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
`
`________________
`
`SECOND SUPPLEMENTAL DECLARATION
`OF JOSHUA PHINNEY, PH.D., UNDER 37 C.F.R. § 1.68
`
`Ex.1026 / IPR2022-00350 / Page 1 of 34
`APPLE INC. v. SCRAMOGE TECHNOLOGY LTD.
`
`

`

`TABLE OF CONTENTS
`Introduction ...................................................................................................... 3 
`A.  
`B.   A POSITA would have found substitute claims 21-23 obvious over
`Park in view of Motoharu. ............................................................................... 4 
`a. 
` Detailed Analysis ................................................................................. 4 
`Declaration ..................................................................................................... 34 
`
`C. 
`
`
`
`
`
`
`
`2
`
`Ex.1026 / IPR2022-00350 / Page 2 of 34
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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 declarations.
`
`See Ex.1003; Ex.1004; Ex.1024.
`
`2.
`
`In the preparation of this declaration, I have studied the materials
`
`noted in my previous declarations, as well as the following additional materials:
`
`(1) Ex.1025 – Certified English Translation of Japanese Patent
`
`Publication H4-51115 to Motoharu et al. (“Motoharu”), Japanese
`
`Language Version of H4-51115, and the Translation Certificate, and
`
`(2) Ex.1027 –U.S. Patent Publication No. 2007/0069961 to Akiho et al.
`
`(“Akiho”).
`
`3.
`
`In forming the opinions expressed below, I have considered: 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
`
`
`
`3
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`experience in the field of wireless charging.
`
`B. A POSITA would have found substitute claims 21-23 obvious over Park
`in view of Motoharu.
`4.
`I have been asked to provide my opinion as to whether Substitute
`
`Claims 21, 22, and 23 in Patent Owner’s Revised Motion to Amend (“Motion,”
`
`Paper 25) would have been obvious in view of prior art. The discussion below
`
`provides a detailed analysis of how U.S. Patent No. 8,922,162 to Park et al.
`
`(“Park,” Ex. 1006) in view of H4-51115 to Motoharu et al. (“Motoharu,” Ex.1025)
`
`renders obvious the limitations of the substitute claims.
`
`a. Detailed Analysis
`The following claim chart describes how the Park reference in view of
`
`5.
`
`the Motoharu reference renders obvious the Substitute Claims 21, 22, and 23.
`
`Prior Art
`Park discloses: “a wireless power receiver.”
`
`Claim 21
`[21.0] A
`wireless power
`receiver,
`comprising:
`
`
`
`
`
`
`
`4
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`coil module 103
`(wireless power receiver)
`
`Ex.1006, Figs. 1 and 2 (annotated)
`
`
`
`Specifically, as shown above in Figs. 1 and 2, Park discloses a
`“coil module 103” (wireless power receiver), where “a portable
`terminal [] implements both a wireless charging function and an
`NFC function using the coil module 103.” Ex.1006, 3:4-11, 4:60-
`65.
`Park in view of Motoharu 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.”
`
`Figures 2 and 3 of Park are annotated below.
`
`
`
`5
`
`[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;
`
`
`
`NFC coil 135
`
`wireless charging
`coil 133
`shielding member 131
`(substrate)
`Ex.1006, Figs. 2 and 3 (annotated)
`
`
`
`Park describes that its coil module includes “shielding member
`131” (substrate) on which coils 133 and 135 are disposed.
`
`The shielding member 131 is made of a “mixture of metal powder
`containing an iron (Fe) component and synthetic resin” and
`includes “first and second accommodation grooves 141 and 142
`on a surface” to accommodate the coils 133 and 135, as illustrated
`in Fig. 3. Ex.1006, 3:35-47.
`
`“One of the first and second coils 133 and 135 may be used as a
`secondary coil for wireless charging and the other coil may be
`used as an NFC antenna element. The coils 133 and 135 may also
`be used as antennas for short-range wireless communications.”
`Ex.1006, 4:16-24.
`
`To the extent Park does not teach that its shielding member
`includes a receiving space of a predetermined shape formed
`therein for a discrete connecting unit as claimed, a POSITA would
`have found it obvious for Park’s shielding member to include such
`a receiving space—for example to further minimize the thickness
`of the coil module, as further explained below.
`
`In the art of induction-based devices, it was already well known to
`utilize a discrete connecting unit to connect inductive coils to
`
`
`
`6
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`power receiving circuits, where the connecting unit is disposed in
`a receiving space in the substrate below the coils.
