Trials@uspto.gov
`571-272-7822
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`Paper # 43
`Entered: July 17, 2023
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner
`
`
`IPR2022-00350
`Patent 9,806,565 B2
`
`
`Record of Oral Hearing
`Held: June 2, 2023
`
`
`
`
`
`BEFORE: JAMESON LEE, KARL D. EASTHOM, and
`MICHELLE N. WORMMEESTER, Administrative Patent Judges.
`
`
`
`
`
`
`
`571-272-7822
`
`
`
`
`
`Paper # 43
`Entered: July 17, 2023
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner
`
`
`IPR2022-00350
`Patent 9,806,565 B2
`
`
`Record of Oral Hearing
`Held: June 2, 2023
`
`
`
`
`
`BEFORE: JAMESON LEE, KARL D. EASTHOM, and
`MICHELLE N. WORMMEESTER, Administrative Patent Judges.
`
`
`
`
`
`
`
`
`IPR2022-00350
`Patent 9,806,565 B2
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`SCOTT T. JARRATT, ESQUIRE
`Haynes and Boone, LLP
`2323 Victory Ave, Suite 700
`Dallas, TX 75219
`
`JAMIE RAJU, ESQUIRE
`Haynes and Boone, LLP
`2323 Victory Ave, Suite 700
`Dallas, TX 75219
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`BRETT COOPER, ESQUIRE
`BC Law Group, P.C.
`200 Madison Ave, 24th Floor
`New York, NY 10016
`
`ANTONIO PAPAGEORGIOU
`Lombard & Geliebter LLP
`230 Park Avue, 4th Floor West
`New York, NY 10169
`
`
`The above-entitled matter came on for hearing on June 2, 2023,
`commencing at 9:00 a.m., via video teleconference.
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`IPR2022-00350
`Patent 9,806,565 B2
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`P R O C E E D I N G S
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`JUDGE WORMMEESTER: Good morning, everyone. We have
`our final hearing in IPR2022-00350, Apple v. Scramoge Technology, which
`concerns U.S. patent number 9,806,565. I'm Judge Wormmeester. Also
`appearing remotely are my colleagues Judges Lee and Easthom. Thank you
`for your flexibility in conducting this hearing via video today.
`Given this format, we wanted to start off by clarifying a few items.
`First, our primary concern is your right to be heard. If at any time during the
`proceeding you encounter technical or other difficulties that undermine your
`ability to adequately represent your client, please let us know immediately,
`for example, by contacting the team members who provided you with
`connection information. Second, for the benefit of the Judges, opposing
`counsel, and court reporter, please identify yourself each time you speak.
`When not speaking, please mute yourself.
`Third, we have the entire record, including demonstratives. When
`referring to demonstratives, papers, or exhibits, please be explicit in
`identifying any slide numbers or page numbers. Please also pause a few
`seconds afterwards so that we can find the reference and follow along.
`Finally, please note that members of the public may be listening to this oral
`hearing. Before we move on, does anyone have concerns about that?
`MR. COOPER: No, Your Honor.
`MR. JARRATT: No, Your Honor.
`JUDGE WORMMEESTER: Great. Thank you. All right. Let's
`get the parties' appearances. Who do we have for Petitioner?
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`IPR2022-00350
`Patent 9,806,565 B2
`MR. JARRATT: Good morning, Your Honors. This is Scott
`Jarratt with Haynes and Boone, and I'm lead Petitioner -- lead counsel for
`Petitioner Apple. And also for Petitioner is Jamie Raju, who's a LEAP
`practitioner, and she will be arguing with respect to the original challenge
`claims. And we also have Andy Ehmke, and he will be arguing with respect
`to the motion to amend. And I will note that his video is not working. Mr.
`Ehmke, can you hear -- or can you speak?
`MR. EHMKE: I can hear fine. I just do not have the video feed,
`which is okay by me.
`JUDGE WORMMEESTER: Okay. Great. Thank you. Good
`morning and welcome. And who do we have for Patent Owner?
