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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
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`APPLE INC.,
`Petitioner
`
`v.
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`IPR2022-00350
`U.S. Patent No. 9,806,565
`
`
`
`
`PETITIONER’S REPLY
`TO PATENT OWNER’S RESPONSE
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`
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`
`
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`TABLE OF CONTENTS
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`PETITIONER’S EXHIBIT LIST .............................................................................. 1
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 2
`
`NO CLAIM CONSTRUCTION IS NECESSARY BECAUSE THE
`PETITION POINTS TO SEPARATE AND DISTINCT
`COMPONENTS FOR THE “SUBSTRATE COMPRISING A
`RECEIVING SPACE” AND “CONNECTING UNIT” ................................. 2
`
`III. THE PETITION ESTABLISHES THAT HONG TEACHES A
`“SUBSTRATE COMPRISING A RECEIVING SPACE” AND A
`SEPARATE “CONNECTING UNIT [THAT] IS DISPOSED IN THE
`RECEIVING SPACE” (CLAIMS 1 AND 12) ................................................. 6
`
`A. Hong is explicit that its wiring layer (connecting unit) is a separate
`element “formed in” its receiving space .............................................. 7
`
`B.
`
`The challenged claims are sufficiently broad that a wiring layer
`embedded within a substrate teaches a connecting unit disposed in
`the receiving space ............................................................................. 10
`
`IV. HONG TEACHES THAT ITS CONNECTING UNIT IS SEPARABLE
`FROM ITS RECEIVING SPACE (CLAIM 13) ...........................................15
`
`A.
`
`Claim 13 broadly recites separability without requiring that the
`entire “connecting unit” be “separable” from the “receiving
`space” ................................................................................................. 15
`
`B.
`
`Hong’s rectifying unit is separable from its receiving space ............. 16
`
`IV. CONCLUSION ..............................................................................................18
`
`CERTIFICATE OF SERVICE ................................................................................20
`
`ii
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`
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`
`
`Ex.1001
`
`Ex.1002
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`Ex.1003
`Ex.1004
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`Ex.1005
`Ex.1006
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`Ex.1007
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`Ex.1008
`Ex.1009
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`Ex.1010
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`Ex.1011
`Ex.1012
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`Ex.1013
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`Ex.1014
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`Ex.1015
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`Ex.1016
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`Ex.1017
`Ex.1018
`Ex.1019
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`PETITIONER’S EXHIBIT LIST
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`U.S. 9,806,565
`
`Prosecution History of U.S. 9,806,565
`
`Declaration of Dr. Joshua Phinney under 37 C.F.R. § 1.68
`Curriculum Vitae of Dr. Joshua Phinney
`
`U.S. 8,941,352 to Hong
`U.S. 8,922,162 to Park et al.
`
`U.S. 2009/0021212 to Hasegawa et al.
`
`U.S. 2012/0274148 to Sung et al.
`U.S. 8,427,100
`
`U.S. 8,687,536
`
`Websters II New College Dictionary: Third Edition, (2005)
`U.S. 8,339,798 to Minoo et al.
`
`U.S. 7,375,609
`
`U.S. 8,164,001
`Scheduling Order, Scramoge Technology Limited v. Apple Inc.,
`WDTX-6-21-cv-00579 (filed Sept. 28, 2021)
`Plaintiff’s Preliminary Disclosure of Asserted Claims and
`Infringement Contentions to Apple Inc., Scramoge Technology
`Limited v. Apple Inc., WDTX-6-21-cv-00579 (served Sept. 7, 2021)
`
`U.S. 8,643,219
`U.S. 2011/0050164
`U.S. 9,252,611
`
`1
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`I.
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`INTRODUCTION
`Patent Owner’s Response (“Response,” Paper 19) fails to overcome the
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`showing of obviousness in the Petition because it is based upon a claim
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`construction that does not actually distinguish the prior art. Patent Owner urges
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`the Board to construe the claimed “substrate comprising a receiving space” and
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`“connecting unit” to be “separate and distinct components”—yet the Petition
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`points to separate and distinct components for these elements in the Hong
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`reference. Moreover, Hong itself makes clear that its connecting unit is “formed
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`in” its separately identified receiving space. Accordingly, Petitioner requests that
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`the Board confirm its preliminary finding of unpatentability.
