UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________________
`
`PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`Luxshare Precision Industry Co., Ltd.,
`Petitioner,
`
`v.
`
`Amphenol Corp,
`Patent Owner.
`
`_____________________
`
`CASE NO: IPR2022-00132
`U.S. PATENT NO. 10,381,767
`
`_____________________
`
`DECLARATION OF JOSEPH C. MCALEXANDER III IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO.
`10,381,767
`
`LUXSHARE EXHIBIT 1002
`Page 1 of 85
`
`
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`______________________________
`
`PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`Luxshare Precision Industry Co., Ltd.,
`Petitioner,
`
`v.
`
`Amphenol Corp,
`Patent Owner.
`
`_____________________
`
`CASE NO: IPR2022-00132
`U.S. PATENT NO. 10,381,767
`
`_____________________
`
`DECLARATION OF JOSEPH C. MCALEXANDER III IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO.
`10,381,767
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`LUXSHARE EXHIBIT 1002
`Page 1 of 85
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`LIST OF EXHIBITS
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`Exhibit No.
`1001
`
`Description
`U.S. Patent No. 10,381,767 to Milbrand, Jr. et al. (“’767
`Patent”)
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
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`1008
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`1009
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`1010
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`1011
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`Declaration of Joseph C. McAlexander III
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`File History of U.S. Patent No. 10,381,767
`
`CN Utility Model Patent No. 201112782Y to Cai et al. (“Cai”)
`and Certified Translation
`
`U.S. Patent No. 7,494,383 to Cohen et al. (“Cohen”)
`
`Specification for QSFP (Quad Small Formfactor Pluggable)
`Transceiver, Revision 1.0 (“QSFP Standard”)
`
`Specification for SFP (Small Formfactor Pluggable)
`Transceiver, Revision 1.0 (“SFP Standard”)
`
`U.S. Patent Application Publication No. 2002/0192988 A1 to
`Droesbeke et al. (“Droesbeke”)
`
`CV of Joseph C. McAlexander III
`
`Decision Invalidating CN Patent Application No.
`201610952606.4, which issued as CN Utility Model Patent No.
`107069274B, and Certified Translation
`
`In re Certain Electrical Connectors and Cages, Components
`Thereof, and Prods. Containing the Same, Inv. No. 337-TA-
`1241, Order No. 31 (Oct. 19, 2021): Construing Certain Terms
`of the Asserted Claims of the Patents at Issue
`
`
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`I.
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`INTRODUCTION
`1.
`I, Joseph C. McAlexander III, have been retained as an independent
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`technical expert on behalf of Petitioner related to Inter Partes Review (“IPR”) of
`
`U.S. Patent No. 10,381,767 (Ex. 1001, “the ’767 Patent”).
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`2.
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`I am being compensated for my work in this matter at an hourly rate. I
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`am also being reimbursed for reasonable and customary expenses associated with
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`my work and testimony in this matter. My compensation is not contingent on the
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`outcome of this matter or the specifics of my testimony. I have no personal or
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`financial stake or interest in the outcome of the present proceeding.
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`3.
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`The opinions and comments formulated during this assessment are
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`based on observations and information available at the time of the investigation. The
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`findings presented herein are made to a reasonable degree of scientific certainty. I
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`have made every effort to accurately and completely investigate all areas of concern
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`identified during our investigation.
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`II. EXPERIENCE AND QUALIFICATIONS
`4.
`I have a Bachelor of Science in Electrical Engineering from North
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`Carolina State University and have studied neural science at the University of Texas
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`Graduate School of Biomedical Science.
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`5.
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`Upon completion of my electrical engineering degree in 1969, I was
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`commissioned as an officer in the U.S. Army. For 2 years, I managed the air defense
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`operation for
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`the New England area, which
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`included radar and secure
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`communication channels to aircraft, missile batteries, and U.S. Command. I then
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`commanded a signal battalion in South Korea for 1 year, designing and orchestrating
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`at the division level the first of its kind communication power grid mapping study
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`using AM and FM transmission/reception, among others, and utilizing crypto
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`security transmission/reception methods.
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`6.
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`I am a Registered Professional Engineer in the state of Texas (Reg. No.
