Apple Inc.
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00350, U.S. Patent No. 9,806,565
`
`Patent Owner’s Demonstrative Exhibits
`
`June 2, 2023
`
`Ex. 2022
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 1
`
`
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00350, U.S. Patent No. 9,806,565
`
`Patent Owner’s Demonstrative Exhibits
`
`June 2, 2023
`
`Ex. 2022
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 1
`
`
`
`Ground 1: Hong has No Receiving Space or Connecting Unit
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 2
`
`
`
`Why Petition Fails
`
`wiring layer 27
`
`1. Hong has no “connecting unit”
`
`2. Hong has no “receiving space”
`
`3. Hong’s wiring layer can not be BOTH
`the “receiving space” AND the
`“connecting unit”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`Hong:‘352 Patent, Fig. 4
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 3
`
`
`
`Hong: No Connecting Unit
`
`wiring layer 27
`
`receiving space 130 in
`substrate 100
`
`connecting unit
`
`Hong:‘352 Patent, Fig. 4
`
`Patent Owner: ‘565 Patent, Fig. 11
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 4
`
`
`
`Claim 1: Connecting Unit Separate and Distinct
`
`Connecting unit presumed
`separate and distinct and
`specifically claimed in separate
`claim elements to describe the
`structure and associated
`receiving space
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`’565 Patent, Claim 1; see also Claim 12.
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 5
`
`
`
`Fig. 11: Separate Connecting Unit
`
`receiving space 130 in
`substrate 100
`
`connection terminal 320
`to be connected to
`connection terminal 220
`
`connection terminal 310
`to be connected to
`connection terminal 210
`
`connecting unit
`
`connection terminal 220
`at inner end of coil 230
`
`connection terminal 210
`at outer end of coil 230
`
`coil 230
`
`Patent Owner:‘565 Patent, Fig. 11; 5:45-59; see also 4:60-64; 5:19-23; 15:57-64.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 6
`
`
`
`Specification: Separate Connecting Unit
`
`Patent Owner: ‘565 Patent at 8:27-37; see also 16:51-58.
`
`Scramoge Technology Ltd.
`
`Patent Owner: ‘565 Patent at 2:45-49; see also 8:48-52, 16:4-13, 18:46-53.
`Ground 1
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 7
`
`
`
`File History: Separate Connecting Unit
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Ex. 1002, ‘565 Patent Prosecution History, at 357-358.
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 8
`
`
`
`Hong’s Wiring Layer
`
`Hong: ‘352 Patent at 4:43-47.
`
`Scramoge Technology Ltd.
`
`Hong: ‘352 Patent at 5:19-24.
`
`Ground 1
`
`MTA
`
`Hong:‘352 Patent, Fig. 4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 9
`
`
`
`Patterning Process ≠ Receiving Space
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Hong: ‘352 Patent at 3:53-62; see also 3:62-4:7.
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 10
`
`
`
`Apple Admits: No Receiving Space or Connecting Unit
`
`Critical language –
`“disposed in substrate”
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Petition at 20 (annotating Hong: ‘352 Patent Fig. 4).
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 11
`
`
`
`Claim 13 Confirms Hong’s Different Structure
`
`• Hong’s wiring layer 27 is not separable
`
`• Rectifying unit 13 is not disposed in
`the “substrate” or the alleged
`“receiving space”
`
`’565 Patent, Claim 13.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`Hong:‘352 Patent, Fig. 4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 12
`
`
`
`“Connected” Means Previously Separate
`
`Regents of the Univ. of Minn. v. AGA Med., 717 F.3d 929, 938 (Fed. Cir. 2013)
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 13
`
`
`
`Not Process Claims
`
`Hazani v. U.S. Int'l Trade Comm’n, 126 F.3d 1473, 1479 (Fed. Cir. 1997)
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 14
`
`
`
`Motion to Amend
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 15
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 1) A wireless power receiver, comprising:
`21.
`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;
`a coil unit disposed on the substrate, the coil unit comprising a first connection terminal, a second
`connection terminal, and a coil; and
`a short-range communication antenna disposed on the substrate and surrounding the coil;
`wherein the coil is configured to wirelessly receive power, wherein the coil is formed as a conductive
`pattern on or within the substrate,
`wherein the conductive pattern comprises a conductive line wound at least two times and conductive
`pattern has a spiral shape, 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, wherein the coil unit overlaps the
`receiving space, and wherein the coil unit is disposed on the substrate in a first direction perpendicular to an
`upper surface of the substrate,
`wherein the connecting unit is disposed in the receiving space and connected to the coil unit,
`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
`wherein the connecting unit comprises:
`a circuit board having a wiring layer;
`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, the fourth connection terminal located at the other end of the coil that is at an inside portion of the
`conductive pattern and wherein the connecting unit is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil unit.
`MTA
`Ground 1
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 16
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 12) A wireless power receiver, comprising:
`22.