`
`As one example, Motoharu teaches an inductive coil rotary
`transformer with a substantially similar design as the design in
`Park. See Ex.1025, Fig. 1.
`
`In particular, as illustrated below in Figs. 1 and 2 of Motoharu,
`Motoharu teaches that its rotary transformer includes a “disc-
`shaped ferrite core 1” with “coil placement grooves 2” in which
`“spiral shape” coils are placed. Ex.1025, 4.
`
`inductive coils in grooves 2
`
`disc-shaped ferrite core 1
`(substrate)
`Ex.1025, Figs. 1 and 2 (annotated)
`
`
`
`
`Motoharu further teaches that—to achieve a thinner profile—the
`ferrite core substrate includes a “board mounting groove 5 …
`extending in the radial direction,” where a “flexible board 4 is
`attached to this board mounting groove 5.” Ex.1025, 4.
`
`As such, Figs. 1 and 2 illustrate the board mounting groove 5
`(reception space) formed in the ferrite core (substrate) and the
`flexible board 4 (connecting unit) disposed in the board mounting
`groove.
`
`
`
`7
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`board mounting groove 5 (receiving space)
`
`flexible board 4 within groove 5
`(connecting unit)
`
`
`
`Ex.1025, Figs. 1 and 2 (annotated)
`Motoharu explains that the groove 5 in ferrite core is specifically a
`“board mounting groove” and is thus of a predetermined shape
`to accommodate the flexible board 4. Ex.1025, 4, 6.
`
`It is my opinion that a POSITA would have been motivated to
`apply Motoharu’s groove and board technique to Park’s coil
`module and would have had a reasonable expectation of success
`doing so. As an initial matter, a POSITA, when considering the
`teachings of Park, would have also considered the teachings of
`Motoharu.
`
`Motoharu is analogous prior art pertaining to the same field of
`endeavor, namely, wireless power transfer via electromechanical
`induction. Because Motoharu describes a “transformer,” the
`conductive coils in Motoharu receive power via induction.
`Ex.1025, 3-4, Figs. 1-2. Similarly, in Park, the coil module
`receives power via induction to implement the wireless charging.
`Ex.1006, 3:4-11, 4:60-65, 3:35-47, Figs. 2-3. It is my opinion that
`a POSITA evaluating Park would have also evaluated references
`like Motoharu because all such references describe induction-
`based coil modules having multiple coils disposed on a substrate
`that wirelessly receive power. Ex.1006, 3:4-11, 4:60-65, 3:35-47,
`Figs. 2-3; Ex.1025, 3-4, Figs. 1-2. As such, both Park and
`Motoharu are analogous art to the ’565 patent, which also
`describes an induction-based device having multiple coils
`
`
`
`8
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`disposed on a substrate that wirelessly receive power. Ex.1001,
`Abstract, Fig. 26.
`
`Park explains that one of its goals is to “minimiz[e]” the thickness
`of the portable terminal in which its coil module is disposed.
`Ex.1006, 5:57-61. I note that minimizing the thickness of a
`wireless charging coil module within a portable terminal was a
`common goal prior to the ’565 patent. See Ex.1008, [0013](stating
`a “need to develop a contactless power transmission device having
`a reduced thickness”), [0015]-[0017]; Ex.1007, [0023] (describing
`“a coil unit that exhibits excellent heat dissipation capability and
`can be reduced in thickness), [0089]. Although Park attempts to
`achieve this goal by positioning its charging coil and NFC coil on
`a “same plane” (Ex.1006, 5:57-61, 3:56-59), POSITAs understood
`that there were additional methods to further minimize the
`thickness of inductive coil modules configured like Park’s.
`
`Motoharu teaches a technique to further reduce the thickness of a
`transformer coil module having accommodation grooves for
`multiple, concentric coils like Park’s. Ex.1025, 2-3 (“As the
`equipment in which rotary transformers are incorporated becomes
`smaller, there is a strong demand for smaller and thinner rotary
`transformers. When a conventional structure of a thin type is
`considered, it is necessary to reduce the thickness of the disc-
`shaped ferrite core, the thickness of the flexible board, and the
`height of the soldering process for the leads.”) Specifically,
`Motoharu teaches that a “thinner profile” may be achieved by
`replacing conventional coil leads (such as those in Park) with coil
`leads that connect to a flexible circuit board disposed in a “board
`mounting groove” below the coils. Ex.1025, 4-5, Figs. 1-2. The
`groove extends “in the radial direction” from the inside of the coils
`to the outside of the coils to accommodate the circuit board.
