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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`____________
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`APPLE INC.,
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`Petitioner,
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`v.
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`SCRAMOGE TECHNOLOGY LTD.,
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`Patent Owner.
`
`____________
`
`Case IPR2022-00350
`
`Patent 9,806,565
`
`
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`_______________________________________________________________
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`REPLY TO PETITIONER’S OPPOSITION TO PATENT
`OWNER’S REVISED MOTION TO AMEND
`
`
`
`i
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`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`____________
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2022-00350
`
`Patent 9,806,565
`
`
`
`_______________________________________________________________
`
`REPLY TO PETITIONER’S OPPOSITION TO PATENT
`OWNER’S REVISED MOTION TO AMEND
`
`
`
`i
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`
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`Exhibit No.
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`Description
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`Paten Owner Exhibit List
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`2001
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`2002
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`2003
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`2004
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`2005
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`2006
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`2007
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`2008
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`2009
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`2010
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`2011
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`Notice of IPR Petitions, Scramoge Technology Ltd. v. Apple
`Inc., Case No. 6:21-cv-00579-ADA, Dkt. No. 35 (W.D. Tex.
`Nov. 11, 2021)
`
`Scheduling Order, Scramoge Technology Ltd. v. Apple Inc.,
`Case No. 6:21-cv-00579-ADA, Dkt. No. 33 (W.D. Tex. Sept.
`28, 2021)
`
`Law360 Article: West Texas Judge Says He Can Move Faster
`Than PTAB
`
`Text Order Denying Motion to Stay Pending IPR, Solas OLED
`Ltd. v. Google, Inc., Case No. 6:19-cv-00515-ADA (W.D. Tex.
`June 23, 2020)
`
`Order Denying Motion to Stay Pending IPR, Multimedia
`Content Management LLC v. DISH Network L.L.C., Case No.
`6:18-cv00207-ADA, Dkt. No. 73 (W.D. Tex. May 30, 2019)
`
`Scheduling Order, Correct Transmission LLC v. Adtran, Inc.,
`Case No. 6:20-cv-00669-ADA, Dkt. No. 34 (W.D. Tex. Dec. 10,
`2020)
`
`Scheduling Order, Maxell Ltd. v. Amperex Technology Ltd.,
`Case No. 6:21-cv-00347-ADA, Dkt. No. 37 (W.D. Tex. Nov. 8,
`2021)
`
`Standing Order Governing Proceedings in Patent Cases, Judge
`Alan D. Albright
`
`Claim Construction Order, Solas OLED Ltd. v. Apple Inc., Case
`No. 6:19-cv-00537-ADA, Dkt. No. 61 (W.D. Tex. Aug. 30,
`2020)
`
`Plaintiff Scramoge Technology Ltd.’s Amended Preliminary
`Disclosure of Asserted Claims and Infringement Contentions to
`Apple Inc. in Scramoge Technology Ltd. v. Apple Inc., Case
`No. 6:21-cv-00579-ADA (W.D. Tex.)
`
`Defendant Apple Inc.’s First Amended Preliminary Invalidity
`Contentions in Scramoge Technology Ltd. v. Apple Inc., Case
`No.6:21-cv-00579-ADA (W.D. Tex.)
`
`ii
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`
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`2012
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`2013
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`2014
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`2015
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`2016
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`2017
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`2018
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`2019
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`2020
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`2021
`
`Android Authority article: LG Innotek’s Latest wireless charger
`is Three times faster
`
`Scheduling Order, Scramoge Technology Ltd. v. Google LLC,
`Case No. 6:21-cv-00616-ADA, Dkt. No. 28 (W.D. Tex. Nov.
`15, 2021)
`
`Defendants’ Joint Reply Claim Construction Brief in Scramoge
`Technology Ltd. v. Apple Inc., Case No. 6:21-cv-00579-ADA
`(W.D. Tex.)
`
`Scheduling Order, Scramoge Technology Ltd. v. Apple Inc.,
`Case No. 6:21-cv-00579-ADA, Dkt. No. 56 (W.D. Tex. Feb. 11,
`2022)
`
`Declaration of John Petrsoric in Support of Motion for
`Admission Pro Hac Vice
`
`November 1, 2022 Deposition Transcript of Joshua Phinney,
`Ph.D.