`MR. COOPER: Good morning, Your Honors. My name is Brett
`Cooper with BCLG. We represent Scramoge, the Patent Owner. My
`colleague, John Petrsoric, is on the line as well. And handling the
`amendment side of this response is Antonio Papageorgiou and Nikitas
`Nicolakis. They are not with BCLG. They are with a different law firm.
`JUDGE WORMMEESTER: Okay. Great. Thank you. We
`previously set forth the procedure for today's hearing, but just to remind
`everyone the way this will work. In our trial order, we granted each party 60
`minutes to present arguments. Because we have a LEAP practitioner
`presenting for Petitioner today, Petitioner will have an extra 15 minutes to
`present arguments.
`Petitioner will go first and may reserve rebuttal time. Patent
`Owner will then present its response and may reserve sur-rebuttal time.
`Please remember that the demonstratives you submitted are not part of the
`record. The record of the hearing will be the transcript. We will maintain a
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`IPR2022-00350
`Patent 9,806,565 B2
`clock and give you a warning when you're reaching the end of your
`argument time.
`Are there any questions before we proceed?
`MS. RAJU: No, Your Honors.
`MR. PAPAGEORGIOU: No, Your Honors.
`JUDGE WORMMEESTER: All right, counsel. Will you be
`reserving any time?
`MS. RAJU: Yes, Your Honor. I'd like to reserve 20 minutes for
`rebuttal.
`JUDGE WORMMEESTER: Let me set the timer real quick. So
`that will give you probably a total of 55 minutes. Then, let's see, let me
`just -- you can begin when you're ready.
`MS. RAJU: Thank you, Your Honor. So the claims of the '565
`patent are directed to a wireless power receiver that receives power through
`electromagnetic induction. And we see one example of such a wireless
`power receiver on Slide 2 of Petitioner's demonstratives, which shows
`Figure 27 of the patent.
`This receiver includes a coil unit and a connecting unit. And it's
`called a connecting unit because it connects the coil unit to a wireless power
`receiving circuit. And that's so that it can transfer power to a load, such as
`for example, a battery.
`As we see on Slide 3, we are first focusing on the original claims 1
`through 20. And the original claims include two independent claims, Claim
`1 and Claim 12, both of which are directed to a wireless power receiver. As
`you will see on Slide 4, these two independent claims are apparatus claims
`and recite a wireless power receiver that includes a connecting unit. And
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`IPR2022-00350
`Patent 9,806,565 B2
`this connecting unit is disposed in the receiving space of a substrate.
`Now, let's take a look at how the prior art teaches a connecting unit
`on Slide 5. As you'll see on Slide 5, Hong teaches a connecting unit of a
`wireless power receiver. And it's the connecting unit because it connects the
`coil unit, which is shown in orange, to a power receiving circuit that Hong
`calls a charging unit. And that's number 15 shown in red in the middle.
`Hong's connecting unit includes a rectifying unit which is shown in
`green and labeled 13. And it also includes a conductive wiring layer, which
`you can see if you'll now turn to Slide 6. On Slide 6, we have a cross-
`sectional view of the receiver we just saw in Slide 5. Here, you see the full
`connecting unit. Again, that includes the rectifying unit, labeled 13, and the
`conductive wiring layer that's labeled number 27. And that conductive
`wiring --
`
`JUDGE LEE: Ms. Raju? It's Judge Lee.
`MS. RAJU: Yes, Your Honor.
`JUDGE LEE: I have a question before you go any further. What's
`your basis for calling something a connecting unit? What is a connecting
`unit?
`
`MS. RAJU: Your Honors, the claims in the patent teaches that a
`connecting unit is something that connects the coil unit to a power receiving
`circuit. That's why it's a connecting unit. So it provides an electrical
`connection so that power can go from the coil unit to a power receiving
`circuit. And here in Hong, that's the charging unit that we showed in red on
`Slide 5.
`
`JUDGE LEE: But don't we need to have something specific?
