UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`IPR2022-00350
`U.S. Patent No. 9,806,565
`
`________________
`
`SUPPLEMENTAL DECLARATION OF JOSHUA PHINNEY, PH.D.,
`UNDER 37 C.F.R. § 1.68
`
`Ex.1024 / IPR2022-00350 / Page 1 of 34
`APPLE INC. v. SCRAMOGE TECHNOLOGY LTD.
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`

`

`TABLE OF CONTENTS
`Introduction ...................................................................................................... 3
`A.
`B. A POSITA would have found substitute claims 21-23 obvious over
`Goma in view of Park. ..................................................................................... 4
`a.
`Summary of Goma ................................................................................ 4
`b.
`Summary of Park ................................................................................... 6
`c.
` Detailed Analysis ................................................................................. 7
`Declaration ..................................................................................................... 34
`
`C.
`
`
`
`
`
`
`
`2
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`I, Joshua Phinney, Ph.D., declare:
`
`A.
`
`Introduction
`1.
`I am making this supplemental declaration at the request of Apple Inc.
`
`in the matter of the Inter Partes Review IPR2022-00350 of U.S. Patent No.
`
`9,806,565 (the “’565 Patent”) to An et al. The terms of my engagement, my
`
`background and qualifications, prior testimony, and the legal standards and claim
`
`constructions that I am applying are set forth in my previous CV and declaration.
`
`See Ex.1003; Ex.1004.
`
`2.
`
`In the preparation of this declaration, I have studied the materials
`
`noted in my previous declaration, as well as the following additional materials:
`
`(1) Ex.1023 – Certified English Translation of Japanese Patent Publication
`
`JP2011-210937 to Goma et al. (“Goma”), Japanese Language Version
`
`of JP2011-210937, and the Translation Certificate.
`
`3.
`
`In forming the opinions expressed below, I have considered:
`
`(1)
`
`the documents listed above; the relevant legal standards, including the
`
`standard for obviousness, and any additional authoritative documents as
`
`cited in the body of this declaration; and my own knowledge and experience,
`
`including my work experience in the field of wireless charging, as described
`
`below.
`
`
`
`3
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`B. A POSITA would have found substitute claims 21-23 obvious over Goma
`in view of Park.
`4.
`I have been asked to provide my opinion as to whether Substitute
`
`Claims 21, 22, and 23 in Patent Owner’s Motion to Amend (“Motion,” Paper 18)
`
`would have been obvious in view of prior art. The discussion below provides a
`
`detailed analysis of how JP2011-210937 to Goma et al. (“Goma,” Ex.1023) in
`
`view of U.S. Patent No. 8,922,162 to Park et al. (“Park,” Ex. 1006) renders
`
`obvious the limitations of the substitute claims.
`
`a. Summary of Goma
`Like the’565 Patent, Goma relates to a “coil module for contactless
`
`5.
`
`power transmission” for electronic devices. Ex.1023, [0002]. Goma also describes
`
`that its “coil module” may be used in “electronic devices such as communication
`
`devices.” Id. at [0001]-[0002].
`
`6.
`
` Figs. 1 and 2 of Goma, reproduced and annotated below, illustrate a
`
`coil module 1 having a “resin structure 3” that includes an “opening 32” of a
`
`rectangular shape to receive a rectangular “circuit board 4.” Id. at [0031], [0037].
`
`The resin structure 3 and the opening 32 are formed by a “mold” with a specific
`
`shape. Id. at [0039]. Goma teaches that the “coil 2 is formed into a coil” or spiral
`
`shape with a “conductor such as a copper wire” disposed on and within the “resin
`
`structure 3”. Id. at [0032].
`
`
`
`4
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`resin
` structure 3
`
`
`opening 32
`
`
`circuit board 4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`
`
`
`circuit board 4 in opening 32
`Ex.1023, Fig. 2 (annotated)
`
`
`
`
`
`
`
`Additionally, as shown in Fig. 1 above, Goma’s circuit board 4 is disposed in the
`
`opening 32 and is connected to the wires 21 of the coil 2. The coil 2 is disposed on
`
`the resin structure 3, and the wire 21 of the coil 2 is connected to the circuit board
`
`4. Additionally, Goma’s circuit board 4 overlaps the opening 32 and extends in a
`
`second direction parallel to the upper surface of the resin structure 3. These
`
`components of the “coil module 1” provide “contactless power transmission” in an