`
`U.S. Patent No. 10,674,610
`
`Merriam-Webster Dictionary - Otherwise
`
`Merriam-Webster Dictionary - Discrete
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`Merriam-Webster Dictionary - Separate
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`
`
`
`
`iii
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`
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`Table of Contents
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. Status of Related Proceedings ............................................................................. 1
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`III. Overview of the ’565 Patent. .............................................................................. 2
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`IV. The Cited References .......................................................................................... 3
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`
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`
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`a.U.S. Patent No. 8,922,162 (“Park”). ................................................................ 3
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`b.Japanese application H4-51115 (“Motoharu”) ................................................ 4
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`V. PETITIONER HAS NOT SHOWN THAT PROPOSED CLAIMS 21-23 ARE
`UNPATENTABLE .................................................................................................... 4
`
`a. ...... Petitioner has not shown that Park in view of Motoharu teaches “discrete
`
`connecting unit” that “is otherwise separate from the first connection terminal, the
`second connection terminal, and the coil” of claims 21-23. ...................................... 5
`
`
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` i.Claim Construction. ..................................................................................... 5
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`b. ........... Petitioner’s failure to construe essential claim limitations is fatal to its
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`opposition of Patent Owner’s Motion to Amend. ...................................................... 6
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`c. .............. Park in view of Motoharu does not disclose a connecting unit that is
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`“discrete” relative to the substrate and “otherwise separate” from the coil when
`these limitations of claims 21-22 are properly construed. ......................................... 8
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`d. .... Petitioner has failed to sufficiently explain how and why one skilled in the
`
`art would modify Park and Motoharu to achieve claim 23. ....................................10
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`VI. CONCLUSION .................................................................................................11
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`iv
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`
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`Cases
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`Table of Authorities
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`Aqua Products Inc. v. Matal, 872 F.3d 1290 (Fed. Cir. 2017) (en banc) .................. 1
`
`DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469 F.3d 1005 (Fed. Cir.
`2006) ....................................................................................................................... 5
`
`Jiawei Tech. (HK) Ltd. v. Richmond, IPR2014-00937 (PTAB Dec. 16, 2014) ........ 8
`
`Xerox Corp. v. Bytemark, Inc., IPR2022-00624, Paper 9 (PTAB Aug. 24, 2022) .... 7
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`
`
`Statutes
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`35 U.S.C. § 103(a) ..................................................................................................... 1
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`37 C.F.R. § 42.121(d)(2) ............................................................................................ 1
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`v
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`I.
`
`INTRODUCTION
`
`Petitioner argues that substitute claims 21-23 are obvious under 35 U.S.C. §
`
`103 over U.S. Patent No. 8,922,162 to Park et al. (“Park,” Ex.1006) in view of
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`Japanese application H4-51115 to Motoharu et al. (“Motoharu,” Ex.1025).
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`Petitioner, however, has failed to satisfy its burden of showing that the substitute
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`claims are unpatentable by a preponderance of the evidence. 37 C.F.R. §
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`42.121(d)(2); Aqua Products Inc. v. Matal, 872 F.3d 1290, 1324 (Fed. Cir. 2017)
`
`(en banc). The Board should therefore grant Patent Owner’s contingent Revised
`
`Motion to Amend (Paper 25) and substitute original claims 1, 12, and 11 of U.S.
`
`Patent No. 9,806,565 (the “’565 Patent”) with substitute claims 21, 22, and 23,
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`respectively, if original claims 1, 12, and 11 are found unpatentable.
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`II.
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`Status of Related Proceedings
`
`The ’565 Patent is the parent of U.S. Patent No. 10,804,740 (the ’740
`
`Patent”), which is the subject of IPR2022-00118. The Board issued a Final Written
`
`Decision in the ’118 IPR on May 5, 2023 (Paper 44). In the Final Written
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`Decision, the Board construed the meaning of several terms of the ’740 Patent,
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`which are similarly recited in the claims of the ’565 Patent, in favor of the Patent
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`Owner. Specifically, the Board held that “the coil and the connecting unit are
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`separate and distinct components, and that the first and second connecting
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`terminals to be structurally separate from the connecting unit and the coil.”