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`II. NO CLAIM CONSTRUCTION IS NECESSARY BECAUSE THE
`PETITION POINTS TO SEPARATE AND DISTINCT
`COMPONENTS FOR THE “SUBSTRATE COMPRISING A
`RECEIVING SPACE” AND “CONNECTING UNIT”
`Patent Owner requests that the Board “construe independent claims 1 and 12
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`to require two separate and distinct components for the ‘substrate comprising a
`
`receiving space’ and ‘connecting unit’” based on an alleged “claim construction
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`dispute between the parties.” Response, 8. This alleged dispute, however, is
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`predicated on a mistaken understanding of the Petition. Specifically, Patent Owner
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`asserts that Petitioner relies on the same elements to satisfy the “substrate
`
`comprising a receiving space” and “connecting unit”:
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`2
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`Petitioner and its expert, Dr. Phinney, rely on Hong’s disclosure
`of a rectifying unit 13 and “through via holes 25a, 25b, and 25c
`and a wiring layer 27 formed on the main circuit board 20” to
`satisfy the “connecting unit” limitation. With respect to the
`“substrate comprising a receiving space” limitation, Petitioner
`and Dr. Phinney also rely on the “through via holes 25a, 25b, and
`25c and a wiring layer 27 formed on the main circuit board 20.”
`Because Petitioner relies on the same structural elements to
`satisfy claim limitations that are required to be separate and
`distinct, Petitioner is unable to establish invalidity as to these
`claims or any of the challenged dependent claims.
`
`Response, 20 (emphasis in original). A plain reading of the Petition illustrates that
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`Patent Owner is wrong.
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`For the claimed “connecting unit,” the Petition points to Hong’s “rectifying
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`unit13” and “wiring layer 27”:
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`3
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`Petition, 30 (highlighting added). The Petition illustrates this mapping with an
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`annotated version of Fig. 4 of Hong:
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`Petition, 31. For the claimed “receiving space,” the Petition separately points to
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`the “via holes 25a, 25b, and 25c and the space extending between them” that
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`“receives the wiring layer 27” (connecting unit):
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`4
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`Petition, 32 (citing Ex.1005, 5:7-24 (“the wiring layer 27 formed in via holes 25a,
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`IPR2022-00350 / U.S. Patent No. 9,806,565
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`25b, and 25c, which are formed on inner layers 23 of the main circuit board 20”))
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`(highlighting added). The Petition provides an annotated version of Fig. 4 of Hong
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`that shows the wiring layer 27 (connecting unit) extending through the via holes
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`25a, 25b, and 25c and the space connecting them:
`
`
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`Petition, 33.
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`Accordingly, Petitioner relies on separate and distinct elements to satisfy the
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`claimed “substrate comprising a receiving space” and “connecting unit,” and no
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`actual claim construction dispute exists. If, however, the Board elects to adopt
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`Patent Owner’s desired claim construction, Hong would of course still meet such a
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`construction because it teaches a separate and distinct connecting unit disposed
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`within a receiving space, as illustrated in the Petition.
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`5
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`IPR2022-00350 / U.S. Patent No. 9,806,565
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`III. THE PETITION ESTABLISHES THAT HONG TEACHES A
`“SUBSTRATE COMPRISING A RECEIVING SPACE” AND A
`SEPARATE “CONNECTING UNIT [THAT] IS DISPOSED IN THE
`RECEIVING SPACE” (CLAIMS 1 AND 12)
`The Petition and Dr. Phinney’s supporting declaration demonstrate that
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`Hong teaches a “substrate comprising a receiving space” and a separate and
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`distinct wiring layer (“connecting unit”) disposed in the receiving space. In
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`particular, the Petition and Dr. Phinney’s declaration establish that Hong’s wiring
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`layer 27 and rectifying unit 13 together teach the “connecting unit.” Petition, 30-
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`32 (citing Ex. 1005, 4:53-67, 5:7-24, Fig. 3, Fig. 4); Ex. 1003 ¶¶ 64-66. The
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`Petition and Dr. Phinney’s declaration further establish that the space within
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`Hong’s substrate that is filled with its wiring layer (and thus not the substrate
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`material) teaches a “receiving space” within a substrate. Petition, 32-33; Ex. 1003
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`¶¶ 67-68.
`
`Patent Owner’s Response fails to rebut this prima facie showing of
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`obviousness because it ignores (i) that Hong explicitly and consistently
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`distinguishes the wiring layer (connecting unit) as a separate element “formed in”
`
`its receiving space; and (ii) that the challenged claims are apparatus claims that are
`
`broad enough to encompass a wiring layer embedded in a space within a substrate.