`Ex.1025, 4-5, Figs. 1-2. This groove and board technique is
`particularly suitable for coil modules with ferrite-based substrates
`(like Motoharu’s and Park’s) because simply thinning the
`substrate to reduce thickness weakens the substrate. Ex.1025, 3
`(stating “due [to] the problem of strength, there were limits to how
`thin the disc-shaped ferrite cores can be made”); Ex.1019, 1:51-62
`
`
`
`9
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`(“However, in the case that a ferrite sheet is processed thinly, the
`thinly processed ferrite sheet may be easily broken and weak in
`impact resistance.”).
`
` POSITA would therefore have been motivated to apply
`Motoharu’s groove and board technique to Park’s substantially
`similar coil module to achieve a similar thinner profile. In
`particular, a POSITA would have found it obvious to similarly
`form a board mounting groove in Park’s shielding member and to
`connect Park’s coils 133 and 135 to a flexible circuit board
`disposed in the board mounting groove, in the manner taught by
`Motoharu. Doing so would have further advanced Park’s goal of
`minimizing portable device thickness.
`
`It is also my opinion that a POSITA would have had a reasonable
`expectation of success in applying Motoharu’s technique to Park’s
`coil module and would have found the combination predictable.
`First, the combination utilizes Motoharu’s groove and board
`technique precisely as it was intended—to further thin an
`inductive coil module. Second, prior to the ’565 patent, it was
`already predictable to utilize a groove and board technique, like
`Motoharu’s, in a coil module within a portable device, like Park’s.
`See Ex.1027, Fig. 1, [0036]-[0042] (describing a recess in a
`magnetic core for a connecting unit that connects to a coil
`antenna)). Third, because Park’s inductive device is physically and
`operationally similar to Motoharu’s (i.e., they are both inductive
`devices with multiple coils disposed in grooves of an iron-based
`substrate), implementation of the modification would have been
`well within the skill of a person of ordinary skill in the art in 2012.
`In that regard, Motoharu explains that its technique may be
`adapted by a POSITA as needed. Ex.1025, 5 (“The depth of the
`board mounting groove is determined by considering the thickness
`of the board and the thickness when the coil leads are connected
`and fixed.”).
`
`Therefore, the combination of Park and Motoharu simply
`represents the application of Motoharu’s known technique to
`improve Park’s similar device in the same way.
`
` A
`
`
`
`10
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`
`With respect to the recitation that the claimed connecting unit be
`“configured to connect to a wireless power receiving circuit,”
`Park teaches that its coil module (and specifically the wireless
`charging coil 133) connects to a wireless charging integrated
`circuit (“WC IC”) in the portable terminal 100, as shown in Figs. 4
`and 5. Ex.1006, 5:11-26 (explaining that the WC IC “control[s]
`current and voltage during charging”).
`
`wireless
`charging
`coil 133
`
`portable device
`
`WC IC
`(wireless power
`receiving circuit)
`
`Ex.1006, Figs. 4 and 5 (annotated)
`
`Motoharu further explains that when a flexible board is utilized in
`induction devices, the flexible board connects to “an external
`circuit.” Ex.1025, 2 (“Then, a protrusion 36 extending from the
`flexible board 35 is used to connect the flexible board to an
`external circuit.”). When Park’s coil module is modified to utilize
`a flexible board connecting unit, as noted above, Park’s flexible
`board would similarly be configured to connect to Park’s WC IC
`in the portable device to transfer the power received by the
`wireless charging coil.
`
`Park in view of Motoharu discloses “a coil unit disposed on the
`substrate, the coil unit comprising a first connection terminal, a
`second connection terminal, and a coil.”
`
`
`In particular, as discussed above in [21.1], Park teaches that its
`coil module 103 includes a wireless charging coil 133 disposed on
`
`11
`
`[21.2] a coil unit
`disposed on the
`substrate, the
`coil unit
`comprising a
`first connection
`terminal, a
`
`
`
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`the shielding member 131 (substrate), as shown below.
`
`second
`connection
`terminal, and a
`coil;
`
`
`
`wireless charging
`coil 133
`
`shielding member 131
`(substrate)
`
`Ex.1006, Figs. 2 and 3 (annotated)
`
`
`
`When Park’s coil module is modified in view of Motoharu, it
`would have been obvious for Park’s coil 133 to utilize connection
`terminals to connect the coil to the flexible board disposed below.