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`Claims 1 and 12 both recite a coil unit, coil, first and second connecting
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`terminals, and a connecting unit, claimed similarly as in the claims of the ’740
`
`Patent. Patent Owner similarly contends in Patent Owner’s Response that these
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`1
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`elements are separate and distinct components. See P.O. Resp., Paper 17 p.9 et
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`sec. The Board should therefore construe these elements here as separate and
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`distinct components.
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`
`
`III.
`
`Overview of the ’565 Patent.
`
`The ’565 Patent teaches a wireless power receiver that uses a connecting
`
`unit to interconnect the coil of the wireless power receiver to a separate circuit. Ex.
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`1001, 5:27-30, see, e.g., Figs. 26-28. The ’565 Patent provides that the thickness of
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`the wireless power receiver (1000) can be reduced by as much as the thickness of
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`the connecting unit (300) by disposing the coil/antenna (230/600) on the surface of
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`a substrate (100) and disposing the connecting unit (300) within receiving space
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`(130) of the substrate (100). Id., 2:24-2:49; 6:10-26; 8:48-52; 16:4-13; 18:46-53;
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`Figs. 26-28.
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`As shown in, Fig. 28 (reproduced below), the substrate (100) has an upper
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`surface and a lower surface (top planer surface and opposite bottom planer
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`surfaces) that generally define the thickness of the substrate layer. The substrate
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`(100) has a portion cut out therefrom, which is identified as the receiving space
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`(130) (see Fig. 26), that disrupts the otherwise continuous thickness of substrate
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`layer (100) so as to receive the connecting unit (300) at least partially within the
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`receiving space (130). The receiving space (130) extends outward continually from
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`the inside of the coil (220/320) to the outside of the coil (at 210/310) so that the
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`interconnections with the coil/antenna fall within the boundary of the receiving
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`space when viewed from the top. See id., Figs. 26-27. Importantly, the connecting
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`2
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`unit is discrete in that it is a distinct structure separate from the other components,
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`except at the claimed interconnections. See id., Figs. 26-28.
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`’565 Patent, Fig. 28 (Annotated)
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`IV.
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`The Cited References
`a. U.S. Patent No. 8,922,162 (“Park”).
`
`Park states that it provides a “portable terminal having a wireless charger
`
`coil and an antenna element on the same plane.” Ex. 1006, Abstract. As shown in
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`Fig. 3, terminal includes a shielding member 131, which has a first and a second
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`accommodation grooves. Id., 3:35-37. “The first and second accommodation
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`grooves 141 and 142 are circular in shape and recessed into one surface of the
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`shielding member 131” to receive the coils 133 and 135. Id., 3:37-39; 4:7-9.
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`Element 137 is “[a] shielding wall 137 [] interposed between the first and second
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`accommodation grooves 141 and 142.” Id., 3:42-44. A battery cover 102 encloses
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`the first and second accommodation grooves 141 and 142. Id., 4:7-17. In this
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`3
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`regard, shielding wall 137 separates the grooves 141 and 142 from each other
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`entirely. Moreover, “[t]he first and second coils 133 and 135 have connection ends
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`143 and 145, respectively, extended from one side of the shielding member 131.”
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`Id., 4:1-3. Importantly, the coils 133 and 135 are attached to the shielding member.
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`Id., 2:25-32, 3:4-8, 6:20-25 (Claim 1).