`
`“electronic device on the power receiving side.” Id. at [0001]-[0002]. Therefore,
`
`
`
`5
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`the coil 2 is configured for “contactless” power reception. Id.
`
`b. Summary of Park
`Like Goma and the ’565 Patent, Park relates to a device for wireless
`
`7.
`
`charging. See Park, Abstract. Park explains in its background section that it was
`
`known to include both a wireless charging coil and NFC antenna on the same
`
`portable device: “To implement both the NFC function and the wireless charging
`
`function in a single portable terminal, an NFC antenna element taking the form of a
`
`loop antenna and a secondary coil for wireless charging should be mounted in the
`
`portable terminal.” Ex.1006, 1:54-59.
`
`Park describes an improvement upon this known concept: “[T]he present invention
`
`is to provide a portable terminal having a structure that facilitates mounting of a
`
`secondary coil for wireless charging and a Near Field Communication (NFC)
`
`antenna element, without increasing the thickness of the portable terminal.” Id. at
`
`2:11-15. Park does this by having “a first coil for wireless charging and a second
`
`coil for the NFC function on the same plane.” Id. at 5:63-65.
`
`
`
`6
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`wireless charging
`coil 133
`
`NFC coil 135
`
`Park, Figs. 3 and 4 (annotated)
`
`recessed
`accommodation
`groove
`
`
`
`Accordingly, Park provides evidence that it was known for a portable device to
`
`include both a wireless charging coil and a near field communication antenna,
`
`particularly in recessed accommodation grooves on the same plane.
`
`c. Detailed Analysis
`The following claim chart describes how the Goma reference in view
`
`8.
`
`of the Park reference renders obvious the Substitute Claims 21, 22, and 23.
`
`Claim 21
`[21.0] A
`wireless power
`receiver,
`
`Prior Art
`Goma discloses a wireless power receiver.
`
`
`
`
`7
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`comprising:
`
`
`
`coil module 1 (wireless power receiver)
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`Specifically, as shown above in Fig. 1, Goma discloses a “coil
`module” (wireless power receiver) for “contactless power
`transmission” in an “electronic device on the power receiving
`side.” Ex.1023, [0001], [0002] (describing a “coil module for
`contactless power transmission in each of the electronic devices
`on the power transmitting side and the electronic device on the
`power receiving side”), [0030], [0036], FIG. 1-3.
`Goma discloses “a substrate comprising a receiving space of a
`predetermined shape formed therein for a discrete connecting unit
`configured to connect to a wireless power receiving circuit.”
`
`In particular, Goma teaches that its coil module includes a “resin
`structure 3” (substrate) made of a “curable resin in which a
`magnetic material such as ferrite or the like is mixed into a powder
`is molded into a flat plate.” Ex.1023, [0031], [0033].
`The resin structure 3 includes an “opening 32” (receiving space)
`of a rectangular shape to receive a rectangular “circuit board 4”
`(connecting unit) configured to “mount the coil module 1 to the
`electronic device.” Ex.1023, [0031], [0037].
`
`Figs. 1 and 2 of Goma, annotated below, illustrate resin structure 3
`
`8
`
`[21.1] a
`substrate
`comprising a
`receiving space
`of a
`predetermined
`shape formed
`therein for a
`discrete
`connecting unit
`configured to
`connect to a
`wireless power
`receiving
`
`
`
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`circuit;
`
`
`
`with opening 32 (red dashes) and circuit board 4.
`
`
`resin
` structure 3
`(substrate)
`
`opening 32
`(receiving
`space)
`
`circuit board 4
`(connecting
`unit)
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`
`
`
`circuit board 4 in opening 32
`Ex.1023, Fig. 2 (annotated)
`
`
`Goma explains that the resin structure 3 and the opening 32
`therein are formed by a “mold” with a specific shape so that the
`“coil 2 and a portion of the circuit board 4 are exposed to the
`exterior at one face 31 of the resin structure 3.” Ex.1023, [0039].
`That is, the opening 32 (receiving space) is of a predetermined
`shape to accommodate and expose the circuit board 4 (connecting
`unit).
`
`With respect to the recitation that the claimed connecting unit be
`“configured to connect to a wireless power receiving circuit,”
`Goma explains that the circuit board 4 (connecting unit) connects
`to an electronic component 41 (wireless power receiving circuit)
