UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT AND APPEAL BOARD
`
`Page 1
`
`APPLE INC., )
` )
` Petitioner, )
` )
` vs. ) IRP2022-00120
` )
`SCRAMOGE TECHNOLOGY LTD, )
` )
` Patent Owner. )
`_______________________________)
`
` REMOTE DEPOSITION OF
`
` JOSHUA PHINNEY, Ph.D., P.E.
`
` Thursday, July 14, 2022
`
` STENOGRAPHICALLY REPORTED BY:
` RHONDA HALL-BREUWET, RDR, CRR
` CA CSR NO. 14411
` TX CSR NO. 11956
` NV CCR NO. 990
` TN LCR NO. 675
` LA CCR NO. 2017004
` WA CCR NO. 21000131
` GA CCR NO. 5087-2801-9674-7264
` FL FPR NO. 693
` JOB NO. SY005238
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
` BEFORE THE PATENT AND APPEAL BOARD
`
`Page 1
`
`APPLE INC., )
` )
` Petitioner, )
` )
` vs. ) IRP2022-00120
` )
`SCRAMOGE TECHNOLOGY LTD, )
` )
` Patent Owner. )
`_______________________________)
`
` REMOTE DEPOSITION OF
`
` JOSHUA PHINNEY, Ph.D., P.E.
`
` Thursday, July 14, 2022
`
` STENOGRAPHICALLY REPORTED BY:
` RHONDA HALL-BREUWET, RDR, CRR
` CA CSR NO. 14411
` TX CSR NO. 11956
` NV CCR NO. 990
` TN LCR NO. 675
` LA CCR NO. 2017004
` WA CCR NO. 21000131
` GA CCR NO. 5087-2801-9674-7264
` FL FPR NO. 693
` JOB NO. SY005238
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 2
`
` July 14, 2022
`
` 1:00 p.m. Eastern
`
` Deposition of JOSHUA PHINNEY, PH.D.,
`
` P.E., held remotely before Rhonda
`
` Hall-Breuwet, Registered Diplomate Reporter,
`
` Certified Realtime Reporter, Certified
`
` Shorthand Reporter (CA and TX), Licensed Court
`
` Reporter (TN), Certified Court Reporter (GA,
`
` LA, NV, and WA), Florida Professional
`
` Reporter, and Notary Public of the State of
`
` Florida.
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 3
`
` A P P E A R A N C E S:
`
` ATTORNEYS FOR PETITIONER:
`
` HAYNES BOONE, LLP
`
` 6000 Headquarters Drive
`
` Suite 200
`
` Plano, Texas 75024
`
` (972) 739-8663
`
` BY: SCOTT JARRATT, ESQUIRE
`
` CALMANN J. CLEMENTS, ESQUIRE
`
` EMAIL: scott.jarratt@haynesboone.com
`
` calmann.clements@haynesboone.com
`
` ATTORNEYS FOR PATENT OWNER:
`
` RUSS AUGUST & KABAT
`
` 12424 Wilshire Boulevard
`
` 12th Floor
`
` Los Angeles, California 90025
`
` (310) 826-7474
`
` BY: JAMES MILKEY, ESQUIRE
`
` EMAIL: jmilkey@raklaw.com
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
` I N D E X
`
`Page 4
`
` PAGE
`
` Direct Examination By Mr. Milkey 6
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
` ------------ EXHIBITS REFERENCED -----------
`
`Page 5
`
` NUMBER DESCRIPTION PAGE
`
` EXHIBIT 1001 US Patent 9,997,962 50
`
` EXHIBIT 1003 Declaration of Dr. 7
` Joshua Phinney
`
` EXHIBIT 1005 US Patent 8,421,574 15
`
` EXHIBIT 1006 US Patent 9,252,611 24
`
` EXHIBIT 1008 US Patent 9,443,648 52
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
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`Page 6
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` CERTIFIED STENOGRAPHER: Raise
`
` your right hand, please.
`
` Do you solemnly swear the
`
` testimony you are about to give will be the
`
` truth, the whole truth, and nothing but the
`
` truth?
