UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
`
`APPLE INC,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00120
`U.S. Patent No. 9,997,962
`_____________________
`
`DECLARATION OF DR. JOSHUA PHINNEY,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
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`Phinney Declaration
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`Inter Partes Review of U.S. 9,997,962
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 4
`I.
`Qualifications and Professional Experience .................................................... 6
`II.
`III. Level of Ordinary Skill in the Art ................................................................... 9
`IV. Relevant Legal Standards .............................................................................. 10
`V.
`Background .................................................................................................... 13
`VI. Overview of the ’962 Patent .......................................................................... 13
`VII. Claim Construction ........................................................................................ 16
`VIII. Identification of how the Claims are Unpatentable ....................................... 16
`A. Ground 1: Claims 1, 18, and 19 are obvious under 35 U.S.C.
`§ 103(a) over Suzuki and Lee. ............................................................ 17
`1.
`Summary of Suzuki ....................................................... 17
`2.
`Summary of Lee............................................................. 18
`3.
`Reasons to Combine Suzuki and Lee ............................ 20
`a)
`Implementing Suzuki’s Adhesive Layer Using Double-
`sided Tape ...................................................................... 21
`Implementing Suzuki’s Device with an NFC Coil ........ 25
`b)
`Claim 1 ........................................................................... 29
`4.
`Claim 18 ......................................................................... 44
`5.
`Claim 19 ......................................................................... 48
`6.
`Ground 2: Claims 2-4 and 7 are obvious under 35 U.S.C.
`§ 103(a) over Suzuki, Lee, and Sawa. ................................................. 51
`1.
`Summary of Sawa .......................................................... 51
`2.
`Reasons to Combine Sawa with Suzuki and Lee .......... 51
`
`B.
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`Inter Partes Review of U.S. 9,997,962
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`C.
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`Claim 2 ........................................................................... 54
`3.
`Claim 3 ........................................................................... 56
`4.
`Claim 4 ........................................................................... 58
`5.
`Claim 7 ........................................................................... 58
`6.
`Ground 3: Claim 8 is obvious under 35 U.S.C. § 103(a) over
`Suzuki, Lee, Sawa, and Park. .............................................................. 59
`1.
`Summary of Park ........................................................... 60
`2.
`Reasons to Combine Park with Suzuki, and Lee ........... 62
`3.
`Claim 8 ........................................................................... 64
`IX. Conclusion ..................................................................................................... 69
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`Phinney Declaration
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`I, Joshua Phinney, do hereby declare as follows:
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`I.
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`INTRODUCTION
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`Inter Partes Review of U.S. 9,997,962
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`1.
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`I am making this declaration at the request of Apple Inc. in the matter
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`of the Inter Partes Review of U.S. Patent No. 9,997,962 (“the ’962 Patent”) to Bae
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`et al.
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`2.
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`I am being compensated for my work in this matter at my standard
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`hourly rate. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the outcome of this matter or the specifics of my testimony.
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`3.
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`I have been asked to provide my opinions regarding whether claims 1-
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`4, 7-8, and 18-19 (“the Challenged Claims”) of the ’962 Patent are unpatentable as
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`they would have been obvious to a person having ordinary skill in the art
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`(“POSITA”) at the time of the alleged invention, in light of the prior art. It is my
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`opinion that all of the limitations of the challenged claims would have been
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`obvious to a POSITA.
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`In the preparation of this declaration, I have studied:
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`the ’962 Patent, Ex.1001;
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`the prosecution history of the ’962 Patent (“’962 File History”),
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`4.
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`a.
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`b.
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`Ex.1002;
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`c.
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`U.S. Patent No. 8,421,574 to Suzuki et al. (“Suzuki”), Ex.1005; and
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`Inter Partes Review of U.S. 9,997,962
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`d.
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`e.
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`f.
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`g.
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`h.
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`i.
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`j.
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`k.
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`l.
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`U.S. Patent No. 9,252,611 to Lee (“Lee”), Ex.1006.