`that includes “a rectifier circuit, a regulator circuit, and a charge-
`control circuit”. Ex.1023, [0036]. I note that the ‘565 Patent
`
`
`
`9
`
`
`
`
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`specification states that “the wireless power receiving circuit may
`include a rectifier circuit.” Ex.1001, 5:31-32.
`
`As shown in Fig. 3(b) and (c) below, during manufacture, the
`circuit module 43 with electronic component 41 (wireless power
`receiving circuit) is connected to circuit board 4 (wireless power
`receiving circuit), which is a discrete component. Ex.1023,
`[0038]-[0039].
`
`
`
`
`Ex.1023, Fig. 3 (annotated and cropped)
`
`
`Accordingly, Goma’s teaching of a resin structure 3 comprising an
`opening 32 of a predetermined rectangular shape formed therein
`for the discrete circuit board 4 configured to connect to a rectifier
`circuit renders obvious “a substrate comprising a receiving space
`of a predetermined shape formed therein for a discrete connecting
`unit configured to connect to a wireless power receiving circuit,”
`as claimed.
`Goma discloses “a coil unit disposed on the substrate, the coil unit
`comprising a first connection terminal, a second connection
`terminal, and a coil.”
`
`As shown in annotated Fig. 1 below, Goma teaches that “the coil
`module 1 is equipped with a flat, plate-shaped coil 2” (coil unit)
`that is disposed on a surface of the resin structure 3 (substrate).
`Ex.1023, [0031], [0033].
`
`10
`
`[21.2] a coil unit
`disposed on the
`substrate, the
`coil unit
`comprising a
`first connection
`terminal, a
`second
`
`
`
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`connection
`terminal, and a
`coil;
`
`
`
`coil 2
`(coil unit)
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`As shown in annotated Fig. 3 below, the coil 2 includes a “circular
`shape” portion (coil) and also first and second “wire 21” portions
`(first and second connection terminals) that are “connected to the
`coil connection terminal 45 formed on the circuit board 4 using
`solder or the like.” Ex.1023, [0038].
`
`circular coil
`
`wires 21
`(first and second
`connection terminals)
`
`Ex.1023, Fig. 3 (annotated and cropped)
`
`
`Further, a POSITA would have understood that a connection
`terminal in the electrical engineering arts is not limited to a
`particular shape but can take on many different shapes, including
`an elongated shape when connected to the ends of a coil. A
`POSITA would also understand that the free ends/leads connected
`to a coil conductor are terminals, specifically “connection
`terminals” that electrically connect the coil to the surrounding
`circuit.
`
`
`
`[21.3] short-
`
`Goma in view of Park renders obvious the limitation: “short-range
`
`
`
`11
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`range
`communication
`antenna
`disposed on the
`substrate and
`surrounding the
`coil;
`
`communication antenna disposed on the substrate and surrounding
`the coil.”
`
`In particular, Goma discloses that its wireless power receiver is
`intended to be used in “electronic devices such as communication
`devices.” Ex.1023, [0001]-[0002].
`
`Although Goma does not explicitly teach that a short-range
`communication antenna may be disposed around the power-
`receiving coil 2, it was common prior to the ’565 patent for
`communication devices like the one in Goma to include such a
`communication antenna. For example, Park explains in its
`background section that it was known to include both a wireless
`charging coil and NFC antenna in the same portable device: “To
`implement both the NFC function and the wireless charging
`function in a single portable terminal, an NFC antenna element
`taking the form of a loop antenna and a secondary coil for wireless
`charging should be mounted in the portable terminal.” Ex.1006,
`1:54-58. Park describes an improvement upon this known concept
`“without increasing the thickness of the portable terminal.”
`Ex.1006, 2:10-15. Park does this by having “a first coil for
`wireless charging and a second coil for the NFC function on the
`same plane.” Ex.1006, 5:63-65. As shown in Figs. 3 and 4 of
`Park, NFC coil 135 “surrounds” wireless charging coil 133, where
`the two coils are disposed on the same substrate 131. Ex.1006,
`3:56-64.
`
`NFC coil 135
`
`wireless charging
`coil 133
`
`Ex.1006, Figs. 3 and 4 (annotated); Ex.1003, ¶ 74.
`
`
`
`
`
`12
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`
`It is my opinion that before the ’565 patent, it would have been
`obvious, beneficial, and predictable for Goma’s device to include
