Inter Partes Review
`U.S. Patent No. 9,806,565
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`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00350
`
`Jamie Raju and Andy Ehmke
`Lead Counsel: Scott Jarratt
`Haynes and Boone, LLP
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`Ex.1029 / IPR2022-00350 / Page 1 of 37
`APPLE INC. v. SCRAMOGE TECHNOLOGY LTD.
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`U.S. Patent No. 9,806,565
`
`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00350
`
`Jamie Raju and Andy Ehmke
`Lead Counsel: Scott Jarratt
`Haynes and Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`Ex.1029 / IPR2022-00350 / Page 1 of 37
`APPLE INC. v. SCRAMOGE TECHNOLOGY LTD.
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`The ’565 Patent
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`Ex.1001 (’565 Patent), Fig. 27.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`2
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`Original Claims 1-20
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`Substitute Claims 21-23
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`3
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`3
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`’565 Patent, Independent Claims 1 and 12
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`…
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`….
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`…
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`….
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`Ex.1001, Claim 1.
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`Ex.1001, Claim 12.
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`4
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`4
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`Hong teaches a “connecting unit”
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`Ex.1005, Fig. 3 (cropped, annotated); Petition, 31.
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`5
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`5
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`Hong teaches a “connecting unit”
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`Ex.1005, Fig. 4 (cropped, annotated); Petition, 30-31.
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`6
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`6
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`Hong teaches a “substrate”
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`Ex.1005, Fig. 4 (cropped, annotated); Petition, 30.
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`7
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`7
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`Hong teaches a “substrate comprising a receiving space”
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`Ex.1005, Fig. 4 (cropped, annotated); Petition, 30-31.
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`8
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`8
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`Hong teaches a “substrate comprising a receiving space”
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`Ex. 1005, 5:19-24; Sur-Reply, 4.
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`Ex.1005, Fig. 4 (cropped, annotated); Petition, 30-31.
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`9
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`9
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`Hong teaches a “substrate comprising a receiving space”
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`Ex. 1005, 4:33-47; Sur-Reply, 4.
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`Ex.1005, Fig. 4 (cropped, annotated); Petition, 30-31.
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`10
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`10
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`Claim 13
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`11
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`11
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`In the ’565 Patent, “separable” includes secured via solder
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`Ex.1001, Fig. 12 (annotated); Declaration, 68.
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`12
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`12
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`Hong’s connecting unit (including rectifying unit) is “separable”
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`Ex.1005, Fig. 4 (cropped, annotated); Petition, 46.
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`13
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`13
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`Additional Slides
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`14
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`14
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`Patent Owner’s Sur-Reply
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`PO Sur-Reply, 13.
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`15
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`15
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`Patent Owner’s Sur-Reply
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`PO Sur-Reply, 11.
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`16
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`16
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`Embedding components in the layers of a substrate was well-known.
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`Ex.1012, Fig. 3; Petitioner’s Reply, 14; Declaration 37-38.
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`17
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`17
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`’565 Patent: Claim 1
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`Ex.1001, Claim 1.
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`18
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`18
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`Original Claims 6, 7, 16, 17, 19, and 20
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`Substitute Claims 21-23
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`19
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`19
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`Substitute Claim 21
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`PO Revised Motion to Amend, 25-26.
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`20
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`20
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`Park in view of Motoharu renders obvious substitute claims 21-23
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`Park
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`Second Opposition, 10
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`21
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`21
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`Park in view of Motoharu renders obvious substitute claims 21-23
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`Motoharu
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`Second Opposition, 14
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`22
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`22
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`Park in view of Motoharu renders obvious substitute claims 21-23
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`Motoharu
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`Second Opposition, 16
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`23
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`23
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`“discrete connecting unit”
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`PO Revised Motion to Amend, 25-26.
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`24
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`24
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`Patent Owner: “discrete” = “distinct structure”
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`PO Reply, 2-3.
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`PO Reply, 5
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`25
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`25
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`Park in view of Motoharu renders obvious substitute claims 21-23
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`Motoharu
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`Second Opposition, 14
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`26
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`26
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`Motoharu’s flexible board is “mounted” and “attached”
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`Motoharu
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`Ex.1025, 4; Pet. Sur-Reply, 2-3.
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`Ex.1025, 5; Pet. Sur-Reply, 2-3.
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`27
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`27
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`Federal Circuit: affixed structures = “discrete structures”
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`Regents of Univ. of Minn. v. AGA Med. Corp., 717 F.3d 929, 939 (Fed. Cir. 2013); Pet. Sur-Reply, 6.
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`Id. at 936; Pet. Sur-Reply, 6
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`28
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`28
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`“otherwise separate”
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`…
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`…
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`PO Revised Motion to Amend, 25-27.
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`29
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`29
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`Patent Owner: “otherwise separate” = “only via”
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`PO Reply, 5.
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`30
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`30
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`Motoharu’s flexible board and coil are connected only via the leads
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`Motoharu
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`Second Opposition, 16
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`31
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`31
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`In combination, substrate is "between" coil and connecting unit
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`PO Reply, 9.
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`32
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`32
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`“Otherwise Separate”
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`‘565 Patent
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet. Sur-Reply, 9-10
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`33
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`33
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`Patent Owner: Motoharu fails to disclose first-fourth connection terminals
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`PO Reply, 10.
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`34
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`34
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`Motoharu’s coil and leads disclose 1st and 2nd connection terminals
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`Motoharu
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`Pet. Sur-Reply, 12
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`35
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`35
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`Motoharu’s leads (1st and 2nd terminals) are soldered to the leads of the flexible
`board
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`Motoharu
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`Pet. Sur-Reply, 8
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`36
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`36
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`Inter Partes Review
`U.S. Patent No. 9,806,565
`
`Apple Inc. v. Scramoge Technology, Ltd., Case IPR2022-00350
`
`Jamie Raju and Andy Ehmke
`Lead Counsel: Scott Jarratt
`Haynes and Boone, LLP
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`37
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