`Based on what you just said, this sounds like a functional element, that
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`IPR2022-00350
`Patent 9,806,565 B2
`you're just saying -- are you saying whatever connects to a coil is a
`connecting unit? Whatever it might be, you know, as long as it connects to a
`coil, it is a connecting unit? Is that how you're understanding the term?
`MS. RAJU: No, Your Honors. Connecting unit needs to meet all
`the limitations in the claim, which includes being connected to -- being able
`to configure to connect to a wireless power receiver, connecting to a coil
`unit, being disposed in the receiving space, and having the various
`connection terminals. So a structure or device or wiring that accomplishes
`all -- meets all of those limitations so that it can connect the coil unit to the
`receiving circuit would be a connecting unit.
`JUDGE LEE: Yeah. That's my concern. Because I'm just
`thinking about what you just said. You say a structure, but we don't know
`what that structure is, right? What you've essentially said is whatever
`structure that performs all of those functions is a connecting unit; is that
`right? Whatever that structure might be.
`MS. RAJU: Well, we're saying that the structure here is a unit,
`that it's part of the wireless power receiver. It's not some outside
`component. It's part of the receiver. It's disposed in the receiving space of
`the substrate, and it has various terminals and connections for connecting to
`the coil unit and the receiving circuit.
`And here in Hong, you see also that you have -- if your concern is
`about where the structure is, we're pointing to both the rectifying unit and
`the actual wiring that kind of traces through or snakes through the layers of
`the circuit board. So there is structure here. There is wiring and a rectifying
`unit.
`
`JUDGE LEE: Okay. Thank you.
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`IPR2022-00350
`Patent 9,806,565 B2
`MS. RAJU: Thanks, Your Honor. So just to emphasize that point
`again, so the conductive wiring that we're talking about that's part of the
`connecting unit is formed by depositing conductive wiring material,
`conductive material, on and between the different layers of the main circuit
`board, and inside via holes. And the via holes are the green vertical sections
`that you see that are labeled 25a, 25b, and 25c.
`And the via holes are actually openings in those layers. They are
`holes that have been created. And just to be clear, the via holes themselves
`are not part of the connecting unit. It is the wiring material inside the holes
`that is part of the connecting unit. The via holes as their name implies,
`they're holes. They're openings that form a space. And that space receives
`the conductive wiring material.
`So as you can see, Hong's rectifying unit, together with its
`conductive wiring layer, teach the claimed connecting unit. Hong further
`teaches that that connecting unit is disposed in the receiving space of a
`substrate. And if you'll turn to Slide 7, we can take a look at how Hong
`teaches the claimed substrate.
`On Slide 7, we see here that the substrate is the top, the upper
`portion -- the top layers that are at the upper portion of the main circuit
`board. And to be clear, it's not the entirety of the circuit board. Dr. Phinney
`actually annotated this figure in his declaration, and we included it in our
`original petition to show exactly what we mean by the claimed substrate.
`We want to be clear. It's the layers of the substrate and
`specifically, the outermost layer, 21a, at the top, and the topmost inner layer
`23 that form the substrate, not the entire main circuit board 20, which would
`include all of the various layers plus other electrical components. So Hong
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`IPR2022-00350
`Patent 9,806,565 B2
`is clearly differentiating substrate layers from the wiring layer.
`Here, you can see that the wiring layer which we previously
`showed in green is actually shown in Hong with cross-hatching. There's a
`hatching pattern that's not used for the substrate. The substrate is just filled
`with solid white. There's no hatching. So Hong is clearly showing that this
`wiring layer, 27, the conductive wiring, is something distinct from the layers
`that make up the substrate.
`Hong also teaches that that substrate has a receiving space and that
`its connecting unit is disposed in the receiving space, as we show on Slide 8.
`The claims require that the substrate comprise a receiving space and a
`connecting unit is disposed in that receiving space. And that's all it tells us
`about the receiving space.
`Hong clearly teaches both. We have the layers 21a and the
`topmost of 23, where you can see there is a space for the conductive wiring
`layer. The space actually includes the via holes, which we just talked about,
`the actual holes the layers, and the space that's occupied by the wiring layers
`extending through the substrate layers.