`an NFC coil surrounding its wireless charging coil, as taught by
`Park.
`
`As an initial matter, Park is analogous prior art pertaining to the
`same field of endeavor as Goma, namely, contactless charging of a
`communication device via electromechanical induction. See
`Ex.1023, [0001]-[0002]; Ex.1006, Abstract. Park explains that
`“[a]s portable terminals have become a daily commodity, they are
`equipped with the NFC function.” Ex.1006, 1:24-33. Park further
`explains that to implement an NFC-capable portable terminal, the
`“portable terminal is provided with an additional antenna for
`performing the NFC function.” Ex.1006, 1:31-33. Thus, as a
`baseline, it was well known and obvious for a portable terminal,
`such as Goma’s, to include an NFC antenna coil as well as a
`wireless charging coil.
`
`One of ordinary skill in the art would have been specifically
`motivated to implement Goma’s device with an NFC coil because
`as of the earliest alleged priority date of the ’565 patent, NFC was
`a standardized data transmission protocol with a multitude of
`commercial applications and advantages over other short-range
`wireless communication protocols. See Ex.1009, 2:9-26; Ex.1010,
`2:64-3:6, 3:66-4:11.
`
`For example, at the time, “[f]amiliar applications of NFC protocol
`technology [were] electronic pass keys used in building security
`systems, mass transit fare card systems, and smart credit cards
`which need only to be brought close to a point of sale reader to
`complete a transaction.” Ex.1010, 4:7-11; see also Ex.1006, 1:27-
`29. Relative to other short-range wireless protocols, “NFC
`technology provides an advantage of fast communication setup
`between communication devices.” Ex.1006, 1:33-36. Further, “the
`intuitive operation of NFC protocol systems makes the technology
`particularly easy for consumers to use (‘just touch and go’).”
`Ex.1010, 4:2-5. Accordingly, a person of ordinary skill in the art
`
`
`
`13
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`would have been motivated to apply Park’s teachings regarding an
`NFC coil to Goma’s portable device. Doing so would allow
`Goma’s mobile device to be easily used for transactions in a
`variety of commercial applications.
`
`
`As an aspect of implementing Park’s teaching of an NFC coil in
`Goma’s device, a POSITA would have found it obvious to locate
`the NFC coil such that it surrounds Goma’s wireless charging coil
`in accommodating grooves, as taught by Park. Specifically, Park
`teaches and illustrates in Figs. 3 and 4 (reproduced above) that its
`NFC coil 135 is “surrounding” its wireless charging coil 133 in
`grooves 141 and 142. Ex.1006, 2:25-31, Figs. 3, 4. A POSITA
`would have found it advantageous to use Park’s arrangement in
`which the NFC coil surrounds the wireless power coil, due to the
`different frequencies at which the different wireless protocols
`operate. See e.g., Ex.1019, 17:49-59 (“Since the NFC antenna coil
`41 has a higher frequency band than the wireless charger antenna
`coil 43, the NFC antenna coil 41 is formed … along the outside of
`the substrate 49 … [and] the wireless charger antenna coil 43 is
`formed in the inside of the NFC antenna coil 41.”). For this same
`reason, a POSITA would have arranged Goma’s NFC coil to
`surround its power-receiving coil 16.
`
`Not only would utilizing Park’s teachings regarding an NFC coil
`in Goma’s wireless power receiver have been advantageous, but a
`POSITA would have also found doing so straightforward and
`predictable given that the combination utilizes Park’s NFC coil
`precisely as it was intended—as a companion to a wireless power
`receiving coil in a portable device. A POSITA would have had a
`reasonable expectation of success because the combination does
`not change the intended functionality of either Goma’s power
`receiver or Park’s NFC coil. Park’s NFC coil was specifically
`intended to be implemented in wireless power receivers ready for
`improvement, such as Goma’s device. A POSITA would have
`further had a reasonable expectation of success in making the
`combination because the NFC wireless protocol was standardized
`and commercially available. See Ex.1009, 2:9-26; Ex.1010, 2:64-
`
`
`
`14
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`3:6. Implementing standardized and commercially available
`components within a mechanical device such as Goma’s device
`would have been well within the skill of a person of ordinary skill
`in the art in 2012.
`
`
`Accordingly, the combination of Goma and Park simply represents