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`U.S. Patent No. 8,922,162 to Park (“Park”), Ex.1007;
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`U.S. Patent No. 9,443,648 to Sawa (“Sawa”), Ex.1008;
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`U.S. Patent Application Pub. No. 2014/0315016, Ex.1009;
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`U.S. Patent No. 8,427,100, Ex.1010;
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`U.S. Patent No. 8,687,536, Ex.1011;
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`U.S. Patent No. 7,161,650, Ex.1012;
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`U.S. Patent No. 9,360,456, Ex.1013;
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`U.S. Patent No. 9,667,086, Ex.1014;
`
`m. U.S. Patent No. 9,306,411, Ex.1017; and
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`n. Websters II New College Dictionary: Third Edition, (2005), Ex.1018.
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`5.
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`In forming the opinions expressed below, I have considered:
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`the documents listed above;
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`the relevant legal standards, including the standard for obviousness,
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`and any additional authoritative documents as cited in the body of this
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`declaration; and my own knowledge and experience based upon my work in
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`the field of networking as described below.
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`6.
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`Unless otherwise noted, emphasis in quoted material has been added.
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`Claim terms are presented in italics. Any citations are to exhibits’ original page
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`numbers.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`7. My complete qualifications and professional experience are described
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`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
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`following is a brief summary of my relevant qualifications and professional
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`experience.
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`8.
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`I am a Principal Engineer in the Electrical Engineering and Computer
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`Science practice at Exponent, an engineering and scientific consulting firm
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`headquartered at 149 Commonwealth Drive, Menlo Park, California 94025. I
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`received a Ph.D. in Electrical Engineering from the Massachusetts Institute of
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`Technology (“MIT”) in 2005. I also earned S.M. and B.S. degrees in Electrical
`
`Engineering from MIT and the University of Illinois, Chicago (“UIC”),
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`respectively.
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`9. My master’s thesis at MIT focused on the miniaturization of power
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`converters, by reducing the energy storage and improving the performance of
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`inductors. As part of this work, I designed, tested, and constructed ferrite, iron-
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`powder, and air-core inductors, while minimizing magnetic losses. During this
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`time, I invented with my advisor, Dr. David Perreault, an electrical component
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`with a capacitive impedance and an inductance-cancellation feature provided by
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`magnetically coupled windings. A filter having a capacitor with inductance
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`cancellation provides enhanced performance over frequency compared with
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`conventional capacitors. This work was later extended to a second patent, with
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`magnetically coupled windings used to improve EMI filters and common-mode
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`chokes.
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`10. My doctoral work at MIT centered on miniaturization of power
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`converters and magnetics. As part of my doctoral work, I constructed and modeled
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`planar magnetic systems, including magnetically coupled, printed magnetic coils.
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`By incorporating such compact, magnetic structures into power converters, the
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`resulting converter enjoyed multiple benefits, including waveform-shaping and
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`reduction of switch stresses. Through the modeling associated with this
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`dissertation, I become proficient in methods for analyzing the inductances of
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`packages and interconnects, especially planar or filamentous systems of
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`conductors.
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`11.
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` For my publications related to both my Master’s and Ph.D. thesis, I
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`received the William M. Portnoy Prize Paper Award (2003) and the IEEE Power
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`Electronics Society Transactions Prize Paper Award (2004).
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`12. After earning my Ph.D., I joined Exponent and have led technical
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`investigations to portable electronic devices, microcomputers, as well as industrial
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`and consumer devices with embedded controllers. My job functions include
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`analyzing hardware and software of these devices to understand their modes of
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`failure, and testifying regarding these devices in legal matters involving patents
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`and trade secrets.
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`13. As part of my employment at Exponent, I have performed design,
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`design reviews, and failure analysis for wireless charging and communication
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`systems. The focus of this work has been (1) coupling between transmitter and
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`receiver coils from the standpoint of efficiency and magnetic-field exposure to
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`users, in particular for the Power Matters Alliance; (2) coupling of interrogators
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`and transponder coils in printed magnetic cards; and (3) integrated-circuit and coil
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`failures due to wear, dimensional changes, and triboelectric charging. In addition
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`to testifying regarding resonant and inductive wireless-power transfer, I have
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`consulted for industry regarding coil design, RFID and near-field communication
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`(NFC) integrated circuits, modulation methods, and on-metal RFID tags.