`
` THE WITNESS: I do.
`
` JOSHUA PHINNEY, Ph.D., P.E.
`
` acknowledged having been duly sworn to tell
`
` the truth and testified upon his oath as
`
` follows:
`
` DIRECT EXAMINATION
`
` BY MR. MILKEY:
`
` Q Good morning, Dr. Phinney.
`
` A Good morning.
`
` Q Do you have in front of you the
`
` declaration submitted in this proceeding,
`
` which is IPR 2022-00120?
`
` A I do.
`
` Q Okay. And that declaration
`
` relates to the '962 patent; correct?
`
` A Correct.
`
` Q For the record, the '962 patent,
`
` the full patent number is US Patent
`
` Number 9,997,962; is that right?
`
`TransPerfect Legal Solutions
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
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` A Yes.
`
` Q And your declaration is submitted
`
`Page 7
`
` as Exhibit 1003 in this proceeding?
`
` A Yes.
`
` Q Did you prepare for your
`
` deposition today?
`
` A I did.
`
` Q And what did you do to prepare for
`
` your deposition?
`
` A I met with counsel one day last
`
` week and one day this week on parts of the
`
` day.
`
` Q Approximately how many hours would
`
` you say you spent preparing for your
`
` deposition today?
`
` A I'd say approximately eight.
`
` (Stenographer requests
`
` clarification.)
`
` BY MR. MILKEY:
`
` Q And what did you do to prepare for
`
` your deposition today?
`
` A I reviewed my declaration. I
`
` looked at the patent owner's preliminary
`
` response, and then I guess I should just make
`
` clear that for the -- for my declaration I
`
`TransPerfect Legal Solutions
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 8
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` also looked at the prior art in other exhibits
`
` that were referenced in my declaration.
`
` Q Did you review the prior art in
`
` preparation for your deposition today?
`
` A Yes, just the -- you know, the
`
` cited exhibits in my declaration.
`
` Q And do you have an understanding
`
` or recollection of approximately how long you
`
` spent actually preparing the declaration you
`
` submitted in this case?
`
` A Yes, some -- some recollection.
`
` It's -- it was quite a while ago.
`
` Q Approximately how long did you
`
` spend preparing the declaration that you
`
` submitted in this case?
`
` A I'd say around -- around two to
`
` three days.
`
` Q Would that be around 24 hours of
`
` total work, would you say?
`
` A Yeah, that's how I'm sort of
`
` counting that. So, yeah, approximately.
`
` Q Okay. And how familiar would you
`
` say you are with the primary prior art
`
` references you relied on, in particular Suzuki
`
` Lee, Park, and Sawa?
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 9
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` A I would say I'm quite familiar
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` with them. I've read them multiple times.
`
` Q Okay. Would you please turn to
`
` paragraph 9 of your declaration.
`
` A Okay. I'm there. You said
`
` paragraph 9? I'm sorry.
`
` Q Yes.
`
` A Yes, I'm there.
`
` Q Do you see in the third sentence
`
` of paragraph 9 you say that you invented, with
`
` your advisor, quote, "intellectual components
`
` with a capacitative" -- sorry -- "with a
`
` capacitive impedance and inductance
`
` cancellation feature provided by magnetically
`
` coupled windings"?
`
` A Yes.
`
` Q Okay. And this invention provides
`
` enhanced performance over frequency compared
`
` with conventional capacitors; right?
`
` A Correct.
`
` Q Is that a benefit of your
`
` invention?
`
` A I would say so. It's one way of
`
` talking about a benefit of that invention.
`
` Q And your declaration describes the
`
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 10
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` benefit of that invention; correct?
`
` A Yeah, in that sentence with
`
` providing enhanced performance, that's part of
`
` my way of explanation why I think that
`
` invention had benefits.
`
` Q And when you were drafting your
`
` declaration, why did you include or describe
`
` this benefit of your invention in your
`
` declaration?