`the combination of a known element (Park’s NFC coil) with
`Goma’s known contactless power transmission apparatus
`according to known methods to yield a predictable result (a
`portable terminal with both NFC and wireless charging
`capabilities).
`Goma discloses that: “the coil is configured to wirelessly receive
`power, wherein the coil is formed as a conductive pattern on or
`within the substrate.”
`
`
`
`resin
` structure 3
`(substrate)
`
`opening 32
`(receiving
`space)
`
`
`
`
`
`
`
`
`
`circuit board 4
`
`(connecting
`
`unit)
`
`
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`[21.4] wherein
`the coil is
`configured to
`wirelessly
`receive power,
`wherein the coil
`is formed as a
`conductive
`pattern on or
`within the
`substrate;
`
`
`
`
`
`
`circuit board 4 in opening 32
`Ex.1023, Fig. 2 (annotated); Ex.1024, ¶xx
`
`
`
`
`
`
`
`15
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`
`As shown in annotated Figs. 1 and 2 above, Goma teaches that the
`“coil 2 is formed into a coil shape” with a “conductor such as a
`copper wire” and disposed on and within “resin structure 3”
`(substrate). Ex.1023, [0032].
`
`As discussed above, the coil is configured for “contactless” power
`reception. Ex.1023, [0001], [0002] (describing “coil module for
`contactless power transmission in each of the electronic devices on
`the power transmitting side and the electronic device on the power
`receiving side”), [0030], [0036], FIG. 1-3.
`
`Goma discloses: “the conductive pattern comprises a conductive
`line wound at least two times and conductive pattern has a spiral
`shape.”
`
`As shown in annotated Fig. 1 below, Goma teaches that the coil 2
`is a “conductive” wire wound more than two times and has a spiral
`shape. Ex.1023, [0032].
`
`
`coil
`
`[21.5] wherein
`the conductive
`pattern
`comprises a
`conductive line
`wound at least
`two times and
`conductive
`pattern has a
`spiral shape,
`
`
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`
`
`[21.6] wherein Goma discloses: “the first connection terminal is located at one
`
`
`
`16
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`end of the coil and the second connection terminal is located at the
`other end of the coil.”
`
`As described in [21.2] and illustrated in Fig. 3 below, the coil 2
`includes first and second “wire 21” portions (first and second
`connection terminals), where the first wire 21 (first connection
`terminal) is located at the outer end of the coil and the second wire
`21 (second connection terminal) is located at the inner end of the
`coil. Ex.1023, [0038].
`
`
`coil
`
`wires 21
`(first and second
`connection terminals)
`
`Ex.1023, Fig. 3 (annotated and cropped)
`
`
`
`
`Goma discloses: “wherein the coil unit overlaps the receiving
`space, and wherein the coil unit is disposed on the substrate in a
`first direction perpendicular to the upper surface of the substrate.”
`
`
`As illustrated in Fig. 1 below, the wire 21 portions of the coil 2
`overlap the opening 32 (receiving space).
`
`
`the first
`connection
`terminal is
`located at one
`end of the coil
`and the second
`connection
`terminal is
`located at the
`other end of the
`coil,
`
`
`
`
`
`[21.7] wherein
`the coil unit
`overlaps the
`receiving space,
`and wherein the
`coil unit is
`disposed on the
`substrate in a
`first direction
`perpendicular to
`the upper
`surface of the
`substrate,
`
`
`
`17
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`coil 2
`
`wires 21 of
`coil unit overlap
`opening 32
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`As illustrated in Fig. 2 below, the coil 2 is disposed on the resin
`structure 3 (substrate) in a first direction perpendicular to the
`upper surface of the resin structure 3:
`resin structure 3
`
`coil 2
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 2 (annotated)
` (
`d)
`
`
`To the extent there is any ambiguity as to the spatial relationship
`recited in this limitation, the spatial relationship between Goma’s
`coil 2 and resin structure 3 is the same as the spatial relationship
`between the coil unit 200 and the substrate 100 in Fig. 28 of the
`’565 patent pointed to by Patent Owner in its Motion. See Motion
`at 7.
`
`Goma discloses: “wherein the connecting unit is disposed in the
`receiving space and connected to the coil unit.”
`
`
`
`[21.8] wherein
`the connecting
`unit is disposed
`in the receiving
`
`
`
`As illustrated in Figs. 1 and 2 below, Goma’s circuit board 4
`
`18
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`Ex.1024 / IPR2022-00350 / Page 18 of 34
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`