`So the conductive wiring layer is formed in the via holes and it's
`occupying a space in the substrate. That is the receiving space. The
`connecting unit is clearly disposed in a receiving space of the substrate. And
`if --
`
`JUDGE LEE: Ms. Raju, it's Judge Lee again.
`MS. RAJU: Yes, Your Honor.
`JUDGE LEE: That channel, you say it's occupying a space. I can't
`dispute that. But I think it's Patent Owner's view that it was there to begin
`with. What if you built the substrate around it? I mean, you haven't done
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`IPR2022-00350
`Patent 9,806,565 B2
`anything to make any space. You have the channel there, a wire, but then
`you build the substrate around it, can you still call that a receiving space?
`Nothing has been received into the substrate because the channel was
`already there to begin with, and then you build your substrate around it and
`to cover it up. Can we say that that's a receiving space?
`MS. RAJU: Well, yes, Your Honor, because the receiving space --
`for two reasons. One, the receiving space includes those via holes. Those
`via holes are formed in the substrate layers. So that's --
`JUDGE LEE: Yeah. Let's put aside those receiving holes. I can
`see that. The horizontal segment between the two vias, there was no hole
`there, right? You just have the wiring layer there. And let's say that then
`you build the substrate up around it, there was never any space, is what the
`Patent Owner is saying. There was no space to begin with and you don't end
`up with a space, so why are you able to call that a receiving space?
`MS. RAJU: Well, Your Honor, if I understand their position
`correctly, they're talking about the fact that you create the wiring layer and
`the substrate in kind of a patterned process, in various layers -- in a layered
`kind of patterned process. And that is trying to really import method
`limitations, manufacturing steps, into what's just an apparatus claim.
`All that's really required for the apparatus is that you have a
`receiver, with a substrate having a receiving space formed therein of a
`predetermined shape. And here, not only are there holes formed, you can
`see that the substrate has within it, by virtue of the wiring layer being inside
`it, a receiving space. So it receives the wiring layer because the wiring layer
`occupies. The receiving space and the wiring layer are coexisting together.
`JUDGE LEE: So you're understanding the word receive in a
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`IPR2022-00350
`Patent 9,806,565 B2
`broader sense, that you don't -- it's like if I'm receiving a guest in my house,
`he doesn't have to come through the front door. He could already be here.
`He could be born in my house and that would be receiving the person is
`what you're saying, right. You're saying it's --
`MS. RAJU: Correct, Your Honor. I'm saying --
`JUDGE LEE: It's there, so it's received.
`MS. RAJU: Receiving space is broad. The patent itself does not
`provide really any description to define receiving per se. And the claim
`simply says that the connecting unit is disposed in the receiving space. It
`doesn't say that it's configured to be slid into the receiving space. It doesn't
`say that the connecting unit is configured to be somehow fit within
`specifically in a certain way, in a certain direction. It just simply says
`disposed in the receiving space. And here --
`JUDGE LEE: Okay. Thank you. Why isn’t it enough to just say
`that it's a process step limitation, which is of no import here in an apparatus
`claim?
`
`MS. RAJU: I'm sorry, Your Honor. I missed the first part of that
`question.
`JUDGE LEE: Oh, I'm saying why wouldn’t it be enough for
`Petitioner simply to say that's a process step limitation, whatever receiving
`might mean, to the extent that it requires an act of doing something? That's
`a process step, which is not pertinent in an apparatus claim.
`MS. RAJU: Correct, Your Honor. And I believe we are saying
`that in our papers. We argue that the Patent Owner is trying to import these
`manufacturing step limitations and method limitations into the claim. We've
`briefed on this, actually. But the Patent Owner doesn't seem to in their
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`IPR2022-00350
`Patent 9,806,565 B2
`briefing say that the receiving space needs to receive. They are simply
`saying we don't have a receiving space because of how it's made. And we’re
`saying that's not true.