`
` A It's a somewhat technical
`
` invention that has to do with magnetic
`
` induction and inductance matrices and things
`
` that I need to sort of bring down to an
`
` application level to explain why -- why
`
` someone would care about them.
`
` So I'm just trying to translate my
`
` work in magnetics to a benefit just to
`
` explain, you know, my contribution to the
`
` field.
`
` Q Okay. And when you were working
`
` on that project, did you make design decisions
`
` with the intention of achieving that benefit?
`
` MR. JARRATT: Objection. Scope.
`
` BY MR. MILKEY:
`
` Q So you can --
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 11
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` MR. JARRATT: You can answer,
`
` Josh. You can answer.
`
` THE WITNESS: You could say that.
`
` There's many ways to describe the invention
`
` and why -- why it does something different
`
` than the prior art. And you could say that's
`
` true. I was trying to make design decisions
`
` sometimes in order to improve a particular
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` performance metric.
`
` BY MR. MILKEY:
`
` Q Okay. Then could you please turn
`
` to paragraph 10 of your declaration.
`
` A Okay. I'm there.
`
` Q And in the work described in
`
` paragraph 10, you constructed and modeled
`
` planar magnetic systems; is that right?
`
` A Yes.
`
` Q And did your work described in
`
` this paragraph result in specific benefits?
`
` MR. JARRATT: Objection. Scope.
`
` THE WITNESS: That's a way of
`
` putting it. Yeah, for some applications it
`
` could be -- have some benefits.
`
` BY MR. MILKEY:
`
` Q You would agree that the resulting
`
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`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 12
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` converter enjoyed multiple benefits, including
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` waveform shaping and induction of switch
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` stresses; correct?
`
` A Yes. That was in a -- even sort
`
` of a bigger context for using these -- these
`
` planar-printed magnetic coils in a power
`
` amplifier that that included those benefits,
`
` the waveform shaping and the strict -- switch
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` stress reduction.
`
` Q Okay. Could you please turn to
`
` page -- oh -- yes, could you please turn to
`
` page 33 of your declaration.
`
` A Okay. I'm there.
`
` Q And page 33 has the heading "A
`
` soft magnetic layer comprising a first
`
` magnetic sheet disposed on the substrate and a
`
` second magnetic sheet disposed on the first
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` magnetic sheet."
`
` Correct?
`
` A Yes.
`
` Q Okay. What in Suzuki are you
`
` relying on is the claimed soft magnetic layer?
`
` A So that -- the parts that I'm
`
` relying on are under that heading "First." So
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` it's in bold in paragraph 62, and then I have
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 13
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` a block quote there. And then also in 63 and
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` in 64. And so all of that under that -- not a
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` heading, but like that introductory bold
`
` "First" -- that word "first" culminates in
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` paragraph 65.
`
` So what I'm saying is all that is
`
` to support that a person of ordinary skill
`
` would understand that there is -- that
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` Suzuki's magnetic layer includes a soft
`
` magnetic layer as claimed.
`
` Q Okay. And so is the specific
`
` element that you are relying on as being the
`
` claim's soft magnetic layer, is that Suzuki's
`
` magnetic layer 171?
`
` A Yeah. That's part of it. The
`
` magnetic layer is -- you know, it's described
`
` as being made of many different materials
`
` potentially, and so in that list, you know,
`
` can be soft magnetic materials.
`
` Q Okay. So in addition to Suzuki's
`
` magnetic layer 171, you also in this section
`
` refer to magnetic layers 171H and 171L; is
`
` that correct?
`
` A And just to clarify your question,
`
` do you mean the section that you introduced on
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 14
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` page 33 that started with the heading 1.2?
`
` Q Correct.
`
` A Yes. In that section I also refer
`
` to 171H and 171L.
`
` Q Okay. What is the relationship
`
` between magnetic layer 171 and the magnetic
`
` layers 171H and 171L?
`
` A I'd point you to my paragraph 66.
`
` So this is under the heading "Second." And
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` again, I include some quotes from Suzuki and
`
` then also an annotated version of Suzuki
`
` Figure 3.