`

`space and
`connected to the
`coil unit,
`
`
`
`(connecting unit) is disposed in the opening 32 (receiving space)
`and is connected to the wires 21 of the coil 2.
`
`opening 32
`
`circuit board 4 in opening 32
`Ex.1023, Fig. 2 (annotated)
`
`
`
`
`
`
`circuit board 4
`connected to
`wires 21 of the
`coil 2
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`
`
`Goma discloses: “wherein the connecting unit overlaps the
`receiving space, the connecting unit extending in a second
`direction parallel to the upper surface of the substrate.”
`
`As illustrated in Fig. 2 below, Goma’s circuit board 4 (connecting
`unit) overlaps the opening 32 (receiving space) and extends in a
`second direction parallel to the upper surface of the resin structure
`3 (substrate).
`
`19
`
`[21.9] wherein
`the connecting
`unit overlaps
`the receiving
`space, the
`connecting unit
`extending in a
`second
`direction
`
`
`
`Ex.1024 / IPR2022-00350 / Page 19 of 34
`APPLE INC. v. SCRAMOGE TECHNOLOGY LTD.
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`

`

`parallel to the
`upper surface of
`the substrate,
`and
`
`opening 32
`
`resin structure 3
`
`
`
`
`circuit board 4
`Ex.1023, Fig. 2 (annotated)
`
`
`
`
`
`[21.10a]
`wherein the
`connecting unit
`comprises: a
`circuit board
`having a wiring
`layer;
`
`Goma discloses: “wherein the connecting unit comprises: a circuit
`board having a wiring layer.”
`
`As shown in Fig. 3(b), Goma teaches that its “circuit board 4”
`(connecting unit) includes “wiring 48” (wiring layer) “between
`the respective terminals [that] are formed on the circuit board 4.”
`Ex.1023, [0038].
`
`
`circuit board 4
`(connecting unit)
`
`wiring 48 (wiring layer)
`Ex.1023, Fig. 3(b) (annotated and cropped)
`
`
`
`
`
`Goma discloses: “a third connection terminal on the circuit board,
`connected to the first connection terminal of the coil unit; and a
`fourth connection terminal on the circuit board, connected to the
`second connection terminal of the coil unit.”
`
`20
`
`[21.10b]
`[wherein the
`connecting unit
`comprises:] a
`third connection
`
`
`
`Ex.1024 / IPR2022-00350 / Page 20 of 34
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`