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`14.
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`I have testified regarding the software-defined features, internal
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`circuitry, and physical embodiments of electronic equipment. Regarding
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`electronics, I have testified regarding power electronics in communication systems,
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`wind turbines, grid-scale photovoltaic plants, and consumer electronics. In
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`addition, I have testified regarding control and compensation in industrial
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`controllers, voltage regulators, and switched-mode power converters. My
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`experience with wireless RF circuitry includes failure analysis of amplifiers, power
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`supplies, matching networks, and multiplexers in satellites, semiconductor-
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`processing equipment, and medical devices.
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`15. Regarding the mechanical elements of electronic equipment, I have
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`testified regarding buttons and touch interfaces, connectors, linear and rotary
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`actuators, position-measuring devices, and the design and construction of modular
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`housings for computerized equipment and peripherals. In particular, I have
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`
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`testified regarding detachable components as they are constructed in relation to the
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`housing and underlying electronic assemblies, including printed circuit boards, flex
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`printed circuits, and other connector assemblies within the housing of electronic
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`equipment.
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`16.
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`In addition to the forgoing, I perform electromagnetic assessment of
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`utility and communication infrastructure. These issues include permitting,
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`interference, and environmental impact of radar, AC and HVDC transmission
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`lines, substations, photovoltaic installations, generators, broadcast antennas, and
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`electrified mass transit systems.
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`17.
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`I am being compensated for my work associated with this case plus
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`reimbursement of reasonable expenses. My compensation is not contingent on my
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`opinions or the outcome of the case, and I have no other interest in this case or the
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`parties thereto.
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`18.
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`I understand there are multiple factors relevant to determining the
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`level of ordinary skill in the pertinent art, including (1) the levels of education and
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`experience of persons working in the field at the time of the invention; (2) the
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`sophistication of the technology; (3) the types of problems encountered in the field;
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`and (4) the prior art solutions to those problems.
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`19. A person of ordinary skill in the art (“POSITA”) in the field of the
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`’962 Patent, as of its earliest possible filing date of June 27, 2013, would have been
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`someone knowledgeable and familiar with the wireless charging arts that are
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`pertinent to the ’962 Patent. That person would have a bachelor’s degree in
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`electrical engineering, or equivalent training, and approximately two years of
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`experience working in the electrical engineering field. Lack of work experience
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`can be remedied by additional education, and vice versa.
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`20. For purposes of this Declaration, in general, and unless otherwise
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`noted, my statements and opinions, such as those regarding my experience and the
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`understanding of a POSITA generally (and specifically related to the references I
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`consulted herein), reflect the knowledge that existed in the field as of the alleged
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`priority date of the ’962 Patent (i.e., June 27, 2013). Unless otherwise stated, when
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`I provide my understanding and analysis below, it is consistent with the level of a
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`POSITA prior to the alleged priority date of the ’962 Patent.
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`IV. RELEVANT LEGAL STANDARDS
`21.
`
`I am not an attorney. In preparing and expressing my opinions and
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`considering the subject matter of the ’962 Patent, I am relying on certain basic
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`legal principles that counsel have explained to me. These principles are discussed
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`below.
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`22.
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`I understand that prior art to the ’962 Patent includes patents and
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`printed publications in the relevant art that predate the alleged priority date of the
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`alleged invention recited in the ’962 Patent. For purposes of this Declaration, I am
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`applying June 27, 2013 as the earliest possible priority date of the ’962 Patent.
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`23.
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`I have been informed that a claimed invention is unpatentable under
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`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person having ordinary skill in the art to which the subject
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`matter pertains. I have also been informed by counsel that the obviousness analysis
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`takes into account factual inquiries including the level of ordinary skill in the art,
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`the scope and content of the prior art, and the differences between the prior art and
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`the claimed subject matter.
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`24.