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`79,454) and am a recognized inventor on thirty-one U.S. patents. I have forty-nine
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`years of professional experience, during which I designed and analyzed a variety of
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`microcircuits, semiconductors, and control systems, inclusive of packaging, board
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`level integration and connector hardware, amongst other technologies, for Texas
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`Instruments, Inc. and EPI Technologies, Inc. Specifically, I have designed Dynamic
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`Random Access Memories (“DRAMs”), Static Random Access Memories
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`(“SRAMs”), Charged Coupled Devices (“CCDs”), Shift Registers (“SRs”), and a
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`variety of functional circuits, including input/output buffers for addresses and data
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`transmission, decoders, clocks, sense amplifiers, fault tolerant parallel-to-serial data
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`paths for video applications, level shifters, converters, pumps, logic devices,
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`wireless communication systems, and microelectromechanical systems (“MEMs”).
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`I possess significant expertise in operations and manufacturing associated with these
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`technologies, including a sophisticated knowledge of quality control, testing,
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`reliability, and failure analyses.
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`7.
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`I have conducted high-level instruction to design and process engineers
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`and managers at Texas Instruments, among others, in Solid State Device Physics,
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`Semiconductor Processing, Circuit Design Techniques, and Statistical Quality
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`Control Methods. I have also instructed corporate audiences in Effectiveness
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`Training, Japanese Manufacturing Techniques, and problem recognition and
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`solution methods and tools.
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`8.
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`As part of licensing of my IP circa 2002–2004, I negotiated and
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`executed a number of licensing and design programs to provide GPS tracking and
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`transmission of information wirelessly, using paging and CDMA. The technologies
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`included partnerships for skier tracking with Snowtrax, offender tracking with
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`Stellar Technology Enterprises, pet tracking with The Procter & Gamble Company,
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`journalist tracking with CNN, asset tracking with TrackDaddy, and family tracking
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`with Disney, to name a few. I also advised a startup between 2013 and 2018 in peer-
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`to-peer encrypted cellular communication. For each of these technologies, signal
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`and voltage/current losses, noise, and cross-talk attributeable to board layout and
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`connector design were continual concerns that had to be addressed with each project.
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`9.
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`I have provided consultancy
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`services associated with
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`the
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`aforementioned technologies.
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` My consulting career began with Cochran
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`Consulting, Inc. in 1991. Currently, I am the President of McAlexander Sound, Inc.
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`and the Managing Director of McAlexander Sound Pte Ltd., where I offer such
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`consultancy services and serve as a Technical Advisor for highly-specialized
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`matters. From 2006–2016, I provided such technical advice to multiple companies
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`that designed and fabricated integrated device packages and system boards.
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`10.
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`I further provide expert witness services for the protection of
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`intellectual property. As an expert witness, I have investigated processes and
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`designs associated with personal computers, peripheral computers, software, and
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`wireless communications systems,
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`including
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`telephones, microprocessors,
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`controllers, memories, programmable logic devices, and other consumer electronics.
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`11. A copy of my curriculum vitae is attached as Appendix A hereto.
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`III. LEGAL STANDARDS
`12.
`I am not an attorney. For purposes of this declaration, I have been
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`informed about certain aspects of the law that are relevant to my analysis and
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`opinions, as set forth below.
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`A. Claim Construction
`13.
`I understand that claim terms are generally given their ordinary and
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`customary meaning, which is the meaning that the term would have to a person of
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`ordinary skill in the art (POSITA) in question at the time of the invention, i.e., as of
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`the earliest priority date of the patent. I further understand that the POSITA is
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`deemed to read the claim term not only in the context of the particular claim in which
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`a claim term appears, but in the context of the entire patent, including the
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`specification and file history.
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`14.
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`I am informed by counsel that the patent specification has been
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`described as the best guide to determining the meaning of a claim term, and is, thus,
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`highly relevant to the interpretation of claim terms. I understand for claim terms that
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`do not have a customary meaning within the art, the specification usually supplies
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`the best context of understanding the meaning of those terms. I also understand that
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`claim terms should be understood in the context of the claim as a whole.
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`15.
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`I understand that the prosecution history can further inform the meaning
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`of the claim language by demonstrating how the inventors understood the invention
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`and whether the inventors limited the invention in the course of prosecution, making
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`the claim scope narrower than it otherwise would be. Extrinsic evidence may also
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`be consulted in construing the claim terms, such as my experience and expert
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`testimony.
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`16.
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`I have not been asked to provide any specific definitions for any of the
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`terms in the claims I have analyzed. If asked, I would undertake such an endeavor.