`

`As shown in Fig. 3(b), Goma teaches that its circuit board 4
`(connecting unit) includes two coil connection terminals 45 (third
`and fourth connection terminals) and that respectively connected
`to the two wires 21 (first and second connection terminals) of the
`coil 2. Ex.1023, [0038] (“the wire material 21 drawn from the coil
`2 is connected to the coil connection terminal 45 formed on the
`circuit board 4 using solder or the like”).
`
`
`coil connection
`terminals 45 (third and forth
`connection terminals)
`connected to the wires 21
`
`wires 21
`(first and second
`connection terminals)
`
`circuit board 4
`(connecting unit)
`
`Ex.1023, Fig. 3(b) (annotated and cropped)
`
`
`
`
`
`Goma discloses: “wherein the connecting unit is otherwise
`separate from the first connection terminal, the second connection
`terminal, and the coil unit.”
`
`As shown in Fig. 1 below, the circuit board 4 (connecting unit) is
`otherwise separate from the two wires 21 (first and second
`connection terminals) and the coil 2.
`
`
`terminal on the
`circuit board,
`connected to the
`first connection
`terminal of the
`coil unit; and a
`fourth
`connection
`terminal on the
`circuit board,
`connected to the
`second
`connection
`terminal of the
`coil unit,
`
`[21.10c]
`wherein the
`connecting unit
`is otherwise
`separate from
`the first
`connection
`terminal, the
`second
`connection
`terminal, and
`the coil unit.
`
`
`
`21
`
`Ex.1024 / IPR2022-00350 / Page 21 of 34
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`

`

`circuit board 4
`only connected
`to wires 21 of
` the
`coil 2
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`Claim 22
`[22.0] A
`wireless power
`receiver,
`comprising:
`
`
`
`Prior Art
`Goma renders obvious the limitation: “[a] wireless power
`receiver,” as described above in [21.0].
`
`
`[22.1] a
`substrate
`comprising a
`receiving space
`of a
`predetermined
`shape formed
`therein for a
`discrete
`connecting unit
`configured to
`connect to a
`wireless power
`receiving
`circuit; and
`
`
`
`Goma renders obvious the limitation: “a substrate comprising a
`receiving space of a predetermined shape formed therein for a
`discrete connecting unit configured to connect to a wireless
`power receiving circuit,” as described above in [21.1].
`
`
`
`
`22
`
`Ex.1024 / IPR2022-00350 / Page 22 of 34
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`

`

`
`[22.2] a coil
`unit comprising
`a first
`connection
`terminal, a
`second
`connection
`terminal, and a
`coil; and
`
`
`
`
`[22.3] a short-
`range
`communication
`antenna
`disposed on the
`substrate and
`surrounding the
`coil;
`
`
`
`[22.4] wherein
`the coil is
`configured to
`wirelessly
`receive power,
`wherein the coil
`is formed as a
`conductive
`pattern on or
`
`
`
`Goma renders obvious the limitation: “a coil unit comprising a
`first connection terminal, a second connection terminal, and a
`coil,” as described above in [21.2].
`
`
`
`
`Goma in view of Park renders obvious the limitation: “ a short-
`range communication antenna disposed on the substrate and
`surrounding the coil,” as described in [21.3].
`
`
`
`
`
`
`
`
`
`
`
`Goma renders obvious the limitation: “ wherein the coil is
`configured to wirelessly receive power, wherein the coil is formed
`as a conductive pattern on or within the substrate,” as described
`below and above in [21.4].
`
`
`
`23
`
`Ex.1024 / IPR2022-00350 / Page 23 of 34
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`