`JUDGE LEE: I see. So you have two arguments. One is
`receiving doesn't mean anything here in an apparatus claim. But even if it
`means something, the art has it because for the reasons you just mentioned.
`Receiving is broad, and if it's there, it's occupying a space, then it's in a
`receiving space.
`MS. RAJU: Correct, Your Honor. Thank you.
`JUDGE LEE: Okay. Thank you.
`MS. RAJU: And I can -- yes? Was another --
`JUDGE EASTHOM: Oh, sorry. This is Judge Easthom. I wasn't
`sure I had my mute off. But I guess your other argument is, and I just want
`to make clear that you don't have to have the whole connecting unit in the
`receiving space, right? Only part of it?
`MS. RAJU: Correct, Your Honor.
`JUDGE EASTHOM: Okay.
`MS. RAJU: Yes. If you turn to Slide 2, which we showed earlier,
`which has Figure 27 of the patent, that's just one example of one of the
`embodiments that they have. But you can see that what is labeled
`connecting unit, which is connecting unit 300, is only partially within the
`receiving space. A good chunk of it is actually outside the receiving space.
`And so the term connecting unit disposed in the receiving space clearly does
`not mean that the entirety needs to be disposed within.
`And what we’re showing here is that we and Hong -- and I'll direct
`you now, sorry we're jumping around a little bit, to Slide 9. In Slide 9, we
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`IPR2022-00350
`Patent 9,806,565 B2
`show the picture again to show that the connecting unit is the rectifying unit
`plus the wiring layer, and the wiring layer is formed in the via holes, which
`are formed on the inner layers. So --
`JUDGE EASTHOM: I'm sorry to jump in. I just --
`MS. RAJU: That's okay.
`JUDGE EASTHOM: I think I understand your point, and so I was
`jumping ahead to Claim 13, which I know you have on -- on your slide.
`You're coming up to it, Slide 11. I guess your argument there is similar.
`You're saying separaable means it only has to be partly separable? The
`connecting unit need only be partly separable?
`MS. RAJU: Correct, Your Honor. That's a portion of the
`argument, yes. That the rectifying unit being separable from the receiving
`space is sufficient to meet this claim similarly to how a portion of the
`connecting unit being disposed in the substrate is sufficient to meet that
`limitation.
`And here, it doesn't seem from the briefing that Patent Owner is
`really arguing that the rectifying unit, whether it is -- they're not saying that
`it's not separable. They're just simply saying it doesn't meet the limitation
`because the rectifying unit is not in the receiving space. But that's not what
`the claim requires. The claim doesn't say the portion of the connecting unit
`that is disposed in the receiving space needs to be separable. It just says the
`connecting unit is separable.
`And I can go further, but you know, the rectifying is clearly
`separable. If you turn to Slide 12 --
`JUDGE EASTHOM: No, I understand the rectifying unit is
`probably -- it looks separable. But I guess my other question is, is it doesn't
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`IPR2022-00350
`Patent 9,806,565 B2
`seem -- and notwithstanding what Patent Owner argued -- I think their
`argument is in their PO response, I think -- I had it 31 to 32. Let me see.
`I’m having trouble finding it.
`MS. RAJU: In the response or the sur-reply? The response?
`JUDGE EASTHOM: I think their Patent Owner response has an
`argument about Claim 13, right?
`MS. RAJU: Correct. Yes, on page 31.
`JUDGE EASTHOM: Thirty-one, okay. Thanks. Let me get to
`that. Sorry. Okay. I'm sorry. One second. Bear with me.
`MS. RAJU: No problem, Your Honor.
`JUDGE EASTHOM: Okay. Well, maybe -- well, the remainder.
`It seems like they're saying on the bottom of 31 that the remainder of the
`alleged connecting unit, including wiring layer 27 that rely on it, that's
`completely disposed in the -- it's not separable. So it seems like they're
`saying it's not separable, you know, the whole connecting unit isn't separable
`there. And so that's one of my questions. It seems they're making that
`argument.