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`Accordingly, I have treated each claim term as it would be understood to have its
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`plain and ordinary meaning to a POSITA in light of the specification, as outlined
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`below.
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`17.
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`I understand that some claims are independent, and that these claims
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`are complete by themselves. Other claims refer to these independent claims and are
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`“dependent” from those independent claims. The dependent claims include all the
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`limitations of the claims from which they depend.
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`B. Obviousness
`18.
`I am informed that a patent cannot be properly granted for subject
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`matter that would have been obvious to a POSITA before the effective filing date of
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`the claimed invention and that a patent claim directed to such obvious subject matter
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`is invalid (under 35 U.S.C. § 103). I am also informed that in assessing the
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`obviousness of claimed subject matter, one should evaluate obviousness over the
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`prior art from the perspective of a POSITA before the effective filing date of the
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`claimed invention. It is my further understanding that obviousness is to be
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`determined based on several factual inquiries:
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`i. The scope and content of the prior art;
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`ii. The difference or differences between the subject matter of the
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`claim (as construed) and the prior art; and
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`iii. The level of ordinary skill in the art at the time of the invention of
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`the subject matter of the claim.
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`Against this background, the obviousness or non-obviousness of the claim is
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`determined.
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`19.
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`I am informed that relevant objective factors (the “secondary indicia”)
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`indicating non-obviousness might be utilized to give light to the circumstances
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`surrounding the origin of the subject matter sought to be patented. I am informed
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`that relevant secondary indicia can include:
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`i. Commercial success of the products or methods covered by the
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`patent claims;
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`ii. A long-felt need for the invention;
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`iii. Failed attempts by others to make the invention;
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`iv. Teaching away from the invention by the prior art;
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`v. Copying of the invention by others in the field;
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`vi. Unexpected results achieved by the invention;
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`vii. Praise, approval, or acclaim of the invention by others in the field;
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`viii. Commercial acquiescence to the validity of the patents;
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`ix. Skepticism of experts;
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`x. Expressions of surprise by experts and those skilled in the art at the
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`subject matter of the claim; and
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`xi. Whether the patentee proceeded contrary to accepted wisdom of
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`the prior art.
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`20.
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`I am informed that, in order to be relevant to the issue of obviousness,
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`such secondary indicia must have some nexus to the claimed invention.
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`21.
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`I am informed that sometimes obviousness is shown by combining
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`multiple prior art teachings under a test commonly referred to as the “teaching-
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`suggestion-motivation” or “TSM” test, which addresses the common situation where
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`previously known components are recited in a claim. I am informed that, according
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`to the TSM test, it must be shown explicitly or implicitly that there is some
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`suggestion or motivation in the prior art to combine known elements to form the
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`claimed invention.
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`22.
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`I am also informed that additional rationales may support an
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`obviousness determination when dealing with a known problem, including:
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`i. Combining prior art according to known methods to yield
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`predictable results;
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`ii. Simple substitution of a known element for another element to
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`obtain predictable results;
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`iii. Use of a known technique to improve similar devices, methods, or
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`products in some way;
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`iv. Applying a known technique to a known device, method, or
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`product ready for improvement to yield predictable results;
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`v. Obvious to try―that is, choosing from a finite number of
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`identified, predictable solutions with a reasonable expectation of
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`success; and
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`vi. Known work in one field of endeavor may prompt variations for
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`use in either the same field or a different one based on design
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`incentives or other market forces if the variations are predictable to
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`a POSITA.
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`23.
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`I am informed that, when I conduct my analysis, I should guard against
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`hindsight, that is, using the claimed invention(s) to retroactively form the basis of
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`any combination of prior art references. To guard against this, a reason must be
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`shown to combine or modify prior art teachings to arrive at the claimed subject
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`matter, and I have taken into consideration any teachings as expressed within the
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`prior art references and the general common knowledge in the art at the time the
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`claimed invention(s) was filed to guide my determination whether or not a POSITA
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`would make any of the combinations or modifications proposed in this declaration.
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`IV. MATERIALS REVIEWED
`24.
`I reviewed the following documents in preparation of this declaration:
`
`a.
`
`b.
`
`c.
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`d.
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`e.
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`The ’767 Patent (Ex. 1001);
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`The File History of U.S. Patent Application No. 15/065,683 (Ex.
