Apple Inc.
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00120, U.S. Patent No. 9,997,962
`
`Patent Owner’s Demonstrative Exhibits
`
`February 2, 2023
`
`Ex. 2020
`
`Scramoge Technology Ltd.
`
`1
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 1
`
`
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00120, U.S. Patent No. 9,997,962
`
`Patent Owner’s Demonstrative Exhibits
`
`February 2, 2023
`
`Ex. 2020
`
`Scramoge Technology Ltd.
`
`1
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 1
`
`
`
`Grounds 1-3: Not Obvious to Combine Suzuki & Lee
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`2
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 2
`
`
`
`’962 Patent, Claim 1
`
`1. A wireless power receiving antenna comprising:
`[1.1] a substrate;
`[1.2] a soft magnetic layer comprising a first magnetic sheet disposed on the substrate and a second
`magnetic sheet disposed on the first magnetic sheet;
`[1.3] a receiving coil disposed on the second magnetic sheet; and
`[1.4] an adhesive layer formed between the second magnetic sheet and the receiving coil,
`[1.5] wherein the adhesive layer includes a first adhesive layer in contact with the second magnetic
`sheet, a second adhesive layer in contact with the receiving coil, and an insulating layer disposed
`between the first adhesive layer and the second adhesive layer, and
`[1.6] wherein a height of a highest position of the second magnetic sheet from the substrate is higher
`than a height of a lowest position of the receiving coil from the substrate.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`’962 Patent, Claim 1; see also Claim 18.
`
`3
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 3
`
`
`
`Summary of Why Petition Fails
`
`• Petition relies on combination of Suzuki (U.S. Patent No. 8,421,574) and
`Lee (U.S. Patent No. 9,252,611), inter alia, for all grounds.
`• Petition focuses on the structure of Lee’s double-sided tape being used
`in Suzuki, not the composition of the tape that POSITA would be
`motivated to look to .
`• Because Suzuki already uses integrated adhesives, POSITA would
`recognize no benefit in using Lee’s double-sided tape.
`• The combination’s drawbacks would outweigh any possible benefit.
`• Clearly a case of hindsight.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`4
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 4
`
`
`
`Petition’s Approach to Suzuki/Lee Combination
`
`• As to limitation [1.4], “Suzuki teaches that an adhesive is used to
`connect the coil 170 to the magnetic layer 171.” Petition at 37 (citing
`Suzuki at 8:8-10).
`• For limitation [1.5], Petition reiterates that “Suzuki generally describes
`the use of an adhesive to connect the coil 170 to the magnetic layer
`171.” Petition at 38 (repeating cite to Suzuki at 8:8-10).
`• Petition pivots exclusively to Lee’s use of double-sided tape to connect a
`coil to a magnetic layer to conclude that a POSITA would find it obvious
`to use the double-sided tape to connect Suzuki’s coil 170 and magnetic
`layer 171.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`5
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 5
`
`
`
`The Stated Motivation to Combine Is Unfounded
`
`• Petitioner initially asserts that “Suzuki chooses to omit implementation
`details that were known to POSITAs—for example, details related to the
`specific adhesive used to adhere the secondary coil to the magnetic layer.”
`Petition at 23 (citing Suzuki at 8:8-10).
`• Suzuki’s disclosure, while short on details as to the adhesive composition,
`clearly describes the structural manner in which adhesives are to be used in
`the receiver coil block.