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`I have been informed by counsel that the Supreme Court has
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`recognized several rationales for combining references or modifying a reference to
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`show obviousness of claimed subject matter. Some of these rationales include the
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`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
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`obtain predictable results; (c) use of a known technique to improve a similar device
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`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
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`in the prior art that would have led one of ordinary skill to modify the prior art
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`reference or to combine prior art reference teachings to arrive at the claimed
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`invention.
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`25.
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`I further understand that certain factors may support or rebut the
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`obviousness of a claim. I understand that such secondary considerations include,
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`among other things, commercial success of the patented invention, skepticism of
`
`those having ordinary skill in the art at the time of invention, unexpected results of
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`the invention, any long-felt but unsolved need in the art that was satisfied by the
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`alleged invention, the failure of others to make the alleged invention, praise of the
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`alleged invention by those having ordinary skill in the art, and copying of the
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`alleged invention by others in the field. I understand that there must be a nexus—a
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`connection—between any such secondary considerations and the alleged invention.
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`I also understand that contemporaneous and independent invention by others is a
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`secondary consideration tending to show obviousness.
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`26.
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`I am not aware of any allegations by the named inventor of the ’962
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`Patent or any assignee of the ’962 Patent that any secondary considerations are
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`relevant to the obviousness analysis of any Challenged Claim of the ’962 Patent.
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`V. BACKGROUND
`27. Mobile devices such as smart phones provide users with a wide
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`variety of communication mechanisms such as phone calls, text messages, internet
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`access, as well as providing other features. Mobile devices typically include a
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`built-in or detachable battery pack that is chargeable. Some types of devices may
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`be charged wirelessly using principles of electromagnetic induction. Specifically, a
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`coil on the charger is inductively coupled with a coil in a phone or other wirelessly
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`chargeable device. It was well known that to improve power transfer efficiency,
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`the coils in both the power transmitting device and power receiving device should
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`be placed adjacent to a magnetic sheet. As will be described in more detail below,
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`the ’962 Patent describes and claims no more than what was already known in the
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`art with regard to such magnetic sheets.
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`VI. OVERVIEW OF THE ’962 PATENT
`28. The ’962 patent generally relates to “a receiving antenna for wireless
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`charging and a wireless power receiving device including the same.” ’962 Patent,
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`1:18-20. The ’962 patent explains that the receiving antenna “includes a substrate,
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`a soft magnetic layer stacked on the substrate, and a receiving coil configured to
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`receive electromagnetic energy.” ‘962 Patent, Abstract. According to the ’962
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`patent, disposing “a soft magnetic material” around “the receiving antenna” helps
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`“focus the electromagnetic energy emitted from the transmission antenna toward
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`
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`the receiving antenna.” ‘962 Patent, 1:46-49. The ’962 patent explains that the
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`receiving coil is “wound in parallel with a plane of the soft magnetic layer and
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`formed inside of the soft magnetic layer.” ‘962 Patent, 2:3-4.
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`29. Fig. 5 of the ’962 Patent illustrates “an adhesive layer 510 … formed
`
`on a soft magnetic layer 500 [and] a receiving coil 520 … formed on the adhesive
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`layer 510,” with “receiving coil 520 … disposed on the upper surface of the soft
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`magnetic layer 500.” ’962 Patent, 6:11-30. “The receiving coil 520 may be
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`embedded inside of the soft magnetic layer 500.” ’962 Patent, 6:30-31. I note that
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`the ’962 Patent claims this embedding concept as “a height of a highest position of
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`the second magnetic sheet from the substrate is higher than a height of a lowest
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`position of the receiving coil from the substrate.” ’962 Patent, claim 1. Fig. 5 of the
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`’962 Patent is shown below.