`
`1003);
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`CN 201112782 to Cai et al. (Ex. 1004);
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`U.S. Patent No. 7,494,383 to Cohen et al. (Ex. 1005);
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`Quad Small Form-factor Pluggable
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`(QSFP) Transceiver
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`Specification Revision 1.0 (“QSFP Standard”);
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`f.
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`U.S. Patent Application Publication No. 20020192988
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`(“Droesbeke”); and
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`g.
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`Any other documents cited and referenced herein.
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`25.
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`In formulating my opinions herein, I relied on the above-cited
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`documents, as well as my personal knowledge and experience.
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`V. THE ’767 PATENT
`A.
`Summary of the ’767 Patent
`26. The ’767 Patent, filed as U.S. Patent Application No. 15/065,683 on
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`March 9, 2016, claims earliest priority to Provisional Application Ser. No.
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`61/332,366 filed on May 7, 2010. ’767 Patent at 1:6–22.
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`27. The “Field of the Invention” for the ’767 Patent states that it “relates
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`generally
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`to electrical
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`interconnection systems and more specifically
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`to
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`interconnections between cables and circuit assemblies.” Ex. 1001, 1:24-28.
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`28.
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`In particular, the ’767 Patent relates to “small form factor pluggable
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`(‘SFP’) and quad small form factor pluggable (‘QSFP’) connectors, both of which
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`are standardized by working groups.” Ex. 1001, 2:7–12. The ’767 Patent purports
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`to improve upon these connectors “through incorporation of one or more design
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`features.” Ex. 1001, 2:16–19. Such “features [] provide desirable electrical
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`performance, such as reduced crosstalk.” Ex. 1001, 4:37-42.
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`29. The ’767 Patent discloses a board-mounted connector in which a plug
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`may be inserted, completing a connection between a cable and electronic
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`components within the device. Ex. 1001, 2:3–12. In particular, the ’767 Patent
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`discloses that the board-mounted connector includes a receptacle containing a
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`housing and lead assemblies where the lead assemblies each include a housing
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`member and plurality of conductive elements each comprising a contact tail, mating
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`contact portion, and intermediate portion. Ex. 1001, FIGS. 5, 6.
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`30. Figure 6 provides an illustrative embodiment of the concept, in which
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`a lead assembly 610A includes a conductive element having a contact tail 312A, a
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`mating contact portion 512A, and an intermediate portion in between. Ex. 1001,
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`10:37–57. The intermediate portion of the conductive element is held within
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`housing member 612A. Id. The contact tail 312A is adapted for attachment to the
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`printed circuit board that is perpendicular to the first side of the printed circuit board.
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`Ex. 1001, Claim 1, 31:11–18.
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`31. The housing member 612A has exterior projections extending away
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`from the conductive element along a horizontal direction parallel to the first surface.
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`Ex. 1001, Figs. 5, 6. The conductive element has signal pairs such as 662A and
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`662B and ground conductors such as 660A, 660B, and 660C. Ex. 1001, Fig. 6. The
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`conductive element is positioned in the column to create a pattern of ground, signal
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`pair, ground, signal pair, ground. Ex. 1001, 13:38–53.
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`32. The intermediate portion has a right angle bend. Ex. 1001, Fig. 6. Lead
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`assemblies 610B, 610C and 610D are similarly formed and claimed as such. Ex.
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`1001, 10:58–67. Lossy inserts 650 and 652 may be provided to separate adjacent
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`ones of the lead assemblies 610A–610D. Ex. 1001, 11:11–67. The lossy inserts may
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`serve a mechanical support function or alter the electrical performance and improve
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`the overall electrical performance of the connector. Id.
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`B. Claims
`33. The ’767 Patent includes 32 claims. Claims 1, 24, 28, and 32 are
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`independent claims, are directed to a receptacle, and are similar in scope. Claims 1,
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`24, and 32 are limited to first and second lead assemblies, while claim 28 adds third
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`and fourth lead assemblies with virtually identical features to the first and second
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`lead assemblies.
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`34. The 32 claims of the ’767 Patent comprise 2818 words and are loaded
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`with repeating duplicative limitations that were and are well-known in the art. Claim
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`24 mainly differs from Claim 1 by inclusion of a well-known conductive element
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`arrangement. Claim 32 mainly differs from Claim 1 by requiring a contact tail
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`adapted for attachment to at least one second hole in a printed circuit board, a
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`limitation which the ’767 Patent presents as not critical to its invention. Finally
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`Claim 28 primarily differs from Claim 1 in the addition of the third and fourth lead
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`assemblies and the addition of a cage for use with the claimed receptacle.