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`6
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`A. Hong is explicit that its wiring layer (connecting unit) is a separate
`element “formed in” its receiving space
`The Response alleges that “Petitioner relies on the same structural elements
`
`to satisfy claim limitations that are required to be separate and distinct.” Response,
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`20. In particular, the Response alleges:
`
`Petitioner and its expert, Dr. Phinney, rely on Hong’s disclosure
`of a rectifying unit 13 and “through via holes 25a, 25b, and 25c
`and a wiring layer 27 formed on the main circuit board 20” to
`satisfy the “connecting unit” limitation. With respect to the
`“substrate comprising a receiving space” limitation, Petitioner
`and Dr. Phinney also rely on the “through via holes 25a, 25b, and
`25c and a wiring layer 27 formed on the main circuit board 20.”
`
`Response, 20 (emphasis in original). However, as previously noted in Section II, a
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`plain reading of the Petition illustrates that the Patent Owner is wrong.
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`First, neither the Petition nor Dr. Phinney’s declaration ever relies on the via
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`holes 25a, 25b, and 25c as a structural element to establish that Hong teaches the
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`“connecting unit,” instead relying on Hong’s wiring layer 27 and rectifying unit
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`13. See Petition, 30 (citing Ex.1005, 4:53-67; 5:17-22), 31 (citing Ex. 1005, 5:7-
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`24, Fig. 3, Fig. 4); Ex. 1003, ¶¶ 64-66. Hong’s wiring layer 27 and rectifying unit
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`13 (together the “connecting unit”) form an electrical connection that carries power
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`received by the coil unit to the battery charging circuit. See Ex. 1005, 4:53-67;
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`5:17-22; Petition, 30-32.
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`7
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`Petitioner’s Reply to Patent Owner’s Response
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`Wiring layer
`(part of connecting unit)
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`Rectifying unit
`(part of connecting unit)
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`Coil unit
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`Ex.1005, Fig. 4 (cropped, annotated); Ex.1003, ¶ 65.
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`Rectifying unit 13
`(part of connecting unit)
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`Charging unit 15 to
`charge battery
`
`Coil unit
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`
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`Ex.1005, Fig. 3 (cropped, annotated); Ex.1003, ¶ 64.
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`Second, neither the Petition nor Dr. Phinney’s declaration rely on the wiring
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`layer 27 as a structural element to establish that Hong teaches a “substrate
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`comprising a receiving space.” The Petition initially describes how the layers of
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`8
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`Hong’s main circuit board 20 upon which and through which various elements are
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`IPR2022-00350 / U.S. Patent No. 9,806,565
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`formed are a “substrate.” Petition, 28-29. The Petition then explains how the via
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`holes 25a, 25b, and 25c formed in Hong’s main circuit board 20 and the space
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`extending between these via holes teach the claimed “receiving space.” Petition,
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`32-33. Hong’s receiving space is formed within the layers of the main circuit
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`board 20 and is the space within its substrate that would otherwise be empty and
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`void of any substrate material but for the wiring layer 27 that is “formed in” and
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`thereby disposed in it. See Ex.1005, 5:7-24, Fig. 4; Petition, 32-33.
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`Wiring layer 27 extending through
`receiving space in circuit board
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`Ex.1005, Fig. 4 (cropped, annotated); Ex.1003, ¶ 67.
`
`
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`Importantly, Hong explicitly distinguishes that the wiring layer is a separate
`
`and distinct element that is “formed in” its receiving space. Ex. 1005, 7:24 (“the
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`wiring layer 27 formed in via holes 25a, 25b, and 25c, which are formed on inner
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`layers 23 of the main circuit board 20” (emphasis added)); Petition, 32-33; Ex.
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`1003, ¶¶ 67. The via holes 25a, 25b, and 25c, which are used to form Hong’s
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`9
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`receiving space, necessarily exist prior to the wiring layer 26 being “formed in”
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`these via holes. See Ex. 1005, 7-24. The wiring layer being “formed in” the via
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`holes does not change that the wiring layer itself is separate and distinct from the
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`via holes. The via holes do not cease to exist. And to the extent Patent Owner’s
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`“separate and distinct” argument is predicated on the fact that the wiring layer is
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`disposed within Hong’s receiving space, the claims require such a relationship.