`
`Specifically, Motoharu teaches that in its technique, each
`inductive coil includes two “terminals” or “leads 3” (connection
`terminals) that are “soldered to the connecting leads on the
`flexible board 4.” Ex.1025, 4. This is illustrated in Fig. 1, which
`shows a lead 3 at the inner end and a lead 3 at the outer end of
`each coil.
`
`leads 3
`
`Ex.1025, Fig. 1 (cropped and annotated)
`
`
`
`12
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`
`Accordingly, when Motoharu’s techniques are applied to Park, it
`would have been obvious for Park’s wireless charging coil 133 to
`include first and second leads (connection terminals) to connect to
`a flexible board, as taught by Motoharu.
`
`As such, Park’s coil 133 and first and second leads together would
`be a coil unit, as claimed.
`
`Park discloses: “short-range communication antenna disposed on
`the substrate and surrounding the coil.”
`
`As discussed above in [21.1], Park teaches that a coil 135 for
`“short-range wireless communication,” such as NFC, “surrounds”
`wireless charging coil 133, where the two coils are disposed on the
`same substrate 131. Ex.1006, 3:56-64, 4:15-24.
`
`
`Park discloses: “wherein the coil is configured to wirelessly
`receive power, wherein the coil is formed as a conductive pattern
`on or within the substrate.”
`
`In particular, the coil 133 of Park is a “coil for wireless charging”.
`The coil 133 is also “formed by spirally winding enamel-insulated
`conductor wires” at least two times on the shielding member 131
`(substrate), as shown in Figs. 3 and 4 (annotated above in [21.2]).
`Ex.1006, 4:15-24, 3:59-60.
`
`Park discloses: “wherein the conductive pattern comprises a
`conductive line wound at least two times and conductive pattern
`has a spiral shape, conductive pattern comprises a conductive line
`wound at least two times and conductive pattern has a spiral
`
`13
`
`[21.3] short-
`range
`communication
`antenna
`disposed on the
`substrate and
`surrounding the
`coil;
`
`[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;
`
`
`
`[21.5] wherein
`the conductive
`pattern
`comprises a
`conductive line
`
`
`
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`wound at least
`two times and
`conductive
`pattern has a
`spiral shape,
`
`
`
`shape.”
`
`The coil 133 in Park is “formed by spirally winding enamel-
`insulated conductor wires” at least two times on the shielding
`member 131 (substrate), as shown in Figs. 3 and 4 (annotated
`below). Ex.1006, 4:15-24, 3:59-60.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`wireless charging
`coil 133
`
`Ex.1006, Figs. 2 and 3 (annotated)
`
`[21.6] 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,
`
`
`
`Park in view of Motoharu discloses: “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 in [21.2], when Park is modified in view of
`Motoharu, it would have been obvious for a first lead 3 (first
`connection terminal) to be located at the outer end of the coil 133
`and for a second lead 3 (second connection terminal) to be located
`at the inner end of the coil 133, for connection to Park’s flexible
`board connecting unit. Ex.1025, 4, Fig. 1.
`
`
`
`
`
`
`
`
`
`14
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`
`
`[21.7] wherein
`the coil unit
`overlaps the
`receiving space,
`and wherein the
`coil unit is
`
`
`
`wireless
` charging
`coil 133
`
`leads 3
`
`Ex.1006, Fig. 2 (rotated and annotated)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Park in view of Motoharu 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.”
`
`Ex.1025, Fig. 1 (cropped and annotated)
`
`
`
`15
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`disposed on the
`substrate in a
`first direction
`perpendicular to
`the upper
`surface of the
`substrate,
`
`As illustrated by Figs. 1 and 2 of Motoharu below, when Park is
`modified in view of Motoharu, it would be obvious that Park’s
`coil 133 and inner and outer leads (together the coil unit) would
`overlap the board mounting groove 5 so that the leads may be
`soldered to the flexible board connecting unit within the board
`mounting groove 5. Ex.1025, 4.
`
`
`board mounting groove 5 (receiving space)
`
`inductive coil and leads overlapping
`board mounting groove 5
`
`Ex.1025, Figs. 1 and 2 (annotated)
`
`
`
`
`As illustrated in Park’s Fig. 3 (annotated in [21.2]), the coil 133
`disposed on the shielding member 131 (substrate) in a first
`direction perpendicular to the upper surface of the shielding
`member 131. Ex.1006, Fig. 3. To the extent there is any ambiguity
`as to the spatial relationship recited in this limitation, the spatial
`relationship between Park’s coil 133 and shielding member 131 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 Revised Motion. See Revised Motion at 6.