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`b. Japanese application H4-51115 (“Motoharu”)
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`Motoharu is directed to a “rotary transformer” Ex. 1025, Title. According to
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`Motoharu, reducing the thickness of the disc-shaped ferrite cores is problematic
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`because it reduces the strength of the unit. This includes when “a stepped surface
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`on the back side of the disc-shaped ferrite core to which the flexible board is
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`bonded” is used. Id., p. 3. Consistent with this discussion, Motohru teaches
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`attaching the board 4 within the ferrite core via the board mounting groove 5 to
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`maintain the integrity of the ferrite core with respect to strength. Id., p. 4 (“In the
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`principal plane of the disc-shaped ferrite core 1, a board mounting groove 5 is
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`formed extending in the radial direction, and a flexible board 4 is attached to this
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`board mounting groove 5.”) (emphasis added), see also, id., (“The leads 34 of the
`
`coil are led out to the back side through slit grooves 33 extending in radial
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`directions, and the leads are connected to a flexible board 35 bonded to the back
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`side.”) (emphasis added).
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`V.
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`PETITIONER HAS NOT SHOWN THAT PROPOSED CLAIMS 21-23
`ARE UNPATENTABLE
`
`4
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
`
`a. Petitioner has not shown that Park in view of Motoharu teaches “discrete
`connecting unit” that “is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil” of claims 21-23.
`i. Claim Construction.
`
`Claims 21 and 22 recite three components: a substrate, a connecting unit,
`
`and wireless power receiving circuit. Revised Motion, Paper 25, Appendix. The
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`substrate has a coil unit and a short-range communication antenna disposed on the
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`substrate. Id. The proposed claims add to the original claims the requirement that
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`the connecting unit is “discrete” and that the connection unit “is otherwise
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`separate from the first connection terminal, the second connection terminal, and
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`the coil” (the “otherwise separate” limitation).
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`The requirement that the connecting unit is “discrete” is not superfluous in
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`the context of the “otherwise separate” limitation. That is, the claims require that
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`the connecting unit be both distinct, i.e., a separate component, relative at least to
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`the substrate and the wireless power receiving circuit, and that the connecting unit
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`is connected to the coil only via the first-third and second-forth connection
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`terminal interconnections.
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`This interpretation is consistent with both the intrinsic and the extrinsic
`
`evidence in the record. DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469
`
`F.3d 1005, 1014 (Fed. Cir. 2006). Specifically, the claimed “otherwise separate”
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`requirement refers back to the preceding limitations relating to the first-third and
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`second-forth interconnections in both claims 21-22, which means that the coil and
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`the connecting unit have no other connections. See Ex. 2019 (defining “otherwise”
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`as “something to the contrary”). As such, the express language of the claims
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`5
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
`
`requires that the connecting unit is not connected to the coil, except at the first-
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`third and second-fourth terminal interconnections. The specification supports this
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`interpretation by consistently describing the connecting unit as one that is not
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`connected to the coil, except at the connection terminal interconnection. See Ex.
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`1001, Figs. 28, 35-36 and related disclosure.
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`With respect to the requirement that the connecting unit is discrete, this
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`limitation is added to the first element of claims 21 and 22, which is the first
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`instance of the substrate in the claims. The claims expressly recite thereafter that
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`the receiving space of the substrate is formed for a discrete connecting unit.
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`Revised Motion, Paper 25, Appendix. The connecting unit is therefore discrete,
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`i.e., distinct or separate, relative to the substrate, whereas the “otherwise separate”
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`requirement relates to the coil. Id. This too is supported by the specification, which
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`consistently shows the connecting unit 300 separate relative to both the substrate
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`100 and the coil 220/320. See, e.g., Figs. 26-28 (showing the substrate 100 separate
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`from both the elements of the connecting unit 100, 310, 320, 340, 350 and the coil,
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`except at connection terminal interconnections). Finally, this interpretation is
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`supported by dictionary definitions: Ex. 2020 (defining discrete as distinct or
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`separate), Ex. 2020 (defining separate as not connected).
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`Accordingly, the Board should apply Patent Owner’s interpretation, which
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`requires that the connecting unit is separate from the substrate and from the coil,
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`except at the first-third and second-fourth terminal interconnections.
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`b. Petitioner’s failure to construe essential claim limitations is fatal to
`its opposition of Patent Owner’s Motion to Amend.