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`See, e.g., Ex.1001, Claim 1 (“wherein the connecting unit is disposed in the
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`receiving space”), Claim 12 (same).
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`Thus, Hong itself is explicit that the structural elements relied on by the
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`Petition to meet the “connecting unit” are separate and distinct from the structural
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`elements relied on by the Petition to meet the “substrate comprising the receiving
`
`space.”
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`B.
`
`The challenged claims are sufficiently broad that a wiring layer
`embedded within a substrate teaches a connecting unit disposed in
`the receiving space
`The Response further attempts to read limitations into the claims that are
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`simply not there. But in patent law, “the name of the game is the claim.” In re
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`Hiniker Co., 150 F.3d 1362, 1369 (Fed. Cir. 1998). Hong’s connecting unit and its
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`receiving space meet the broad limitations of the challenged apparatus claims.
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`First, Patent Owner contends that “Hong, however, makes clear that the
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`disclosed wiring layer is part of the substrate and not a feature of a separate and
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`10
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`distinct ‘connecting unit’” and that “[t]he inner layer wiring/traces are part of the
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`circuit board, and thus part of the substrate.” Response, 29. Patent Owner’s
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`argument is based on the fallacy that the wiring layer somehow consists of the via
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`holes. Response, 29 (“the wiring layer 27—consisting inter alia of the circuit
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`board wiring and the via holes”). As already shown, Hong is unequivocal that the
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`wiring layer is separate and distinct from the receiving space in which it is formed.
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`Ex. 1005, 7:24 (“the wiring layer 27 formed in via holes 25a, 25b, and 25c, which
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`are formed on inner layers 23 of the main circuit board 20” (emphasis added)).
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`Patent Owner further ignores that the challenged claims are broad
`
`apparatus claims that recite structural elements that are unconcerned with any
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`manufacturing or assembly steps that may have been used to arrive at these
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`structure elements. The challenged independent claims recite only three
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`limitations with respect to the receiving space and the connecting unit: (i) “a
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`receiving space of a predetermined shape formed therein for a connecting unit”;
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`(ii) “the connecting unit is disposed in the receiving space”; and (iii) “the
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`connecting unit overlaps the receiving space . . . .” Ex. 1001, Claim 1, Claim 12
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`(same). The Petition establishes that Hong’s receiving space and its connecting
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`unit meet each of these broad structural limitations. Petition, 32-33, 42-44.
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`Second, Patent Owner alleges that “[b]ecause the inner layer wiring/traces
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`are formed when the substrate is formed, they cannot simultaneously be part of the
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`11
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`‘connecting unit’ and be the ‘receiving space.’” Response, 29. But Patent Owner
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`cannot read method of manufacturing limitations into the challenged apparatus
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`claims. Hong’s wiring layer is simply “disposed in the receiving space.” See Ex.
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`1005, 7:-24, Fig. 4. That the wiring layer becomes “disposed in” Hong’s receiving
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`space by being “formed in” Hong’s receiving space is irrelevant to the obviousness
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`analysis for this structural limitation. The challenged claims are apparatus claims
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`that do not recite or require any kind of timing with respect to when the structural
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`elements of the claims came into existence.
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`Third, Patent Owner contends that “[t]here is no ‘receiving space’ formed in
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`Hong’s substrate (circuit board 20) and, consequently, there is no ‘receiving space’
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`in which the ‘connecting unit is disposed.’” Response, 29-30. The challenged
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`claims simply require a “substrate comprising a receiving space of a
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`predetermined shape formed therein for a connecting unit.” Hong’s receiving
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`space in its substrate comprises via holes 25a, 25b, and 25c and the space between
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`them that necessarily does not include substrate material because the wiring layer
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`27 is “formed” therein. See Ex.1005, 5:17-24, Fig. 4; Petition, 32-33; Ex. 1003
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`¶¶ 67-68. Hong teaches the via holes and wiring layer are formed “according to a
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`designed condition” (i.e., they are predetermined). See Ex.1005, 5:17-24; Petition,
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`32-33. To the extent Patent Owner is attempting to read in a limitation about how
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`the receiving space is formed, the claims do not require this.