`• Based on the unfounded assumption that Suzuki’s disclosure regarding
`adhesives is lacking in all facets, Petitioner wrongly asserts that “[o]ne of
`ordinary skill in the art would have found it obvious to specifically implement
`Suzuki’s adhesive as a double-sided tape because it was common in the
`wireless power art to utilize double-sided tape to adhere a power-receiving
`coil to a magnetic layer.” Petition at 24.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`6
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 6
`
`
`
`Petitioner Ignores Suzuki’s Full Disclosure
`
`• Suzuki describes six embodiments
`– Petition relies on first embodiment to show that the coil is adhered to the magnetic layer
`
`– Petition relies on sixth embodiment to show that there are multiple magnetic layers
`• First embodiment (4:46 – 9:8; Figs. 1A through 8)
`– Describes general operation of a wireless charging system; circuitry of wireless transmitter
`and receiver; design and manufacturing of laminated structure of receiver coil block
`• Sixth embodiment (10:35 – 13:2; Figs. 17A through 22B)
`– Describes the use of a plurality of magnetic layers on both the transmitting and receiving
`sides in lieu of the singular magnetic layer of prior embodiments
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`7
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 7
`
`
`
`Suzuki’s Disclosure of Magnetic Materials
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`Suzuki at 6:66 – 7:12.
`
`8
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 8
`
`
`
`Suzuki’s Manufacturing of Coil Block
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`Suzuki at 7:64 – 8:16.
`
`9
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 9
`
`
`
`Petitioner Ignores Suzuki’s Full Disclosure
`
`• Suzuki describes two classes of materials to be used in the magnetic
`layer
`
`– Magnetic sheets
`– Magnetic fillers, magnetic powders or magnetic coatings
`• Suzuki’s first manufacturing method creates a magnetic layer
`consisting of the two classes of magnetic materials:
`
`(1) magnetic sheet material, “e.g., the nickel ferrite sheet”; and
`
`(2) “adhesive or pressure sensitive adhesive which is mixed with magnetic filler
`or magnetic powder.”
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`10
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 10
`
`
`
`Petitioner Ignores Suzuki’s Full Disclosure
`
`• Suzuki unequivocally identifies the adhesive, mixed with magnetic
`filler, as being part of the magnetic layer 171.
`
`Suzuki at 8:13-16.
`• Suzuki does not, as Petitioner contends, disclose a “different
`embodiment in which a separate adhesive layer is placed between the
`secondary coil 170 and the magnetic layer 171.” Petitioner’s Reply at 3.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`11
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 11
`
`
`
`Petitioner Ignores Suzuki’s Full Disclosure
`
`• Suzuki’s other manufacturing methods, which Petitioner did not rely
`on, reinforce that the adhesive, mixed with magnetic filler, is part of
`the magnetic layer 171.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`12
`
`Suzuki at 8:25-33.
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 12
`
`
`
`POSITA’s Recognition of Suzuki
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶ 36.
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶ 39.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`13
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 13
`
`
`
`POSITA’s Motivation to Combine
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`14
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶41.
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 14
`
`
`
`The Combination Provides No Benefit
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶42.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`15
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 15
`
`
`
`The Combination Is Detrimental to Suzuki
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶44.
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶44.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`16
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 16
`
`
`
`The Combination Is Detrimental to Suzuki
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶45.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`17
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶46.
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 17
`
`
`
`Obviousness Requires a Motivation to Combine
`
`•
`
`In assessing the prior art, the Board must consider whether a POSITA would
`have been motivated to combine the prior art to achieve the claimed
`invention.
`• “[O]bviousness concerns whether a skilled artisan not only could have
`made but would have been motivated to make the combinations or
`modifications of prior art to arrive at the claimed invention.”
`
`– Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed. Cir. 2015)
`• “[I]t can be important to identify a reason that would have prompted a
`person of ordinary skill in the relevant field to combine the elements in the
`way the claimed new invention does.”
`
`– KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418–19 (2007)
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`18
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 18
`
`
`
`Absence of a Benefit Precludes Obviousness
`
`• “The proper question to have asked was whether a pedal designer of ordinary
`skill, facing the wide range of needs created by developments in the field of
`endeavor, would have seen a benefit to upgrading Asano with a sensor.”
`– KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418–19 (2007)
`• The Board has found IPR Petitions deficient where “profferred reasons to
`combine” are “excessively generic” and where “Petitioner never identifies or
`explains adequately any benefit or improvement gained by adding” the
`secondary reference.
`
`– Duo Sec. Inc. v. Strikeforce Techs., Inc., IPR2017-01041, 2017 WL 4677235, at *9
`(PTAB Oct. 16, 2017)(citing In re Nuvasive, Inc., 842 F.3d 1376, 1381–82 (Fed. Cir.