`And then, number two is it doesn't seem you have the same support
`for this this partly separable interpretation that you're making. It's not the
`same as, you know, the Figure 27 you showed. I get that that shows that it's
`not totally inside the receiving space, so that's --
`MS. RAJU: So --
`JUDGE EASTHOM: Go ahead, yeah, thanks, if you understand
`my question.
`MS. RAJU: I do, I think. And let me start with the second part
`that you just laid out. So, again, if you turn to Slide 12, the claims use the
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`IPR2022-00350
`Patent 9,806,565 B2
`term separable. But that word appears nowhere in the specification. There's
`no guidance as to what separable means. So we look at it and we look at the
`patent, and we say, what does this mean?
`So Dr. Phinney, our expert, took a look at the patent and noted that
`even though the term separable is not used, the patent describes the
`connecting unit as being connected to the coil unit via solder. And that's
`shown on Slide 12. And so Dr. Phinney noted that for the connecting unit to
`be separable, that encompasses, at the very least, that the connecting unit is
`connected via solder. And so something that has been connected via solder
`would be considered separable.
`And so if you'll turn to Slide 13, Hong teaches a connecting unit
`that is separable in exactly in the same way. We have the rectifying unit 13
`with a terminal 13b. And that terminal 13b is connected to the via hole 25c,
`via solder to the wiring layer in it. That connection is a soldered connection,
`the same type of connection that's contemplated by the patent. And so
`separable means --
`JUDGE EASTHOM: Well, wait a minute. That's skipping the
`issue of whether that's just saying that -- that's just showing how you're
`saying Hong can be partly separable, but that doesn't give any insight into
`the meaning of the claim based on this Slide 12 because it's still wholly
`separable, notwithstanding that you have to cut through the solder and melt
`the -- excuse me, melt the solder, right?
`MS. RAJU: Yes, Your Honor, but the patent doesn't provide any
`guidance about what it means to be separable other than -- it doesn't even
`talk about separation after you've connected the terminal. It just says that
`the connecting unit might be separable.
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`JUDGE EASTHOM: Okay.
`MS. RAJU: So it's configured such that it is separable. There's no
`act of separation that's actually required. The patent doesn't talk about an
`actual separation, it just says configured such that it is separable. If the
`claim doesn't say, like in Figure 27 on Slide 2, when you're looking -- or in
`Slide 12 when you're looking at that figure, the claim, you know, separating
`the connecting unit would require pulling it out of, removing it, taking it out
`of.
`
`But the claim doesn't say where the connecting unit is removable
`from the receiving space or that it needs to be capable of being taken out of
`or slid out of. It just says separable, again, very broadly. And what Patent
`Owner is trying to do is trying to narrow and, like, impose limitations of
`how you might take it out.
`JUDGE EASTHOM: So I mean, are you arguing then that, you
`know, if you go to Slide 13, that you could separate even the wiring layer?
`Or did you --
`MS. RAJU: That's not our primary argument, Your Honor. What
`we're really saying is that the connecting unit is separable because the
`rectifying unit is connected to the wiring layer, and thus the via hole, via a
`soldered connection similar to the type of connection you see in the patent.
`And all we're left to get from the patent is that's something that can be
`soldered in that same way with something that -- is something that would be
`considered separable.
`JUDGE EASTHOM: Okay. And then, this is a related question.
`Is there anything in the challenged patent spec -- specification, excuse me --
`that shows that if you go to Slide 12, that the connecting unit, 300 and 100,
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`is there any description of any other layers that would bind those two
`together or otherwise make it so that they're connected, you know, in
`addition to the soldered connection?
`MS. RAJU: I don't believe so, Your Honors. The patent simply
`just says -- and I can direct you to where it says soldered. There are
`descriptions. Well, if you take it at face value that the patent has the
`description of solder, beyond the soldering of the connections of the
`connection terminals, there's no other description. The connecting unit
`slides into, in this embodiment, the receiving space. And then, it's simply
`secured and connected by solder to those connection terminals.