`
` And maybe just sticking with that
`
` figure for a second, at the end of
`
` paragraph 66, I shaded in green 171, and then
`
` I'm pointing to sort of an upper area and a
`
` lower area of 171 as being a second magnetic
`
` sheet and first magnetic sheet; so that H and
`
` the L.
`
` Q Okay. So you're referring to the
`
` annotated Figure 3 of Suzuki on page 37 in
`
` your declaration?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: So I'm trying to say
`
` that this entire paragraph that starts on 66,
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
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`Page 15
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` and is all under the heading "Second," is --
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` is -- you know, this is where I'm putting my
`
` support in Suzuki for what 171H and L are.
`
` And so that's -- that figure is one depiction
`
` of that.
`
` BY MR. MILKEY:
`
` Q Okay. So Figure 3 of Suzuki
`
` itself -- actually, before I ask this
`
` question, I'm going to share for the court
`
` reporter the Suzuki reference, which is
`
` Exhibit 1005 submitted in this proceeding.
`
` And if you would like to view that exhibit,
`
` Dr. Phinney, you're, of course, welcome to do
`
` so. You have a copy of that; correct?
`
` A Yes.
`
` Q So Dr. Phinney, Figure 3 of Suzuki
`
` doesn't actually make reference to magnetic
`
` layers 171H and 171L; is that correct?
`
` A I'd agree with you that the labels
`
` were -- 171H and L are not in the Figure 3,
`
` you know, as labels.
`
` Q Does Suzuki's description of
`
` Figure 3 make reference to 171H or 171L?
`
` A So if I can just be clear, what
`
` you're referring to when you say the
`
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` description of Figure 3.
`
` Q Let me just ask you this: Do you
`
` believe that Suzuki discloses that Figure 3
`
` would include layers 171H and 171L?
`
` A Yes. I think that's a fair
`
` statement. I think those layers are
`
` already -- can be part of 171.
`
` Q Okay. So are 171H and 171L really
`
` just a subset of -- oh, let me try to clarify
`
` that. So 171H and 171L, are they each
`
` individually a subset of layer 171, in your
`
` understanding?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: I'm not -- I'm not
`
` sure I exactly understand your question you're
`
` asking. Are each individually a subset?
`
` And do you think you can just
`
` rephrase that? I'm not quite sure if I'm not
`
` understanding what you're getting at for
`
` those --
`
` BY MR. MILKEY:
`
` Q Yeah. Absolutely.
`
` So layer -- you believe that --
`
` withdrawn.
`
` Do you believe that magnetic layer
`
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`Exhibit 2018
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` 171H is merely a subset of what Suzuki
`
` describes as layer 171?
`
` A I think that could be, that 171
`
` could be made up of 171H and 171L. That could
`
` be an example and I think in that case, the
`
` answer -- for that example I think the answer
`
` would be yes.
`
` Q What are some other examples of
`
` ways that you could implement 171H and 171L
`
` where they would not be subsets of layer 171?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: So I don't think I
`
` considered that specifically. If there's some
`
` other way that those sheets would somehow not
`
` be part of 171. So, you know, sitting --
`
` sitting here, I'm thinking of it as being
`
` sheets that are, you know, somehow comprise
`
` 171 in some way to make that coil block.
`
` BY MR. MILKEY:
`
` Q Okay. And does Suzuki's magnetic
`
` layer 171 constitute a functional magnetic
`
` sheet?
`
` A And it's okay for me to search my
`
` electronic copy my declaration; is that right?
`
` Q That's correct.
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
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` A Okay. So if I recall your
`
` question it's, do the two sheets, 171H and L,
`
` can they be combined to -- in Suzuki to create
`
` a functional magnetic sheet?
`
` Q That's correct.
`
` A I'm not sure if you're asking
`
` about some specific meaning of functional, but
`
` that makes sense to me, that it would be a
`
` functional magnetic sheet because it would be
`
` able to guide flux.
`
` Q Okay. Are you aware of any
`
` drawbacks to implementing Suzuki's magnetic
`
` layer 171 as two magnetic layers, 171H and
`
` 171L?