`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
`a coil unit comprising a first connection terminal, a second connection terminal, and a coil; and
`a short-range communication antenna disposed on the substrate and surrounding the coil;
`wherein the coil is configured to wirelessly receive power, wherein the coil is formed as a conductive
`pattern on or within the substrate,
`wherein the conductive pattern comprises a conductive line wound at least two times and the
`conductive pattern has a spiral shape,
`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,
`wherein the connecting unit is disposed in the receiving space and connected to the coil unit,
`wherein the connecting unit overlaps the receiving space, the connecting unit extending in a direction
`parallel to the upper surface of the substrate, and
`wherein the connecting unit comprises:
`a circuit board having a wiring layer;
`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, the fourth connection terminal located at the other end of the coil that is at an inside portion of
`the conductive pattern and wherein the connecting unit is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil unit; and wherein the coil unit is disposed on the
`substrate and the connecting unit.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 17
`
`
`
`Substitute Claims – Interpretation – “Otherwise Separate”
`
`Claims 21 and 22:
`
`… discrete connecting unit…
`
`wherein the connecting unit is otherwise separate from the first connection
`terminal, the second connection terminal, and the coil unit…
`
`P.O. Interpretation with respect to the connecting unit:
`
`Distinct - a separate component, relative at least to the substrate and the
`
`wireless power receiving circuit, and
`
`Otherwise separate - connected to the coil only via the first-third and
`
`second-forth connection terminal interconnections.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 18
`
`
`
`Support for PO’s Interpretation
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Patent Owner: ‘740 Patent, Fig. 28 (Annotated) (Ex. 1001)
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 19
`
`
`
`Support for PO’s Interpretation
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`Patent Owner: ‘740 Patent (Annotated) (Ex. 1001)
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 20
`
`
`
`Discrete - Petitioner’s Citations to Motoharu, Ex. 1025
`
`Op. at p.17 (citing Motoharu, Ex.1025)
`
`Ex. 1025, Motoharu, Fig. 2
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 21
`
`
`
`Motoharu Does not Disclose a Discrete Connecting Unit
`
`Ex. 1025, Motoharu, Fig. 2
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
`
`Ex. 1025 (5/19), Motoharu, pg. 4
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 22
`
`
`
`Park and Motoharu Do Not Disclose an “Otherwise
`Separate” Connecting Unit
`
`Motoharu: the flexible board 4 (alleged connecting unit) attached to the ferrite core 1 (substrate)
`
`Ex. 1025, Motoharu, Fig. 2
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`Ex. 1025 (5/19), Motoharu, pg. 4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 23
`
`
`
`Park and Motoharu Do Not Disclose an “Otherwise
`Separate” Connecting Unit
`
`Park: coils 133, 135 attached to the shielding member 131 (substate).
`
`Ex. 1006, 2:25-32.
`
`Ex. 1006, 3:4-8.
`
`Ex. 1006, 6:20-25 (Claim 1).
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 24
`
`
`
`Park and Motoharu Do Not Disclose an “Otherwise
`Separate” Connecting Unit
`
`Collectively, Park and Motoharu teach coils 133, 135
`attached to the flexible board 4 (alleged connecting unit)
`via the shielding member 131.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 25
`
`
`
`Substitute Claims
`
`23. (Proposed substitute for claim 11) The wireless power receiver of
`claim 1 21, wherein the third connection terminal is located within a horizontal
`boundary defining the receiving space and is located at one end of the coil that
`is at an outside portion of the conductive pattern, and the fourth connection
`terminal is located within the horizontal boundary defining the receiving space
`and is located at the other end of the coil that is at an the inside portion of the
`conductive pattern, and wherein the connecting unit comprises a fifth
`connecting terminal located within the horizontal boundary defining the
`receiving space and a sixth connecting terminal located within the horizontal
`boundary defining the receiving space, the short-range communication
`antenna comprises a seventh connection terminal and an eighth connection
`terminal, wherein the fifth connection terminal is connected to the seventh
`connection terminal of the short-range communication antenna within the
`horizontal boundary defining the receiving space and the sixth connection
`terminal is connected to the eighth connection terminal of the short-range
`communication antenna within the horizontal boundary defining the receiving
`space,….
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 26
`
`
`
`Substitute Claims
`
`23. (Proposed substitute for claim 11) …
`
`wherein the fifth connection terminal to the seventh connection terminal
`connection and the sixth connection terminal to the eighth connection terminal
`connection occur on the connecting unit at a location outside the conductive
`pattern of the coil, wherein the connecting unit comprises a flexible circuit
`board with the third, fourth, fifth, and sixth connection terminals disposed on a
`surface of the connecting unit, and wherein the substrate has a horizontal
`upper surface and a horizontal lower surface opposite the upper surface, and
`wherein the receiving space extends between the horizontal upper surface and
`the horizontal lower surface of the substrate continually from inside the coil to
`outside the coil.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`Scramoge Technology Ltd.
`Exhibit 2022, Page 27
`
`
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