`
`Park in view of Motoharu 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
`space and
`connected to the
`
`
`
`As illustrated by Figs. 1 and 2 of Motoharu below, when Park is
`modified in view of Motoharu, it would be obvious for Park’s
`flexible board connecting unit to be disposed in the board
`mounting groove and connected to the leads of the coil 133.
`
`16
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`coil unit,
`
`
`
`Ex.1025, 4 (“the leads 3 of the coils are soldered to the connecting
`leads on the flexible board 4 in the board mounting groove 5”),
`(“the terminals of the coils are connected to the board”).
`
`
`board mounting groove 5 (receiving space)
`
`flexible board 4 within groove 5
`(connecting unit)
`
`coil connected to flexible board 4
`Ex.1025, Figs. 1 and 2 (annotated)
`
`[21.9] wherein
`the connecting
`unit overlaps
`the receiving
`space, the
`connecting unit
`extending in a
`second
`direction
`parallel to the
`upper surface of
`the substrate,
`and
`
`Park in view of Motoharu 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 by Fig. 2 of Motoharu (annotated below), when Park
`is modified in view of Motoharu, it would be obvious that Park’s
`flexible board (connecting unit) would overlap the board mounting
`groove (receiving space) and extend in a second direction parallel
`to the upper surface of the shielding member 131 (substrate).
`Ex.1025, 4.
`
`
`
`
`17
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`board mounting groove 5 (receiving space)
`
`flexible board 4 within groove 5
`(connecting unit)
`
`coil connected to flexible board 4
`Ex.1025, Figs. 1 and 2 (annotated)
`
`[21.10a]
`wherein the
`connecting unit
`comprises: a
`circuit board
`having a wiring
`layer;
`
`Park in view of Motoharu discloses: “wherein the connecting unit
`comprises: a circuit board having a wiring layer.”
`
`As shown in Figs. 1 and 2, Motoharu teaches that its “flexible
`board 4” is a circuit board with “connecting leads” and associated
`wiring layer. Ex.1025, 4.
`
`flexible board 4 with wiring layer
`(connecting unit)
` in groove 5
`
`Ex.1025, Figs. 1 and 2 (annotated)
`
`As illustrated by Figs. 1 and 2 of Motoharu (annotated above), it
`would be obvious to modify Park to include Motoharu’s flexible
`board (connecting unit) that has a circuit board with “connecting
`
`
`
`18
`
`Ex.1026 / IPR2022-00350 / Page 18 of 34
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`

`leads” and associated wiring layer. Ex.1025, 4.
`
`Park in view of Motoharu 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.”
`
`Motoharu teaches that the flexible board 4 (connecting unit)
`includes “connecting leads” (connection terminals) to which the
`“leads 3” of the coils (connection terminals) are “soldered.”
`Ex.1025, 4. This is illustrated in Fig. 1, which shows connecting
`leads on the flexible board connected to the first and second leads
`3 at the inner end and outer end of each coil.
`
`
`
`connecting leads of flexible
`board 4 (3rd and 4th connection
`terminals) connected to
`to leads 3 of coil (1st and 2nd
`connection terminals)
`
`[21.10b]
`[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,
`
`Ex.1025, Fig. 1 (cropped and annotated)
`
`Accordingly, when Motoharu’s techniques are applied to Park, it
`would be obvious that Park’s wireless charging coil 133 would
`include first and second leads (first and second connection
`terminals) that respectively connect to third and fourth connecting
`leads (third and fourth connection terminals) on a flexible board
`connecting unit, as taught by Motoharu.
`
`
`
`
`
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`[21.10c] the
`fourth
`connection
`terminal located
`at the other end
`of the coil that
`is at an inside
`portion of the
`conductive
`pattern
`
`Park in view of Motoharu discloses: “the fourth connection
`terminal located at the other end of the coil that is at an inside
`portion of the conductive pattern.”
`
`In particular, Figure 1 of Motoharu illustrates that one of the
`“connecting leads” of the flexible board 4 is located and connected
`to the coil lead 3 at an inside portion of the coil’s conductive
`pattern.