`
` A I think it would all essentially
`
` be a hypothetical kind of situation, you know,
`
` if there were issues of cost or complexity,
`
` but -- but overall, I don't think that
`
` laminated magnetics poses really any kind of
`
` insurmountable challenge. You know, if there
`
` are challenges, they're things that can be
`
` overcome, mitigated.
`
` Q Okay. Could you turn to Suzuki,
`
` which is Exhibit 1005, at Column 8, line 50.
`
` A Okay. I'm there.
`
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` Q Okay. And do you see the sentence
`
` that says, "The magnetic layer 171 is also
`
` formed of the magnetic material, and the
`
` adhesive or pressure-sensitive adhesive"?
`
` A Okay. So I was starting at -- oh,
`
` I see. At 51, line 51 in Column 8.
`
` Q Yes.
`
` A Yes, I see that.
`
` Q Would implementing magnetic layer
`
` 171 as two layers, 171H and 171L, implicate or
`
` prevent -- strike that.
`
` Would implementing magnetic layer
`
` 171 as two layers, 171H and 171L, hinder or
`
` prevent the implementation described here
`
` where magnetic layer 171 is formed of the
`
` magnetic material and the adhesive or
`
` pressure-sensitive adhesive?
`
` A I don't think it would prevent
`
` that. I don't think it would prevent
`
` implementing magnetic layer 171 as two sheets,
`
` given that embodiment.
`
` Q Okay. So in your proposed
`
` combination of Suzuki's Figure 3 with layers
`
` 171H and 171L, could those layers be formed of
`
` the magnetic material and the adhesive or
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
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` pressure-sensitive adhesive?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: So I just, sort of
`
` as a preliminary thing, I disagree with how
`
` you've posed that question about my
`
` combination of 171H and L with Figure 3
`
` because I think that those are already
`
` implicated within the design depicted in
`
` Figure 3.
`
` So -- but -- so I just would say
`
` that. And I don't know if you could -- if you
`
` could rephrase.
`
` BY MR. MILKEY:
`
` Q Okay. So, yeah, let's -- that's
`
` a -- thank you for raising that.
`
` So is it your opinion that when
`
` Suzuki is talking about layer 171, it's
`
` implicitly talking about 171H and 171L?
`
` A I think that's -- that's a sort of
`
` fair way to put it, that it can include
`
` multisheet structure for 171, and that's --
`
` that's already one of the possibilities for
`
` 171 as shown in Figure 3.
`
` Q Are there any teachings in Suzuki
`
` regarding layer 171 that you believe would
`
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`APPLE V. SCRAMOGE
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`Exhibit 2018
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` preclude a two-layer implementation?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: And you ask this:
`
` Are there any teachings about 171 that would
`
` preclude? Did I hear that right?
`
` BY MR. MILKEY:
`
` Q That's correct.
`
` A I guess what I'd answer is that
`
` no, like, there's nothing that would prevent
`
` that secondary side from being implemented as
`
` a two-sheet or multisheet structure.
`
` Q Okay. So we were talking a little
`
` bit ago about Suzuki starting -- it's the last
`
` paragraph -- sorry -- the last sentence in the
`
` paragraph in Column 8 around lines 50 to 53.
`
` Do you see that?
`
` A Yes.
`
` Q Okay. And there, the magnetic
`
` layer is formed of the magnetic material and
`
` the adhesive or pressure-sensitive adhesive;
`
` is that right?
`
` A Yes.
`
` Q Okay. So in your Ground 1
`
` combination, is the magnetic layer formed of
`
` magnetic material and the adhesive or
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
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` pressure-sensitive adhesive?
`
` A I think it could be.
`
` Q What else could magnetic layer 171
`
` be in your proposed Ground 1 combination?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: So also in column 8
`
` in Suzuki, I cite -- upward in the -- in that
`
` column in my declaration. And so I'm going to
`
` try to find some -- a paragraph in my
`
` declaration.