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`6
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`Petitioner did not expressly construe any terms of claims 21-22. Petitioner
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`instead argues with respect to requirement that connecting unit is discrete, that “it
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`was already well known to utilize a discrete connecting unit to connect inductive
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`coils to power receiving circuits, where the connecting unit is disposed in a
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`receiving space in the substrate below the coils.” Opp. Paper 30, p.4 (citing
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`Ex.1026, Phinney Supp. Decl. at p. 6-7). With respect to the otherwise separate
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`limitation, Petitioner argues “As shown in Fig. 1 of Motoharu, the flexible board 4
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`(connecting unit) is otherwise separate from the two leads 3 (first and second
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`connection terminals) of the coil highlighted in green. Ex.1026, 20-21. For
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`example, the flexible board 4 is only connected to the coil at the two leads 3…”
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`Opp. Paper 30, p.17 (citing Ex.1026, Phinney Supp. Decl. at p. 20-21).
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`First, the statements in Dr. Phinney’s Declaration find no support in any of
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`the evidence of record and simply mirror the arguments in Petitioner’s Opposition.
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`As such, these conclusory statements are not entitled to any weight. Xerox Corp. v.
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`Bytemark, Inc., IPR2022-00624, Paper 9 (PTAB Aug. 24, 2022).
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`Second, because Petitioner has not provided any construction or analysis of
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`either the “discrete” or the “otherwise separate” limitations, which are critical to
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`the understanding of the scope of proposed claims 21-22, the Board must find that
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`Petitioner has failed to satisfy its burden of persuasion. See Jiawei Tech. (HK) Ltd.
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`v. Richmond, IPR2014-00937, Paper 24 at 7-8 (PTAB Dec. 16, 2014).
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`Third, based on Petitioner’s contentions with respect to Park and Motoharu,
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`7
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`the “discrete” or the “otherwise separate” limitations have no meaning. That is, as
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`discussed above, Park discusses that the coils are attached to the shielding member
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`(the alleged substrate) and Motoharu discusses that the board (the alleged
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`connecting unit) is attached to the ferrite core (the alleged substrate) via the board
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`mounting surface. The Petitioner does not explain how these components, which
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`are clearly attached in a way that the proposed substitute claims require them not to
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`be, can meet the limitations of proposed claims 21-23. They cannot unless the
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`“discrete” or the “otherwise separate” limitations have no meaning, which cannot
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`be correct under any claim construction theory.
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`c. Park in view of Motoharu does not disclose a connecting unit that is
`“discrete” relative to the substrate and “otherwise separate” from the coil
`when these limitations of claims 21-22 are properly construed.
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`As shown in Motoharu Fig. 2, board 4 is sandwiched between layers of the
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`ferrite core 1. Ex. 1025. Motoharu teaches that board 4 is attached to the mounting
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`groove 5 within the ferrite core 1. Ex. 1025., p. 4. Motoharu, therefore, does not
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`teach a discrete connecting unit relative to the substrate, that is, a connecting unit
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`that is distinct/separate from the substrate, because Motoharu requires the board 4
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`and the ferrite core 1 to be attached. Indeed, Motoharu’s design requires this
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`attaching of the split ferrite layers to board 4, because without this, the ferrite core
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`is inherently weaker than even than the stepped design, which Motoharu stated was
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`problematic. Id., p. 3. Therefore, Motoharu does not only fail to disclose the
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`claimed discrete connecting unit, there is no reason to modify Motoharu to achieve
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`the claimed invention, because doing so would weaken Motoharu’s ferrite core,
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`8
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`contrary to Motoharu’s express purpose to provide a thinner assembly without
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`weakening its strength. Id. Park does not cure these deficiencies.
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`Motoharu, Fig. 2
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`With respect to the “otherwise separate” limitation, Park clearly teaches that
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`the coils 133 and 135 are attached to the shielding member. Ex. 1006, 2:25-32,
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`3:4-8, 6:20-25 (Claim 1). Therefore, Park in view of Motoharu teach that the coils
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`are attached to the shielding member/ferrite core (the alleged substrate), and that
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`the ferrite core is attached to the board (the alleged connecting unit). In this regard,
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`the combination of references that forms the basis for Petitioner’s opposition teach
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`that the coils 133 and 135 are connected to the board (the alleged connecting unit)
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`via the shielding member/ferrite core between them, which is contrary to the
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`requirement of the “otherwise separate” limitation that the coil is separate from the
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`connecting unit, except at the first-third and the second-fourth interconnections.