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`35. During prosecution, the claims of the ’767 Patent were repeatedly
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`rejected in a number of office actions. In each occasion, the Patent Owner responded
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`by adding narrowing amendments to the claims. As a result, the 32 claims of the
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`’767 Patent are loaded with frivolous limitations that were and are well-known in
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`the art.
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`36. Many of the amendments, e.g., very precise geometrical relationships,
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`do not even appear in the specification of the ’767 Patent and, as such, appear to be
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`solely and liberally derive support only from the drawings of the ’767 Patent.
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`Moreover, a number of the amendments do not appear to be limitations at all. All
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`32 claims of the ’767 Patent are directed to a receptacle, and such amendments do
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`not appear to modify the claimed receptacle, but only describe how to use the
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`claimed receptacle, e.g., in combination with a cage, by attachment to a printed
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`circuit board.
`
`C.
`37.
`
`Person Having Ordinary Skill in the Art
`I understand that an assessment of claims of the ’767 Patent should be
`
`undertaken from the perspective of a POSITA as of the priority date. The ’767
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`claims its earliest priority to Provisional Application Ser. No. 61/332,366 filed on
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`May 7, 2010. Ex. 1001, 1:6–22.
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`38.
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`I have also been advised that, to determine the appropriate level of a
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`person having ordinary skill in the art, the following factors may be considered: (1)
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`the types of problems encountered by those working in the field and prior art
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`solutions thereto; (2) the sophistication of the technology in question, and the
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`rapidity with which innovations occur in the field; (3) the educational level of active
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`workers in the field; and (4) the educational level of the inventor.
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`39.
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`In my opinion, a POSITA as of May of 2010, had, among other
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`credentials, a Bachelor’s Degree in engineering or similar discipline and three to five
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`years of experience working with electromechanical systems. Additional graduate
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`education might substitute for experience, while significant industry experience may
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`substitute for formal education. Id. Such a POSITA would have had an
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`understanding of high-speed signal transmission and knowledge of design
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`considerations known in the industry and would have been familiar with then-
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`existing products and solutions, including known protocols and techniques; the
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`POSITA would have understood how to search available literature for relevant
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`publications. Id.
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`D.
`Interpretation of Claim Terms
`40. Based on my review of the ʼ767 Patent and its file history, a POSITA
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`would have understood the claim terms in light of the specification and interpreted
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`them by using their plain and ordinary meaning in accordance with the then current
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`state of the art.
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`VI. OVERVIEW OF THE PRIOR ART REFERENCES
`A. Cai (Ex. 1004)
`41. CN Utility Model Patent No. CN 201112782Y (“Cai”) (Ex. 1004) is
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`entitled “Electrical Connector” and issued on September 10, 2008, based on CN
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`Utility Model Patent Application No. 200720041080.0, filed on July 30, 2007.
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`42. Cai discloses an “electrical connector 1” that has “first and second
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`insert[ion] holes” for receiving “docking connector[s].” Ex. 1004 at 20; Claim 1;
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`FIG. 1. The electrical connector 1 includes four layers of right-angled conductive
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`terminals 31, 32 organized in two assemblies, and fixed in an insulating body 2. Id.
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`at FIG. 4, 21. The “insulating body 2 is provided with an upper surface 20, a lower
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`surface 21, and a docking surface 22.” Id. at 19; see also FIG. 2, 4 “A first inserting
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`hole 221 and a second inserting hole 222 are arranged side by side up and down by
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`protruding forward from the docking surface 22.” Id. Insulating blocks prevent the
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`conductive terminals from moving upwardly and thereby prevent them from being
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`deformed or causing signal crosstalk. Id. at 22; see also id., FIGS. 4 and 6.
`
`B. Cohen (Ex. 1005)
`43. U.S. Patent No. 7,494,383 (“Cohen”) (Ex. 1005) is entitled “Adapter
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`for Interconnecting Electrical Assemblies” and issued on Feb. 24, 2009, based on
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`U.S. Patent Application Serial No. 11/880,679, filed on July 23, 2007. Cohen
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`qualifies as prior art to the ‘767 Patent at least under pre-AIA 35 U.S.C. § 102(a)
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`and (b) because, for example, Cohen was published more than one year before the
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`earliest priority date of the ’767 Patent.