`within the
`substrate,
`
`
`[22.5] wherein
`the conductive
`pattern
`comprises a
`conductive line
`wound at least
`two times and
`the conductive
`pattern has a
`spiral shape,
`
`
`
`
`
`[22.6] wherein
`the first
`connection
`terminal is
`located at one
`end of the coil
`and the second
`connection
`terminal is
`located at the
`other end of the
`coil,
`
`
`
`[22.7] wherein
`the connecting
`unit is disposed
`
`
`
`Goma renders obvious the limitation: “ wherein the conductive
`pattern comprises a conductive line wound at least two times and
`the conductive pattern has a spiral shape,” as described below and
`above in [21.5].
`
`
`
`Goma renders obvious the limitation: “ wherein the first
`connection terminal is located at one end of the coil and the
`second connection terminal is located at the other end of the coil,”
`as described above in [21.6].
`
`
`
`Goma renders obvious the limitation: “ wherein the connecting
`unit is disposed in the receiving space and connected to the coil
`
`24
`
`Ex.1024 / IPR2022-00350 / Page 24 of 34
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`

`

`unit,” as described above in [21.8].
`
`
`
`Goma renders obvious the limitation: “wherein the connecting unit
`overlaps the receiving space, the connecting unit extending in a
`direction parallel to the upper surface of the substrate,” as
`described above in [21.9].
`
`
`
`Goma renders obvious the limitation: “wherein the connecting unit
`comprises: a circuit board having a wiring layer,” as described in
`[21.10a].
`
`in the receiving
`space and
`connected to the
`coil unit,
`
`
`
`[22.8] wherein
`the connecting
`unit overlaps
`the receiving
`space, the
`connecting unit
`extending in a
`direction
`parallel to the
`upper surface of
`the substrate,
`and
`
`
`
`[22.9a]
`wherein the
`connecting unit
`comprises: a
`circuit board
`having a wiring
`layer;
`
`
`
`[22.9b]
`[wherein the
`connecting unit
`comprises:] a
`third connection
`
`Goma renders obvious the limitation: “[wherein the connecting
`unit comprises:] a third connection terminal on the circuit board,
`connected to the first connection terminal of the coil unit; and a
`fourth connection terminal on the circuit board, connected to the
`second connection terminal of the coil unit,” as described in
`
`
`
`25
`
`Ex.1024 / IPR2022-00350 / Page 25 of 34
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`

`

`terminal on the
`circuit board,
`connected to the
`first connection
`terminal of the
`coil unit; and a
`fourth
`connection
`terminal on the
`circuit board,
`connected to the
`second
`connection
`terminal of the
`coil unit,
`
`[22.9c] wherein
`the connecting
`unit is
`otherwise
`separate from
`the first
`connection
`terminal, the
`second
`connection
`terminal, and
`the coil; and
`
`
`
`[22.10] wherein
`the coil unit is
`disposed on the
`substrate and
`the connecting
`
`[21.10b].
`
`Goma renders obvious the limitation: wherein the connecting unit
`is otherwise separate from the first connection terminal, the
`second connection terminal, and the coil,” as described in
`[21.10c].
`
`Goma discloses: “wherein the coil unit is disposed on the substrate
`and the connecting unit.”
`
`As illustrated in Fig. 2 below, the coil 2 (coil unit) is disposed on
`the resin structure 3 (substrate), and the wire 21 portion of the coil
`2 is connected to (disposed on) the circuit board 4 (connecting
`
`
`
`26
`
`Ex.1024 / IPR2022-00350 / Page 26 of 34
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`

`unit.
`
`
`
`unit):
`resin structure 3
`(substrate)
`
`coil 2
`
`wires 21 of the
`coil 2
`connected to
`circuit board 4
`
`
`
`
`
`
`
`
`
`
`Ex.1023, Fig. 1 (annotated)
`
`
`
`
`
`Claim 23
`
`
`
`[23.0] The
`wireless power
`receiver of
`claim 21,
`
`
`
`[23.1] wherein
`the third
`connection
`terminal is
`located within a
`horizontal
`boundary
`defining the
`receiving space
`and is located at
`one end of the
`coil that is at an
`
`
`
`Goma renders obvious the wireless power receiver of claim 21.
`See claim 21.
`
`Goma discloses: “wherein the third connection terminal is located
`within a horizontal boundary defining the receiving space and is
`located at one end of the co