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`highest position of
`the second magnetic
`sheet
`
`adhesive
`layer
`
`receiving coil embedded
`in magnetic layer
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`height from
`substrate
`
`lowest portion of the
`receiving coil
`’962 Patent, Fig. 5 (annotated)
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`soft magnetic
`layer
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`30. The ’962 further describes and claims details about the adhesive layer:
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`“the adhesive layer 510 may include a first adhesive layer 512, an insulating layer
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`514 formed [on] the first adhesive layer 512, and a second adhesive layer 516
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`formed on the insulating layer.” ’962 Patent, 6:42-45. One example of the
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`insulating layer is “polyethylene terephthalate (PET) material.” ’962 Patent, 6:47. I
`
`note that the ’962 specification refers to the multi-layer adhesive as “double-
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`sided.” Ex.1001, 6:37-38. This double-sided tape configuration of the adhesive
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`layer is illustrated in Fig. 6, which I have annotated below.
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`second adhesive layer
`
`adhesive
`layer
`
`insulating layer
`
`first adhesive
`layer
`’962 Patent, Fig. 6 (annotated).
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`31. The ’962 Patent was allowed after the applicant added limitations to
`
`the claims related to embedding the coil into the magnetic layer, as well as the
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`limitations related to the double-sided tape configuration. See ’962 Patent File
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`History, 22-23, 47-48. As I explain below, these concepts were not new when the
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`’962 Patent was filed.
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`VII. CLAIM CONSTRUCTION
`32.
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`It is my understanding that in order to properly evaluate the ’962
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`Patent, the terms of the claims must first be interpreted. It is my understanding that
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`for the purposes of this inter partes review, the claims are to be construed under
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`the so-called Phillips standard, under which claim terms are given their ordinary
`
`and customary meaning as would be understood by one of ordinary skill in the art
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`in light of the specification and prosecution history, unless the inventor has set
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`forth a special meaning for a term.
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`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`33.
`
`I have been asked to provide my opinion as to whether the Challenged
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`Claims of the ’962 Patent would have been obvious in view of the prior art. The
`
`discussion below provides a detailed analysis of how the prior art references
`
`identified below teach the limitations of the Challenged Claims of the ’962 Patent.
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`34. As part of my analysis, I have considered the scope and content of the
`
`prior art and any differences between the alleged invention and the prior art. I
`
`describe in detail below the scope and content of the prior art, as well as any
`
`differences between the alleged invention and the prior art, on an element-by-
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`element basis for each Challenged Claims of the ’962 Patent.
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`35. As described in detail below, the alleged invention of the Challenged
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`Claims would have been obvious in view of the teachings of the identified prior art
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`references as well as the knowledge of a POSITA.
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`A. Ground 1: Claims 1, 18, and 19 are obvious under 35 U.S.C.
`§ 103(a) over Suzuki and Lee.
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`Summary of Suzuki
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`1.
`36. Suzuki describes a “contactless power transmission apparatus.”
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`Suzuki, Abstract, 4:49-50. Like the ’962 Patent, Suzuki describes a coil 170
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`embedded in a magnetic layer, as shown in Fig. 3 below. Note that, for the sake of
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`presenting a consistent orientation with the receiver described in the ’962 Patent, I
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`have flipped Suzuki’s Fig. 3 180 degrees (upside down) throughout this
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`declaration. Specifically, the ’962 patent describes its power receiver with the
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`assumption the associated transmitter is “above” the receiver, whereas Suzuki
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`describes its power receiver with the assumption the associated transmitter is
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`“below” the receiver. For readability, I similarly flipped the reference numerals.
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`coil
`
`magnetic
`layer
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`Suzuki, Fig. 3 (flipped, annotated).
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`37. Suzuki explains that its apparatus includes a “secondary coil block
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`17” that includes “a magnetic layer 171, a shield layer 172 for shielding
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`electromagnetic noise, and a heat insulation layer 173, which together are unified
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`with the secondary coil 170.” Suzuki, 6:29-33. In one example, the magnetic
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`layer 171 is made of “soft magnetic material made of crystalline metal material or
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`non-crystalline metal material.” Suzuki, 10:8-10. “[T]he secondary coil 170 is a
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`planar coil and the magnetic layer 171 is laminated on at least one side … of the
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`secondary coil 170.” Suzuki, 6:33-35. The coil 170 embedded in the magnetic
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`layer 171, as shown in Fig. 3, after each of the manufactured layers are pressed
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`together. See Suzuki, 8:66-9:1 (“In each of the manufacturing methods, preferably
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`sticking several thin layers together as stated above is treated collectively by
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`pressing”).