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`44. Cohen discloses an electrical connector suitable for use as an adapter.
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`Ex. 1005, Abstract. The adapter may be mounted on a printed circuit board. Id.
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`Specifically, Cohen discloses an adapter including electrical connectors with a
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`plurality of subassemblies. Id. at 3:19–26. A first subassembly includes a first
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`plurality of conductive members, each of which has a first end and a second end. Id.
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`at 3:27–44. At least a first subset of the first plurality of conductive members has a
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`mating contact at each of the first end and the second end, with the mating contacts
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`at the first ends being aligned in a first row and the mating contacts at the second
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`ends being aligned in a second row, parallel to the first row. Id. A first insulating
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`housing is molded around at least a portion of each of the first plurality of conductive
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`members. Id. A second subassembly includes a second plurality of conductive
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`members, each of which has a first end and a second end. Id. At least a second
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`subset of the second plurality of conductive members has a mating contact at each
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`of the first end and the second end, with the mating contacts at the first ends being
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`aligned in a third row and the mating contacts at the second ends being aligned in a
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`fourth row, parallel to the third row. Id. A second insulating housing is molded
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`LUXSHARE EXHIBIT 1002
`Page 19 of 85
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`around at least a portion of each of the second plurality of conductive members. Id.;
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`see also id. at FIG. 2.
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`45. The adapter also includes an insert that may be wholly or partially
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`formed of lossy material. Id. at 9:47-51. Cohen discloses that any suitable lossy
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`material may be used. Id. at 10:1–6. The lossy insert includes projections that are
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`positioned to couple with ground conductors. Id. at 9:54-60; see also id. at FIG. 5.
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`46. Cohen teaches that the lossy insert has been found to “reduce both near
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`and far end cross-talk and to also reduce both insertion loss and return loss over a
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`frequency range spanning between about 1 GHz and 10 GHz.” Id. at 9:61-63.
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`Page 20 of 85
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`C. QSFP Standard (Ex. 1006)
`47. Specification for Quad Small Form-factor Pluggable (QSFP)
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`Transceiver Revision 1.0 (“QSFP Standard”) (Ex. 1006) published on December 1,
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`2006. As listed on its face, Revision 1.0 of the QSFP standard was released by the
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`SFF committee December 1, 2006. See Ex. 1006, 8. The QSFP standard further
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`provides that “SFF Committee documentation may be purchased in hard copy or
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`electronic form SFF specifications are [sic] available at ftp://ftp.seagate.com/sff.”
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`Id. at 2. A POSITA would have known that the QSFP standard was available for
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`review on the Seagate website, and a skilled artisan could have easily accessed the
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`website and found the QSFP standard as of its release date.
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`48. QSFP Standard discloses specifications for the QSFP module edge
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`connector. Ex. 1006, 16-24. The QSFP connector has conductive elements
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`including a plurality of signal pairs and ground conductors. Id.; see also id. at FIG.
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`2. The signal pairs are positioned between adjacent ground conductors. Id.
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`Page 21 of 85
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`49. QSFP Transceiver Spec Rev 1.0 further discloses that the QSFP
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`connector is disposed within a cage. Id. at 33–37; see also id. at FIGS. 15, 16.
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`Page 22 of 85
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`D. Droesbeke (Ex. 1008)
`50. U.S. Patent Publication No. 2002/0192988 (“Droesbeke”) (Ex. 1008) is
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`entitled “RIGHT-ANGLED CONNECTOR” and published on Dec. 19, 2002.
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`Droesbeke qualifies as prior art to the ’767 Patent under pre-AIA 35 U.S.C. § 102(b)
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`because Droesbeke was published more than one year before the earliest priority
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`date of the ’767 Patent.
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`51. Droesbeke provides an example of an electrical “connector
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`compris[ing] a housing of insulating material and [four] right-angled contact
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`elements arranged in rows and columns.” Ex. 1008, Abstract. The contact elements
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`Page 23 of 85
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`of Droesbeke are disposed in four housing members. See Ex. 1008, annotated FIG.
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`1 (below); see also ¶15 (“The contact elements 4 are inserted into holes in the front
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`wall parts 18 as straight contact elements and are bent to obtain the right-angled
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`contact elements 4”).