`
` So one -- one place is
`
` paragraph 46 of my declaration. There, I'm
`
` citing around 8 -- Column 8, line 8, talking
`
` about sticking together collectively by
`
` pressing in the -- that the pressure-sensitive
`
` adhesive can be used to accomplish that, and
`
` if you look at that part of Column 8 in
`
` Suzuki, it's saying that some of these things
`
` that can be stuck together are magnetic layers
`
` 171, formed into one of the shapes shown in
`
` Figure 6A to 6E.
`
` BY MR. MILKEY:
`
` Q Okay. And -- actually, let's talk
`
` about the specific combination you make with
`
` Suzuki and Lee.
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
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` A I didn't quite hear that.
`
` Q Yeah. Understood.
`
` Let's move on to the specific
`
` combination with Suzuki and Lee. I'm not
`
` intending to limit the question to this
`
` paragraph, but I'll direct you to paragraph 42
`
` of your declaration --
`
` A Yes.
`
` Q -- just as an orientation for this
`
` question.
`
` A Okay.
`
` Q So what modifications to Suzuki,
`
` in view of Lee, are you proposing for your
`
` Ground 1 combination?
`
` A So as you can see, after 42 I have
`
` two other subheadings. And one's called A,
`
` and that addresses the adhesive layer. And
`
` then another is called B, which is down all
`
` the way at -- above paragraph 48, which
`
` includes the NFC coil.
`
` And in both of those I'm -- just
`
` to be general about this, I'm saying that
`
` Suzuki doesn't really provide implementation
`
` details, and so a person of ordinary skill
`
` would naturally look to references that do
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`APPLE V. SCRAMOGE
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`Exhibit 2018
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` provide additional detail. So that's
`
` something I make -- a point I make, for
`
` instance, for the -- regarding the adhesive in
`
` paragraph 43, and then similarly for the --
`
` you know, later for the NFC coil.
`
` But my point is that in a way I'm
`
` not really modifying Suzuki. I'm making a
`
` point that Suzuki chooses to omit certain
`
` implementation details that then a person of
`
` ordinary skill can find with greater
`
` specificity elsewhere.
`
` Q Okay. So in your view, are any
`
` modifications to Suzuki necessary in order to
`
` achieve your Ground 1 proposal?
`
` A In a way, the answer is no,
`
` because the specific implementation of that
`
` adhesive is something that, you know, is shown
`
` in Lee, whereas it's described generally in
`
` Suzuki.
`
` So I don't think there's a need
`
` to -- to really make modifications to
`
` what's -- what Suzuki includes within its
`
` embodiments.
`
` Q Okay. I'm putting in the chat
`
` Exhibit 1006, which is the Lee reference, and
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
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` you have access to this, right, Dr. Phinney?
`
` A Yes. I'm using yours from the
`
` chat.
`
` Q Okay. So if we could turn in your
`
` declaration to paragraph 46.
`
` A Okay. I'm there.
`
` Q And towards the end of that
`
` paragraph you state that implementing Suzuki's
`
` adhesive layer as a pressure-sensitive
`
` double-sided tape and configuring it as needed
`
` to align with Suzuki's manufacturing goals
`
` would thus have been well within the skill of
`
` a person of ordinary skill in the art in 2014.
`
` Do you see that?
`
` A Yes.
`
` Q So how -- how would you go about
`
` configuring these double-sided tapes to align
`
` with Suzuki's manufacturing goals?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: I think it could
`
` depend on what particular type of
`
` manufacturing method was being used and what
`
` components were being used.
`
` BY MR. MILKEY:
`
` Q Suzuki gives some examples of
`
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` manufacturing methods for its magnetic layer
`
`Page 26
`
` 171; is that right?
`
` A Yes.
`
` Q And Suzuki also gives some
`
` examples of materials to be used for its
`
` magnetic layer 171; is that right?
`
` A Yes, I'd agree with that.