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`38. Suzuki describes various other elements that were common in
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`wireless power receiving antennas. For example, Suzuki describes that laminating
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`the secondary coil and magnetic layer may include using an “adhesive or pressure
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`sensitive adhesive.” Suzuki, 8:8-10. Suzuki describes that the magnetic layer 171
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`may also include “a plurality of magnetic layers” such as “magnetic layers 171H
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`and 171L that are laminated on one side of the secondary coil 170.” Suzuki, 10:65-
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`67, 11:12-14.
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`Summary of Lee
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`2.
`39. Like Suzuki and the ’962 Patent, Lee describes a “magnetic field
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`shield sheet for a wireless charger.” Lee, abstract. In particular, Lee describes
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`using “a double-sided tape 30b” to attach “a receiving-side secondary coil 6 of the
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`wireless charger” to “a magnetic field shield sheet 10.” Lee, 16:33-36. Lee
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`explains that the double-sided tape includes “a base member 32 made of a fluorine
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`resin-based film,” and “second and third adhesive layers 31 and 33.” Lee, 9:29-33.
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`The resin-based film 32 may be “for example, a PET (Polyethylene Terephthalate)
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`film.” Lee, 9:31. Lee’s double-sided tape is shown in Fig. 5 below, along with Fig.
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`6 of the ’962 Patent for comparison purposes.
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`adhesive
`layer
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`PET film
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`second adhesive
`layer
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`Lee, Fig. 5 (annotated).
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`first adhesive
`layer
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`second adhesive layer
`insulating layer
`adhesive
`layer
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`first adhesive
`layer
`’962 Patent, Fig. 6 (annotated).
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`40. Also like the ’962 Patent, Lee teaches a near-field communication
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`(NFC) coil surrounding the wireless charger coil. A “dual antenna 40 is
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`configured to include, for example, a NFC antenna coil 41 and a wireless charger
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`antenna coil 43 that are formed together on a substrate 49.” Lee, 17:42-45. Lee’s
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`NFC coil, along with the NFC coil of the ’962 Patent, is shown below.
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`wireless power
`receiving coil
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`NFC coil
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`wireless power
`receiving coil
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`NFC coil
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`Lee, Fig. 18 (annotated)
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`’962 Patent, Fig. 3 (annotated)
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`41. Accordingly, Lee provides additional evidence that various elements,
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`such as multi-layer adhesives and NFC coils, were well known in the wireless
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`charging space.
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`3.
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`Reasons to Combine Suzuki and Lee
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`42.
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`It is my opinion that a POSITA would have been motivated to
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`combine the teachings of Suzuki and Lee, which are both directed to wireless
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`charging. In particular, before the ’962 Patent, it would have been obvious,
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`beneficial, and predictable to implement Suzuki’s adhesive layer as double-sided
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`tape, as taught by Lee. A POSITA would have further found it obvious, beneficial,
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`and predictable for Suzuki’s device to include an NFC coil as taught by Lee.
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`Implementing Suzuki’s Adhesive Layer Using
`a)
`Double-sided Tape
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`43.
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`It is my opinion that when considering the teachings of Suzuki a
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`POSITA would have also considered the teachings of Lee. Specifically, in
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`describing the general features and functionality of its contactless power
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`transmission apparatus, Suzuki chooses to omit implementation details that were
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`known to POSITAs—for example, details related to the specific adhesive used to
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`adhere the secondary coil to the magnetic layer. Suzuki, 8:8-10. Suzuki merely
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`states the “secondary coil 170 is then stuck on the other side (a lower surface) of
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`the magnetic layer 171 with adhesive or pressure sensitive adhesive.” Suzuki, 8:8-
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`10. Accordingly, when considering the description of the adhesive in Suzuki, a
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`POSITA would have naturally considered other literature more fully describing
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`known adhesives intended for use in wireless charging applications. Lee, for
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`example, describes a known adhesive for such applications. In particular, Lee
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`describes using “a double-sided tape 30b” to attach “a receiving-side secondary
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`coil 6 of the wireless charger” to “a magnetic field shield sheet 10.” Lee, 16:33-36.