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`VII. GROUND 1: CLAIMS 1-10 AND 28-32 ARE OBVIOUS OVER CAI
`A. Claim 1
`52. Claim 1 would have been obvious to a POSITA over Cai. Below I show
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`how each element of claim 1 is disclosed, taught, and/or suggested by Cai.
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`1[pre] A receptacle adapted for mounting to a printed circuit
`board, comprising:
`53. Cai discloses a receptacle adapted for mounting to a printed circuit
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`board. For example, FIG. 1 of Cai depicts an “electrical connector 1” that has “first
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`- 24 -
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`LUXSHARE EXHIBIT 1002
`Page 24 of 85
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`and second insert[ion] holes” for receiving “docking connector[s].” Ex. 1004 at 20;
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`Claim 1. A POSITA would have understood that an electrical connector with
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`inserting holes for receiving docking connectors constitutes a receptacle.
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`54. Moreover, Cai discloses that the electrical connector 1 includes “a
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`mounting support 252 that can fix the electrical connector 1 on [a] circuit board (not
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`shown).” Id. Accordingly, the electrical connector 1, like the receptacle of Claim
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`1, is adapted for mounting on a printed circuit board.
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`1[a] a housing having a cavity bounded by a first surface that is
`parallel to the printed circuit board and an opposing second
`surface that is parallel to the printed circuit board:
`55. The electrical connector 1 satisfies this element. The insulating body 2
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`defines a housing and the first inserting hole 221 defines a cavity bounded by a first
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`surface and second surface, as illustrated annotated FIG. 1 of Cai (below).
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`Page 25 of 85
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`56. Cai expressly discloses that its electrical connector 1 is to be attached
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`to a circuit board. See e.g., id. at 20. While Cai does not show the circuit board, a
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`POSITA would have readily understood that the first surface and second surface,
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`depicted in annotated FIG. 1 of Cai, are parallel to each other, and to a circuit board
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`when the electrical connector 1 is attached to the circuit board.
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`57.
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`It was well known that electrical connectors and the outlets that they
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`plug into comprise corresponding parallel surfaces to ensure establishing proper
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`electrical contact. Accordingly, it was well known for the lower surface 21 to be
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`parallel to the circuit board when connected to the electrical connector 1. Moreover,
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`Page 26 of 85
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`annotated FIG. 1 of Cai clearly shows the lower surface 21 in parallel with the first
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`and second surfaces. Accordingly, by the transitive properties of parallel
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`relationships, it would have been obvious for the circuit board to also be in parallel
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`with the first and second surfaces, when the electrical connector 1 was assembled
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`with the circuit board.
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`58. Moreover, a POSITA would have readily understood that a lower
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`surface 21 non-parallel to the circuit board would have resulted in undesirable
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`partially-exposed and/or misaligned connections. Accordingly, it is reasonable to
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`conclude that the lower surface 21 would have been in parallel with the circuit board
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`and, thus, in parallel with the first and second surfaces, when the electrical connector
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`1 is connected to the circuit board.
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`59. The parallel relationship between the lower surface 21 and the circuit
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`board, which translates into a parallel relationship between the first and second
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`surfaces and the circuit board, can be proven a different way. Cai discloses “vertical
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`portion[s] 34 [] provided with [] welding portion[s] 341 extending out from the
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`insulating body 2 to connect to a circuit board.” Id. at 21; FIG. 4. Cai also discloses
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`“a mounting support 252 that can fix the electrical connector 1 on the circuit board
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`(not shown) [and] is extended downwards” from the insulating body 2 in parallel
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`with the vertical portions 34. Id. at 20; FIG. 4. The mounting support 252 and the
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`Page 27 of 85
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`vertical portions 34 are clearly perpendicular to the lower surface 21, as depicted in
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`annotated FIG. 2 (below).
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`60. As such, a POSITA would have readily understood that a nonparallel
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`relationship between the lower surface 21 and the circuit board would have resulted
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`in a misalignment that would have made it impossible for the welding portions 341
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`and the mounting support 252 to properly connect to the circuit board. Accordingly,
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`the lower surface 21 would have been in parallel with the circuit board while the
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`circuit board is connected to the welding portions 341 and mounting support 252. It
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`follows then that the first and second surfaces would have been parallel and that the
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`Page 28 of 85
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`first inserting hole 221 would have also been in parallel with the circuit board, since
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`they are in parallel with the lower
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