`2016)(“[T]he factual inquiry whether to combine references must be thorough
`and searching, and the need for specificity pervades ....”.)
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`19
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 19
`
`
`
`Benefits Must Be Weighed Against Drawbacks
`
`• Motivation to combine requires balancing the desirability of trade-offs from a
`proposed combination. “The fact that the motivating benefit comes at the
`expense of another benefit, however, should not nullify its use as a basis to
`modify the disclosure of one reference with the teachings of another.
`Instead, the benefits, both lost and gained, should be weighed against one
`another.”
`– Winner Int’l Royalty Corp. v. Wang, 202 F.3d 1340, 1349 n.8 (Fed. Cir. 2000)
`• “Since Harding strives to increase cooling, one skilled in the art would have
`been discouraged from modifying Harding's device with Ootsuka's
`nonconductive, thermally insulating, cap.”
`
`– Ex Parte Shigetoshi Ito & Daisuke Hanaoka, Appeal No. 2010-003391, 2012 WL
`3041144, at *4 (BPAI July 23, 2012).
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`20
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 20
`
`
`
`“Could Have” Does Not Satisfy “Would Have”
`
`• “[O]bviousness concerns whether a skilled artisan not only could have
`made but would have been motivated to make the combinations or
`modifications of prior art to arrive at the claimed invention.”
`
`– Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed. Cir. 2015)
`• “An unsupported statement that combining the teachings of the two
`references would have been ‘well within the skill of a POSA,’ because the
`results of reacting a reducing sugar with an amine reactant ‘were well-known
`and predictable’ does not meet Petitioner’s burden.”
`
`– Johns Manville Corp. v. Knauf Insulation, Inc., IPR2018-00827, 2018 WL 5098902,
`at *6 (PTAB Oct. 16, 2018).
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`21
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 21
`
`
`
`The Proposed Combination Is Made In Hindsight
`
`• Petition merely makes generic assertions that a POSITA would find the
`proposed combination of Suzuki with Lee “advantageous,” “straightforward
`and predictable” and “would have had a reasonable expectation of success.”
`• Petition identifies no benefit or improvement with the proposed combination.
`• Petition does not factor in the benefits lost, i.e., detrimental effects, with
`the proposed combination.
`• “Without any explanation as to how or why the references would be
`combined to arrive at the claimed invention, we are left with only hindsight
`bias that KSR warns against.”
`
`– Ex Parte Masashi Hayakawa, Appeal No. 2020-006550, 2021 WL 6133976, at *4
`(PTAB Dec. 27, 2021).
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`22
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 22
`
`
`
`Petitioner’s New Reply Evidence
`
`• For the first time in Reply, Petitioner points to Fig. 16 of Suzuki and
`asserts that Patent Owner “conveniently omit[s]” reference to the
`figure in the Response because it “illustrates that a POSITA would have
`found it obvious to utilize a double-sided tape between the coil 170 and
`magnetic layer 171.” Reply at 6.
`
`• “In an inter partes review, the burden of persuasion is on the petitioner
`to prove ‘unpatentability by a preponderance of the evidence,’ 35
`U.S.C. § 316(e), and that burden never shifts to the patentee.”
`– Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir.
`2015).
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`23
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 23
`
`
`
`Petitioner’s New Reply Evidence
`
`• Petition does not assert that Fig. 16 suggests to a POSITA a reason to combine
`the double-sided tape of Lee with Suzuki.
`• “[I]t is of the utmost importance that petitioners in the IPR proceedings
`adhere to the requirement that the initial petition identify “with particularity”
`the “evidence that supports the grounds for the challenge to each claim.”
`
`– Acceleration Bay, LLC v. Activision Blizzard Inc., 908 F.3d 765, 775 (Fed. Cir. 2018)
`• “Petitioner may not submit new evidence or argument in reply that it could
`have presented earlier, e.g.[,] to make out a prima facie case of
`unpatentability.”