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`12
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`Petitioner’s Reply to Patent Owner’s Response
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`Even so, Patent Owner blatantly ignores Hong’s explicit showing that the
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`
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`“the wiring layer 27 [is] formed in via holes 25a, 25b, and 25c, which are formed
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`on inner layers 23 of the main circuit board 20.” Ex. 1005, 17:-24, Fig. 4; Petition,
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`32-33. The via holes 25a, 25b, and 25c, which are used to form Hong’s receiving
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`space, are “formed on inner layers 23 of the main circuit board 20” and necessarily
`
`exist such that the wiring layer 27 can be “formed in” these via holes. Ex. 1005, 7-
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`24. The via holes do not cease to exist once the wiring layer is formed, they are
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`simply filled.
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`Fourth and lastly, Patent Owner argues that “[i]f Petitioner’s arguments were
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`correct, the ‘receiving space’ limitation would be rendered superfluous” and that
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`“[a]ny structure would necessarily occupy the ‘receiving space’ in which it is
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`formed.” Response, 30. This too Patent Owner gets wrong. Hong’s receiving
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`space in which the wiring layer is disposed is no more superfluous than the
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`“receiving space” of the challenged apparatus claims in which the “connecting
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`unit” is disposed.
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`Moreover, the only evidence in the record on this point confirms that a
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`POSITA would understand the need and purpose for the receiving space of Hong’s
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`substrate. As noted in the Petition and explained in Dr. Phinney’s Declaration,
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`“[i]t was well known to POSITAs in the electrical arts that when manufacturing
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`printed circuit boards that will contain embedded components, ‘recesses’ or
`
`13
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`‘openings’ (receiving spaces) are formed in the layers of the circuit board to
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`accommodate the embedded components.” Ex.1003, ¶ 68; Petition, 33.
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`Specifically, it was known that the “layers of [a] printed circuit board may be
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`provided with holes, slots, and other openings to accommodate embedded
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`components.” Ex. 1003, ¶ 68 (quoting Ex.1012, 2:24-28); see also Ex. 1012, 6:21-
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`37, 8:63-9:13, Fig. 3, Fig. 14. Dr. Phinney’s declaration provided the following
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`example of a layered printed circuit board having holes, slots, and other openings
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`to accommodate embedded components. Ex. 1003, ¶ 68 (citing Ex.1012, 2:24-28,
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`Fig. 3).
`
`Ex.1012, Fig. 3
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`
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`Thus, each of Patent Owner’s arguments fail because Hong explicitly
`
`identifies the wiring layer (connecting unit) as a separate element “formed in” its
`
`14
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`receiving space and because the challenged claims are apparatus claims that are
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`broad enough to encompass a wiring layer embedded in a space within a substrate,
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`irrespective of how and when the wiring layer is formed.
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`IV. HONG TEACHES THAT ITS CONNECTING UNIT IS SEPARABLE
`FROM ITS RECEIVING SPACE (CLAIM 13)
`The Petition establishes that Hong’s connecting unit is separable from its
`
`receiving space. Patent Owner’s Response does not rebut this prima facie showing
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`of obviousness because (i) claim 13 does not require that only the portion of the
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`connecting unit that is disposed in the receiving space be separable and (ii) the
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`rectifying unit is separable from the receiving space under the broad plain and
`
`ordinary meaning of the term “separable.”
`
`A. Claim 13 broadly recites separability without requiring that the
`entire “connecting unit” be “separable” from the “receiving space”
`Patent Owner alleges that “[w]hile the rectifying unit may be separable from
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`the circuit board 20, the remainder of the alleged ‘connecting unit,’ including the
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`wiring layer 27 that Dr. Phinney and the Petition rely on as supposedly ‘disposed
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`in the receiving space,’ is not separable from the circuit board 20 (the ‘substrate’).”
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`Response, 31. Claim 13 does not require that the entire “connecting unit” be
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`separable from the receiving space. Thus, regardless of whether or not the wiring
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`layer is separable from the receiving space, claim 13’s limitation is met by Hong’s
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`rectifying unit, which is separable from the receiving space.
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`15
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`Patent Owner further argues that “neither Dr. Phinney nor the Petition allege
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`
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`that the rectifying unit is disposed in the supposed ‘receiving space.’” Response,
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`31-32. But claim 13 similarly does not require that the portion of the connecting
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`unit that is “disposed in the receiving space” be separable from the receiving
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`space. Claim 13 is sufficiently broad to encompass any portion of the connecting
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`unit being separable from the receiving space.1
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`B. Hong’s rectifying unit is separable from its receiving space
`The term “separable” is a broad term whose plain and ordinary meaning can
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`encompass any multitude of possibilities for how one component is capable of
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`being separated from another component. The specification neither provides
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`guidance nor places any limitations on what the term “separable” means in the
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`context of claim 13. The specification only “describes (in association with Figs.