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`Lee’s adhesive layer includes “a base member 32 made of a fluorine resin-based
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`film,” and “second and third adhesive layers 31 and 33.” Ex.1006, 9:29-33. The
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`resin-based film 32 may be “for example, a PET (Polyethylene Terephthalate)
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`film.” Ex.1006, 9:31. Accordingly, when considering the description of the
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`adhesive in Suzuki, a POSITA would have naturally considered Lee, as it more
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`fully describes known adhesives intended for use in adhering a power-receiving
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`coil to a magnetic layer.
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`44. A POSITA would have found it obvious to specifically implement
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`Suzuki’s adhesive as a double-sided tape because it was common in the wireless
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`power art to utilize double-sided tape to adhere a power-receiving coil to a
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`magnetic layer. For example, beyond Lee, patent literature contains many
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`examples of utilizing double-sided tape in this manner:
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`• U.S. Patent No. 9,360,456: “[T]he receiver coil L2 may be disposed and
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`affixed on top of the magnetic shielding material 41 using double-sided
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`adhesive tape with adhesive applied on both sides thereof.” Ex.1013, 22:19-
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`26.
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`• U.S. Patent No. 9,667,086: “An insulative double-faced tape or adhesive or
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`the like is used … to adhere the upper face of first magnetic sheet 44 and the
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`lower face of the charging coil 41….” Ex.1014, 5:44-48.
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`• U.S. Patent No. 9,306,411: This patent describes and illustrates a protective
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`layer of “double-sided tape” between a magnetic sheet and a coil. Ex.1017,
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`25:21-25, 26:15-26, Fig. 13.
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`Therefore, a POSITA would have found it obvious to utilize a common type of
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`adhesive (i.e., double-sided tape) in the manner commonly found in the art (i.e.,
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`to adhere a coil to a magnetic layer).
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`45. A POSITA would have also found the combination straightforward
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`and predictable given that the combination utilizes Lee’s multi-layer adhesive
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`precisely as it was intended—for attaching a power-receiving coil to a magnetic
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`layer. A POSITA would have had a reasonable expectation of success because the
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`combination does not change the intended functionality of either Suzuki’s power
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`receiver or Lee’s adhesive. Lee’s improved adhesive design was specifically
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`intended to be implemented in wireless power receivers ready for improvement,
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`such as Suzuki’s receiver.
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`46. A POSITA would have further had a reasonable expectation of
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`success in using double-sided tape within the context of Suzuki’s manufacturing
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`method. Specifically, Suzuki explains that in its method, the layers are stuck
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`together “collectively by pressing” and that the adhesive may be a “pressure
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`sensitive adhesive.” Suzuki, 8:66-9:1, 8:8-10. It was known in the electronics
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`manufacturing art that double-sided tape may be a pressure sensitive adhesive
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`(PSA). For example, U.S. Patent App. Pub. 2014/0315016 explains that “a
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`pressure-sensitive adhesive tape … may in principle be a double-sided pressure-
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`sensitive adhesive tape.” Ex.1009, [0140]. It was also known that pressure
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`sensitive, double-sided tape may be configured to have a desired thickness
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`depending on the particular application. For example, U.S. Patent App. Pub.
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`2014/0315016 also explains that the “optimum thickness is dependent on the
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`(opto)electronic construction, on the end application, on the nature of the
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`embodiment of the PSA …”. Ex.1009, [0141]-[0142]. “High layer thicknesses …
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`are employed when the aim is to achieve improved adhesion to the substrate and/or
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`a damping effect within the (opto)electronic construction.” Ex.1009, [0141]-
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`[0142]. “Low layer thicknesses … reduce the permeation cross section, and hence
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`the lateral permeation and the overall thickness of the (opto)electronic
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`construction.”