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`Accordingly, Petitioner has failed to show that Park and Motoharu disclose
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`or otherwise suggests all limitations of substitute claims 21-22, and Petitioner has
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`further failed to show why one skilled in the art would modify these references to
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`teach the claimed invention. For at least these reasons, Petitioner has failed to
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`9
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`satisfy its burden to show that the proposed claims are unpatentable by a
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`preponderance of the evidence.
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`d. Petitioner has failed to sufficiently explain how and why one skilled in
`the art would modify Park and Motoharu to achieve claim 23.
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`Petitioner has failed to show that claim 23 is unpatentable by a
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`preponderance of the evidence. Petitioner argues that Motoharu teaches all of the
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`claimed terminal connections (1-8) with reference to Fig. 1. As discussed above,
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`the Board construed the first and second connection terminals as separate and
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`distinct from the coil and also from the connection unit. See Sect. II, supra. The
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`same construction applies here. Because the coil unit is separate and distinct from
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`the connecting unit, the third and fourth connection terminals are also separate and
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`distinct from the coil unit. In contrast, Motoharu’s describes the leads 3 of the coil
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`soldered to the connecting leads on the flexible board 4. Ex. 1026, p. 4. Motoharu,
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`therefore, fails to disclose separate and distinct first-fourth connection terminals.
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`Park does not cure this deficiency, particularly with respect to the third and fourth
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`terminal connections. Accordingly, Park and Motoharu fail to disclose the
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`limitations of claim 23.
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`Petitioner has further failed to provide sufficient reasons for the combination
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`of Park and Motoharu. Indeed, Petitioner repeats the same contention, “[t]hus,
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`when Park is modified in view of Motoharu, this limitation is obvious”, for each of
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`the elements of proposed claim 23 (Opp. at p. 20, et sec.), without any evidentiary
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`support or explanation, which is the definition of conclusory statements that are not
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`10
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`entitled to any weight.
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`Finally, Petitioner has failed to satisfy its burden here because it did not
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`explain how and why one skilled in the art would modify Park and Motoharu to
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`achieve the claimed invention.
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`VI.
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`CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests that the Board
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`grant its contingent Revised Motion to Amend should claims the original claims of
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`the’565 Patent be found unpatentable.
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`
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`Dated: May 5, 2023
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`Respectfully submitted,
`
`/Antonio Papageorgiou/
`Antonio Papageorgiou
` Reg. No. 53,431
`
`LOMBARD & GELIEBTER LLP
`230 Park Avenue, 4th Floor West
`New York, NY 10169
`(212) 520-1172 (telephone)
`(646) 349-5567 (facsimile)
`ap@lombardip.com
`
`
`Attorney for SCRAMOGE
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`TECHNOLOGY LTD.
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`11
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`IPR2022-00350
`Reply to Opp. to Revised Motion to Amend
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`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
`
`that on May 5, 2023, a copy of this REPLY TO PETITIONER’S OPPOSITION
`
`TO PATENT OWNER’S REVISED MOTION TO AMEND was served by filing
`
`this document through the Patent Trial and Appeal Case Tracking System (P-
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`TACTS) system, as well as delivering a copy via electronic mail upon the
`
`following attorneys of record for the Petitioner:
`
`
`
`Scott T. Jarratt (Reg No. 70,297)
`scott.jarratt.ipr@haynesboone.com
`Andrew S. Ehmke (Reg No. 50,271)
`andy.ehmke.ipr@haynesboone.com
`Calmann J. Clements (Reg No. 66,910)
`calmann.clements.ipr@haynesboone.com
`
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Dated: May 5, 2023
`
`Respectfully submitted,
`
`/Antonio Papageorgiou/
`Antonio Papageorgiou
` Reg. No. 53,431
`
`
`
`
`
`
`
`12
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`
`
`
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