recited in the claim. Ex.1003, ¶ 60.
`
`[6.4] a second connection terminal connected to an inner end of the coil;
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`Inter Partes Review of U.S. 10,804,740
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`Hasegawa teaches that its coil unit 22 includes an “inner end lead line 34”
`
`
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`(second connection terminal) that is “connected to the inner end of the [coil]
`
`spiral,” as illustrated in Fig. 2 below. Ex.1005, [0068] (describing an “an inner end
`
`lead line 34 connected to the inner end of the spiral”).
`
`Planar coil 30
`
`Inner end of coil 30
`
`Inner end lead line 34 (second
`connection terminal) connected
`to inner end of coil
`
`Ex.1005, Fig. 2 (annotated); Ex.1003, ¶ 61
`
`
`
`As shown in Fig. 3A below, the purpose of the inner end lead line 35
`
`(second connection terminal) is to electrically connect the inner end of the coil to a
`
`coil connection pad 103. Ex.1005, [0074] (describing “coil connection pads 103
`
`27
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`
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`connected to the inner end lead line 34 and the outer end lead line 35”).
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`Lead line 34 connects
`inner end of coil
`to coil connection pad 103
`
`Ex.1005, Fig. 3A (annotated); Ex.1003, ¶ 62
`
`
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`Accordingly, the inner end lead line 34 is a connection terminal because it
`
`electrically connects the inner end of the coil to the connection pad 103. Ex.1003,
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`¶¶ 55-59 (citing Ex.1007 and Ex.1008 and explaining that it was common to refer
`
`to the lead lines that “connect” to the outer and inner ends of a planar charging coil
`
`as “terminals”).
`
`Thus, Hasegawa’s teaching of an inner end lead line connected to the inner
`
`end of the coil renders obvious “a second connection terminal connected to an
`
`inner end of the coil,” as recited in the claim. Ex.1003, ¶ 64.
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`[6.5] a connecting unit2 overlapping the receiving space in a vertical direction
`perpendicular to the adhesive layer,
`
`First, Hasegawa teaches that its coil unit includes several elements that
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`connect the power-receiving planar coil to the portable telephone to charge it,
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`including lead lines 34 and 35 (first and second connection terminals), coil
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`connection pads 103, and the wiring pattern of substrate 100 (together the
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`connecting unit). See Ex.1005, [0062] (describing charging the portable telephone
`
`via “electromagnetic induction that occurs between a coil of a coil unit 12 of the
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`charger 10 and a coil of a coil unit 22 of the portable telephone 20”), [0072]-
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`[0075], [0079]; Ex.1003, ¶¶ 65. These elements that connect the planar coil to the
`
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`2 With respect to the elements that comprise the connecting unit, claim 6 explicitly
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`recites that the third and fourth connection terminals are part of the connecting
`
`unit, but is silent in that regard as to the first and second connection terminals. The
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`’740 patent specification describes that its connecting unit 300 includes a “first
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`connection terminal 310” and “second connection terminal 320” that each connect
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`to the coil unit 200. Ex.1001, 15:57-30. Thus, although claim 6 does not require the
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`recited first connection terminal and second connection terminal to be part of the
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`connecting unit, the claim encompasses such a read based on the specification.
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`Ex.1003, ¶ 69.
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`29
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`portable telephone (together the connecting unit) are annotated in Figs. 3A and 4
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`below, where each figure shows the front side 101 of substrate 100.3
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`Ex.1005, Fig. 3A (annotated)
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`Ex.1005, Fig. 4 (annotated)
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`Lead lines 34 and 35
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`Wiring pattern
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`Coil connection pads 103
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`Front side 101 of substrate
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`Ex.1003, ¶ 66
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`
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`To the extent Hasegawa does not explicitly utilize the term “connecting
`
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`3 Although Figs. 3A and 4 both illustrate the front side 101 of the substrate 100, it
`
`appears they are mirror images of one another with respect to the placement of the
`
`components. Ex.1003, ¶ 66.
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`30
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`unit,” a POSITA would have found it obvious that the lead lines 34 and 35, coil
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`IPR2022-00118 Petition
`Inter Partes Review of U.S. 10,804,740
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`connection pads 103, and the wiring pattern on substrate 100 of the coil unit
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`together render obvious the claimed connecting unit because these components
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`together form an electrical connection between the power-receiving planar coil and
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`the portable telephone. Ex.1003, ¶ 67. This connection carries the power received
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`by the coil to the portable telephone to charge it. Ex.1003, ¶ 67 (citing Ex.1005,
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`[0062]). The ’740 Patent does not appear to provide any specific meaning to
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`“connecting unit” other than the collection of the claimed components that
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`“transfer the power received from the coil unit 200 to a load.” Ex.1003, ¶ 68 (citing
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`Ex.1001, 15:38-16:13). Moreover, with specific reference to Hasegawa’s lead lines
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`34 and 35 being part of Hasegawa’s connecting unit, it was commonly known prior
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`to the ’740 patent that antenna lead lines may form part of an external connection
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`unit. Ex.1003, ¶ 70 (citing Ex.1006, [0036]-[0042], Fig. 1).
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`Second, as discussed in [6.1], Hasegawa teaches and illustrates in Fig. 2 that
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`the slit 62 (receiving space) in adhesive spacer member 60 is configure
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