Inter Partes Review
`U.S. Patent No. 9,997,962
`
`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00120
`
`Scott T. Jarratt,
`Haynes and Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
`
`Ex.1033 / IPR2022-00120 / Page 1 of 27
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
`
`
`U.S. Patent No. 9,997,962
`
`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00120
`
`Scott T. Jarratt,
`Haynes and Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Ex.1033 / IPR2022-00120 / Page 1 of 27
`APPLE INC. v. SCRAMOGE TECHNOLOGY, LTD.
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`
`
`The ’962 Patent
`
`Ex.1001, Fig. 5 (annotated); ’962 Petition, 8.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`2
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`
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`Ground 1: Claims 1, 18, and 19 are
`obvious over Suzuki and Lee
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
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`3
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`’962 Patent, Claim 1
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`Ex.1001, Fig. 6 (annotated); ’962 Petition, 9.
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`Ex.1001, Claim 1.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`4
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`4
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`Suzuki teaches a receiving coil embedded and adhered to a magnetic layer
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`Suzuki
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`Ex.1005, Fig. 3 (annotated); ’962 Petition, 34.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`5
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`5
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`Suzuki explains that the coil is “stuck on” the magnetic layer with
`“adhesive or pressure sensitive adhesive”
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`Ex.1005, 8:8-12; ’962 Petition, 37.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`6
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`6
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`
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`Suzuki teaches different methods of adhering the coil to the magnetic layer
`
`“Stuck on” method
`relied upon in Petition
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`“Magnetic layer is
`adhesive” method
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`Ex.1005, 7:64-8:18; ’962 Petition, 37-38; Reply, 3.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`7
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`7
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`Pressure sensitive adhesive = tape
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`• To a POSITA, a disclosure of “pressure sensitive adhesive” is a
`disclosure of tape. See, e.g.:
`
`o Ex.1020, 438 (“[T]he quintessential PSA application is adhesive
`tape.”)
`
`o Ex.1024, 2 (“The oldest and most commonly known type of PSA is an
`adhesive tape.”)
`
`o Ex.1027, 832 (“The major application area for all pressure-sensitive
`adhesives is in tapes.”)
`
`o Ex.1032, 1:25-26. (“PSA compositions have been used as tapes, in
`particular as double-sided tapes used to adhere two articles
`together.”)
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`’962 Reply, 2-4; ’962 Petition, 25-26.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`8
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`8
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`Lee illustrates it was known to adhere a coil to a magnetic layer
`with double-sided tape
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`Ex.1006, 16:31-36; ’962 Petition, 39.
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`Ex.1006, Fig. 5 (annotated); ’962 Petition, 39.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`9
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`9
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`Adhering a coil to a magnetic layer with double-sided tape was common
`
`• Beyond Lee, prior art is replete with examples of the specific
`combination. See, e.g.:
`
`o Ex.1013, 22:19-26 (“[T]he receiver coil L2 may be disposed and
`affixed on top of the magnetic shielding material 41 using double-
`sided adhesive tape.”)
`
`o Ex.1014, 5:44-48 (“An insulative double-faced tape or adhesive or the
`like is used … to adhere the upper face of first magnetic sheet 44 and
`the lower face of the charging coil 41.”)
`
`o Ex.1017, 25:21-25, 26:15-26, Fig. 13 (describing a “double-sided
`tape” between a magnetic sheet and a coil).
`
`’962 Petition, 24.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
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`10
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`
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`KSR: An old combination of old elements is obvious
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`KSR
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`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007);’962 Reply, 12-13.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`11
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`11
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`
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`Patent Owner: a POSITA would not utilize an insulating layer in Suzuki
`
`PO Response
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`Ex.1005, Fig. 16 (annotated); ’962 Reply, 7
`
`PO Response, 16-17.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`12
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`Suzuki teaches toward the combination, not away
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`Suzuki
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`Ex.1005, Fig. 16 (annotated); ’962 Reply, 7.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`13
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`13
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`Suzuki and Lee render obvious claims 1, 18, and 19
`
`Summary
`
`• Only issue in dispute: whether it was obvious to use double-side tape
`between a coil and a magnetic layer
`
`• Suzuki’s coil is “stuck on” its magnetic layer with “pressure sensitive
`adhesive” (i.e., tape)
`
`• Lee (and others) illustrate that it was routine to use double-sided tape to
`adhere a coil to magnetic layer
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`14
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`
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`Ground 2: Claims 2-4 and 7 are
`obvious over Suzuki, Lee, and Sawa
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`15
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`15
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`’962 Patent, Claim 2
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`Ex.1001, Claim 2.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`16
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`Suzuki teaches a generic soft magnetic layer
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`Suzuki
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`Ex.1005, Fig. 3 (annotated); ’962 Petition, 34.
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`Ex.1005, 10:7-10; ’962 Petition, 34.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`17
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`17
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`Suzuki motivates POSITAs to use different alloys
`for its magnetic layer, including alloys “like” Fe-Ni
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`Suzuki
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`Ex.1005, 6:66-7:8; ’962 Petition, 47-48; ’962 Reply 19-21.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`18
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`
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`Sawa illustrates that Fe-Si is “like” Fe-Ni for this application
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`Sawa
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`Ex.1008, 8:64-9:6; ’962 Petition at 48; Reply, 20-21.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`19
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`19
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`POSITAs were capable of adjusting magnetic characteristics as needed
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`Sawa
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`Ex.1008, 11:28-32; ’962 Reply, 18.
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`Dr. Ricketts’ testimony
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`Ex.1019, 27:4-6; ’962 Reply, 18.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`20
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`20
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`Patent Owner’s “magnetostriction” argument is illogical
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`PO Response
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`PO Response, 21.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`21
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`21
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`Patent Owner’s “magnetostriction” argument is illogical
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`Suzuki
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`Ex.1005, 6:66-7:8; ’962 Reply, 16-17.
`Sawa
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`Ex.1008, 8:64-9:4; ’962 Reply, 16-17.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`22
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`22
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`POSITAs could adjust magnetostriction of Fe-Si as needed
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`Sawa
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`Ex.1008, 11:28-32; ’962 Reply, 18.
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`Ex.1008, 10:48-52; ’962 Reply, 18-19.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`23
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`23
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`
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`Inter Partes Review
`U.S. Patent No. 9,997,962
`
`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00120
`
`Scott T. Jarratt,
`Haynes and Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
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`
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`Additional Slides
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`25
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`25
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`Magnetic double-sided tape
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`Prior Art
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`Ex.1030, [0012]; ’962 Reply, 5.
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`Ex.1031, 3576; ’962 Reply, 5.
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`Dr. Ricketts’ Testimony
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`Ex.1019, 67:13-17; ’962 Reply, 5.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
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`26
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`Patent Owner’s shifting theory on Suzuki’s magnetic layer
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`PO Response
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`PO Response, 8.
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`PO Sur-reply
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`PO Sur-reply, 3.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`27
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`27
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