`
`– PTAB Consolidated Patent Trial Practice Guide (Nov. 21, 2019)
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`24
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 24
`
`
`
`Still No Motivation to Combine
`
`• Petition relies on first embodiment to show that the coil is adhered to the
`magnetic layer and sixth embodiment to show that there are multiple
`magnetic layers
`
`•
`
`In Reply, Petitioner improperly relies on fifth embodiment (9:64 – 10:35; Figs.
`14A through 16) for motivation to combine
`– Describes different manufacturing method of the magnetic layer 171, involving the pressing
`of a soft magnetic material made of crystalline metal material or non-crystalline metal
`material on one side of the secondary coil 170.
`
`– To prevent risk of material leaking through the spiral gap in the secondary coil, “an
`insulating thin film 175 (e.g., a PET film) between the secondary coil 170” and the magnetic
`material.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`25
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 25
`
`
`
`Still No Motivation to Combine
`
`• For each of the second through sixth embodiments, Suzuki recites “[f]or the purpose
`of clarity, like kind elements are assigned the same reference numerals as depicted in
`the first embodiment.” (See, e.g., Suzuki at 10:2-3).
`
`•
`
`•
`
`•
`
`Sixth embodiment, disclosing multiple magnetic layers, does not utilize magnetic
`material of the fifth embodiment.
`
`– “[E]ach magnetic material of the magnetic layers 121L and 171L is e.g., compound of amorphous
`material and resin.” (Suzuki at 11:26-28).
`
`Suzuki avoids the use of an insulating film layer in the first and sixth embodiments –
`that layer is unnecessary.
`
`Still no reason or rationale to combine Lee with Suzuki
`– Reply still does not identify a benefit or improvement with the proposed combination.
`– Reply still does not factor in the benefits lost, i.e., detrimental effects, with the proposed combination
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`26
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 26
`
`
`
`Ground 2: Not Obvious to Combine Suzuki & Sawa
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`27
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 27
`
`
`
`Summary
`
`2. The wireless power receiving antenna of claim 2, wherein
`the soft magnetic layer includes an Fe—Si based alloy.
`
`’962 Patent, Claim 2
`
`• Petition relies on combination of Suzuki (U.S. Patent No. 8,421,574) and Sawa (U.S.
`Patent No. 9,443,648), inter alia, for Ground 2,
`
`• Because Suzuki already discloses magnetic materials, there is no benefit to the
`proposed combination beyond what already exists in Suzuki. To the contrary, a POSITA
`would recognize drawbacks to the combination.
`
`• Petition does not present any evidence that a POSITA would have viewed Sawa’s Fe-Si
`alloy to be a predictable, known equivalent substitute for the materials already
`disclosed by Suzuki.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`28
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 28
`
`
`
`POSITA’s Motivation to Combine
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶49.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`29
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 29
`
`
`
`The Combination Is Detrimental to Suzuki
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`30
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶51.
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 30
`
`
`
`Not An Equivalent Substitution
`
`Ex. 2018, Phinney Tr. at 63:8-17.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`31
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 31
`
`
`
`Not An Equivalent Substitution
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶54.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`32
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 32
`
`
`
`No Benefit in the Combination
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶56.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`33
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 33
`
`
`
`No Benefit in the Combination
`
`Ex. 2016, Declaration of Dr. David S. Ricketts, ¶57.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`34
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 34
`
`
`
`The Proposed Combination Is Made In Hindsight
`
`• Petition merely makes the generic assertion that a POSITA would find
`the proposed combination of Suzuki with Sawa “straightforward and
`predictable.”
`
`• Petition identifies no benefit or improvement with the proposed
`combination.
`
`• Petition does not factor in the benefits lost, i.e., detrimental effects,
`with the proposed combination.
`
`• The proposed combination is made with hindsight bias.
`
`Scramoge Technology Ltd.
`
`Grounds 1-3
`
`Ground 2
`
`35
`
`Scramoge Technology Ltd.
`Ex. 2020 - Page 35
`
`
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