`
` Q Okay. So take your pick of
`
` manufacturing method and material used for
`
` Suzuki's layer 171. For any combination of
`
` that that you want, how would you go about
`
` configuring Lee's double-sided tape to align
`
` with Suzuki's manufacturing goals?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: Well, to describe
`
` one, generally, would be where there's
`
` pressing, in pressing used to form a coil
`
` block 171. And in that case, a magnetic sheet
`
` 171H, I believe it is, could be -- could be
`
` formed from a more viscous material. And if
`
` you let me first just make sure I got the
`
` right designator there.
`
` Yes, 171H. I'm sorry. I was
`
` looking for my annotated figure.
`
` ///
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
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` BY MR. MILKEY:
`
` Q Understood. And so how would you
`
` configure Lee's double-sided tape to align
`
` with Suzuki's manufacturing goals in that
`
` scenario?
`
` A Well, Lee describes how it can
`
` form an interface with a magnetic material
`
` that can be, you know, flaked or otherwise
`
` composed of little particulate pieces, but --
`
` and if now using a pressing method, the coil
`
` needs to be pressed into the -- into the layer
`
` 171H to accommodate the coil but also stick to
`
` the coil.
`
` So by choosing the correct
`
` viscosity of 171H and putting an intervening
`
` layer of double-sided tape that can adhere to
`
` that -- you know, get in the interstices of
`
` the magnetic material if necessary and then
`
` put a coil on top of that on the other side of
`
` this double-sided tape, and now pressing that
`
` into a final coil block. That would be an
`
` example.
`
` Q Sir, can you go to page 43 of your
`
` declaration.
`
` A Page 43?
`
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` Q Yeah.
`
` A Okay. I'm there.
`
` Q And there's another annotation of
`
` Suzuki Figure 3 there; is that right?
`
` A Yes. It's like a -- yes, there
`
` is.
`
` Q And in this scenario, does the
`
` adhesive extend the entire width of magnetic
`
` sheet 171H?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: The -- I think
`
` you're asking about the extent of the purple
`
` line, and I've shown it here around the
`
` conductors of the coil. So I think the answer
`
` is -- if I've understood you right, it's -- I
`
` think I'm not showing it going that whole
`
` width.
`
` BY MR. MILKEY:
`
` Q Okay. So Lee's double-sided tape
`
` is shown on an annotated figure on page 19 of
`
` your declaration; is that right?
`
` A Yes.
`
` Q Okay. And that double-sided tape
`
` includes a PET film 32 and then adhesive
`
` layers 31 and 33; is that right?
`
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`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
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` A Yeah, I think that's -- that's
`
` accurate. The PET is an example of the base
`
` member that also be a -- a fluorine
`
` resin-based film.
`
` Q And what are the specific
`
` adhesives that Lee uses for adhesive layers 31
`
` and 33?
`
` A I'm going to have to search. I
`
` don't -- I don't recall citing anything
`
` specific about what adhesives were used or
`
` disclosed in Lee. I don't know if you're
`
` thinking of a particular place, because
`
` otherwise I'm just searching Lee at this
`
` point.
`
` Q I'm not actually aware if Lee
`
` discloses that. Do you have an opinion as to
`
` whether Lee discloses what adhesive layers 31
`
` and 33 are made of?
`
` A What I do know is that the
`
` performance of the adhesive for gap filling,
`
` when it's adjacent to gaps that were
`
` intentionally formed in the microscopic
`
` structure of an adjacent magnetic film that's
`
` described, you know, how high it needs to be
`
` and some of the heat that may need to be
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE V. SCRAMOGE
`IPR2022-00120
`Exhibit 2018
`
`
`
`Page 30
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
`
` subjected to. That's the kind of thing I
`
` recall, that's like sort of performance and
`
` build-related information about the adhesive.
`
` But I just -- I don't -- I'm not
`
` sure that it talked about chemically what that
`
` adhesive should be. I'm still looking.
`
` Oh, here. This is an example.
`
` Paragraph -- sorry -- Column 9, line 50. The
`
` first and third adhesives can include our
`
` layers 31 and 33, may be implemented by using,
`
` for example, acrylic adhesives, but may be of
`
` course possibly implemented by using different
`
` types of adhesives, as illustrated in
`
` Figure 2.
`
`
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