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`11-13) that the connecting unit 300 is secured within the receiving space 130 by
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`soldering the connection terminals of the connecting unit to the connection
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`1 This aligns with the language of claims 1 and 12, which does not require that the
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`entirety of the “connecting unit is disposed in the receiving space” and is consistent
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`with the figures in the ’565 Patent that show a portion of the connecting unit 300
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`being disposed outside of the receiving space 130. See, e.g., Ex. 1001, Fig. 12,
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`Fig. 27.
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`16
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`
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`terminals of the coil unit 200.” Petition, 59 (citing Ex. 1003 ¶ 122). Thus, the
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`claimed “connecting unit configured such that it is separable” at least encompasses
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`a connecting unit that is secured within the receiving space by solder. Petition, 59
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`(citing Ex.1003, ¶ 122).
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`Hong’s rectifying unit 13, which forms a portion of its connecting unit, is in
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`direct contact with via hole 25c, which forms a part of Hong’s receiving space, as
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`illustrated below in Fig. 4. Ex. 1005, Fig. 4. Hong explains that the “connection
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`between the secondary coil unit 11 and the rectifying unit 13 may be achieved
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`through via holes 25a, 25b, and 25c and a wiring layer 27 formed on the main
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`circuit board 20.” Ex. 1005, 5:7-10; Petition, 59. The connecting terminal 13b of
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`the rectifying unit 13 maintains contact with the wiring layer 27 in via hole 25c and
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`thereby, with via hole 25c, to maintain its electrical connection with the coil that is
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`connected to the wiring layer 27. See Ex. 1005, 5:17-24, Fig. 4.
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`17
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`Wiring layer 27 extending through
`receiving space in circuit board
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`Ex.1005, Fig. 4 (cropped, annotated); Ex.1003, ¶ 67.
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`Simply removing the rectifying unit such that it is no longer in direct contact with
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`the via hole 25c (receiving space) is one example way in which the rectifying unit
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`13 is separable from Hong’s receiving space. Accordingly, Hong renders obvious
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`that “the connecting unit is configured such that it is separable from the receiving
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`space.”
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`V. CONCLUSION
`For the foregoing reasons, Patent Owner’s arguments in its Response should
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`be rejected, and the challenged claims should be found unpatentable.
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`Respectfully submitted,
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`
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`/Scott T. Jarratt/
`Scott T. Jarratt
`Lead Counsel for Petitioner
`Registration No. 70,297
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`Dated: January 30, 2023
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`
`
`Customer No. 27683
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`18
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
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`
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`CERTIFICATE OF WORD COUNT
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`Pursuant to 37 C.F.R. § 42.24(d), Petitioner hereby certifies, in accordance
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`with and reliance on the word count provided by the word-processing system used
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`to prepare this petition, that the number of words in this paper is 3,110. This word
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`count excludes the table of contents, table of authorities, mandatory notices under
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`§42.8, certificate of service, certificate of word count, signature block, and
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`appendix of exhibits. See 37 C.F.R. §42.24(c).
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`/Scott T. Jarratt/
`Scott T. Jarratt
`Lead Counsel for Petitioner
`Registration No. 70,297
`
`
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`19
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`IPR2022-00350 / U.S. Patent No. 9,806,565
`Petitioner’s Reply to Patent Owner’s Response
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that, in accordance with 37 C.F.R. § 42.6(e),
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`service was made on Patent Owner as detailed below.
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`
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`Date of service January 30, 2023
`Manner of service Electronic Mail: bcooper@bc-lawgroup.com;
`ap@lombardip.com; ehuang@lombardip.com;
`jpetrsoric@bc-lawgroup.com;
`Scramoge_Counsel@b-clg.com
`Documents served Petitioner’s Reply to Patent Owner’s Response
`Brett Cooper
` Persons served
`John Petrsoric
`BC Law Group, P.C.
`200 Madison Avenue, 24th Floor
`New York, NY 10016
`
`Antonio Papageorgiou
`Eric Huang
`Lombard & Geliebter LLP
`230 Park Avenue, 4th Floor West
`New York, NY 10169
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`
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`/Scott T. Jarratt/
`Scott T. Jarratt
`Lead Counsel for Petitioner
`Registration No. 70,297
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`20
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