`
`connecting lead of flexible
`board 4 (4th connection
`terminal) located
`at inside portion of coil
`
`Ex.1025, Fig. 1 (cropped and annotated)
`
`
`
`Park in view of Motoharu discloses: “and wherein the connecting
`unit is otherwise separate from the first connection terminal, the
`second connection terminal, and the coil unit.”
`
`As shown below in Fig. 1 of Motoharu, the flexible board 4
`(connecting unit) is otherwise separate from the two leads 3 (first
`and second connection terminals) of the coil highlighted in green.
`For example, the flexible board 4 is only connected to the coil at
`the two leads 3:
`
`20
`
`[21.10d] and
`wherein the
`connecting unit
`is otherwise
`separate from
`the first
`connection
`terminal, the
`second
`connection
`terminal, and
`the coil unit.
`
`
`
`Ex.1026 / IPR2022-00350 / Page 20 of 34
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`

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`coil only connected to
`flexible board 4 at leads 3
`
`flexible board 4
`(connecting unit)
` in groove 5
`
`Ex.1025, Fig. 1 (annotated)
`
`Accordingly, when Motoharu’s techniques are applied to Park, it
`would be obvious that Park’s wireless charging coil 133 would
`include first and second leads (first and second connection
`terminals) that are separate from the flexible board (connecting
`unit).
`Prior Art
`Park renders obvious the limitation: “[a] wireless power
`receiver,” as described above in [21.0].
`
`
`
`
`Park in view of Motoharu 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; and,” as described
`above in [21.1].
`
`
`
`
`21
`
`Claim 22
`[22.0] A
`wireless power
`receiver,
`comprising:
`
`[22.1] a
`substrate
`comprising a
`receiving space
`of a
`predetermined
`shape formed
`therein for a
`discrete
`connecting unit
`configured to
`connect to a
`
`
`
`Ex.1026 / IPR2022-00350 / Page 21 of 34
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`wireless power
`receiving
`circuit; and
`
`
`[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
`
`
`
`Park in view of Motoharu renders obvious the limitation: “a coil
`unit comprising a first connection terminal, a second connection
`terminal, and a coil; and,” as described above in [21.2].
`
`
`
`
`Park renders obvious the limitation: “a short-range communication
`antenna disposed on the substrate and surrounding the coil,” as
`described in [21.3].
`
`
`
`
`
`
`
`
`
`
`
`Park 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].
`
`
`
`22
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`is formed as a
`conductive
`pattern on or
`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,
`
`
`
`Park 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].
`
`
`Park in view of Motoharu 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].
`
`
`
`
`
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`[22.7] wherein
`the connecting
`unit is disposed
`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;
`
`
`
`
`
`
`
`Park in view of Motoharu renders obvious the limitation: “wherein
`the connecting unit is disposed in the receiving space and
`connected to the coil unit,” as described above in [21.8].
`
`
`
`Park in view of Motoharu 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, and,” as described above in [21.9].
`
`
`
`Park in view of Motoharu renders obvious the limitation: “wherein
`the connecting unit comprises: a circuit board having a wiring
`layer,” as described in [21.10a].
`
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`[22.9b]
`[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,
`
`[22.9c] the
`fourth
`connection
`terminal located
`at the other end
`of the coil that
`is at an inside
`portion of the
`conductive
`pattern
`
`[22.9d] and
`wherein the
`connecting unit
`is otherwise
`separate from
`
`
`
`Park in view of Motoharu 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 [21.10b].
`
`Park in view of Motoharu renders obvious the limitation: “the
`fourth connection terminal located at the other end of the coil that
`is at an inside portion of the conductive pattern ,” as described in
`[21.10c].
`
`Park in view of Motoharu renders obvious the limitation: “and
`wherein the connecting unit is otherwise separate from the first
`connection terminal, the second connection terminal, and the coil;
`and,” as described in [21.10d].
`
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`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
`unit.
`
`
`
`Park in view of Motoharu renders obvious the limitation: “wherein
`the coil unit is disposed on the substrate and the connecting unit.”
`
`In particular, as illustrated in Figs. 2 and 3 (annotated below), Park
`teaches that the coil 133 is disposed on the shielding member 131
`(substrate).
`
`
`wireless charging
`coil 133
`
`shielding member 131
`(substrate)
`
`Ex.1006, Figs. 2 and 3 (annotated)
`
`
`
`
`Further, when Park is modified in view of Motoharu, it would be
`obvious that the leads of Park’s coil 133 would be