`JUDGE EASTHOM: But what do they do? What do they do with
`this unit? Don't they sell it and put it in a housing or something, ultimately?
`You're saying there's no description of that being mounted anywhere or
`otherwise secured to something?
`MS. RAJU: I'm sorry, can you rephrase that question, Your
`Honor? I'm not sure I quite understand it. You said mounting in a housing?
`JUDGE EASTHOM: Right. Like, if you look at Figure 12, for
`example, on Slide 12, and you have, you know, you have the whole
`configuration there, the 100, 200. Let's say this is manufactured. They slide
`this connecting unit. They solder it together, then what? What do they do
`with it? Is there anything in the patent about what they do with this?
`MS. RAJU: The device would be connected to some other device
`which has a wireless power receiving circuit. So you would connect it to
`something that you could connect to a load. And it describes being to a load,
`but it says that that load is not shown in the patent. And so the focus in the
`patent is just on the substrate 100 and the connecting unit and the coil unit.
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`JUDGE EASTHOM: Okay. Thank you. I'll ask your friends
`about this, too, if they want to think about it. I appreciate your responses.
`MS. RAJU: Thank you, Your Honor.
`JUDGE LEE: Ms. Raju, it's Judge Lee. I've got a follow up. On
`that segment the two via holes, do we know how that got there? The 27, the
`horizontal portion.
`MS. RAJU: On Slide 13, Your Honor?
`JUDGE LEE: Yeah. Do we know how that was laid down?
`MS. RAJU: Well, Hong talks about using a patterning process,
`which is basically like deposition. And the material is deposited, and it's
`done in the same type of way that the coil unit is described. They happen
`around the same time, but it's with different material than what the substrate
`is made out of. So the substrate, layers 21a and the topmost inner layer, 23,
`those layers of the substrate are a nonconductive material. They're basically
`like insulation. And then, you need to
`JUDGE LEE: So that segment is laid down and then you put more
`layers of the substrate on top of it? That's how it got to be embedded? Is
`that the idea?
`MS. RAJU: So for example, that one segment that you're
`referencing, 22nd, yes. You would lay down the conductive material for that
`section. You have the rest of your substrate that's created on top. You
`create holes in the substrate, fill those with more conductive material, and
`then add another layer of substrate. But again --
`JUDGE LEE: Thank you.
`MS. RAJU: -- those are -- and I'll just tie that up with, you know,
`that's kind of again focusing on how it's made, the manufacturing. But at the
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`end of the day when you look at the cross-section of the receiver, you still
`see that there's a substrate with a receiving space formed in it for the wiring
`layer.
`
`JUDGE LEE: Thank you.
`MS. RAJU: Thanks, Your Honors. And I'll just add, if there were
`no other questions on the substrate comprising a receiving space or on claim
`13, I'll just follow that Hong clearly renders obvious that the substrate
`comprises a receiving space, as we've just shown, and that the connecting
`unit is disposed in that receiving space.
`And Hong also renders obvious the limitation of claim 13. And so
`overall, the various combinations that we've proposed in the IPR render
`obvious the original claims 1 through 20, and we ask that you find those
`claims unpatentable. And unless there are any other questions?
`JUDGE LEE: Yeah, I do. Just one sum up question. If we were
`to disagree with you and say a receiving space has to be created first, and
`then filled with the -- whatever is supposed to go in there, then Hong would
`not disclose or render obvious such a feature. I mean, hypothetically, if we
`say you got to have the receiving space first, and that that step is required.
`MS. RAJU: Hypothetically, if you were to disagree with that
`position, then I would say no, Your Honor, actually, Hong does teach this.
`Because it very clearly has via holes. And the via holes have material that is
`filled in them. And so if you'll turn to Slide 9 one more time, there's that
`passage. And the passage of Hong clearly states, and it explains directly,
`explicitly, the wiring layer 27 is formed in via holes which are formed on
`inner layers 23. So Hong clearly teaches that there is a substrate layers,
`inner layer 23, a hole is formed in it, there's a receiving space created in that
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`layer, and then wiring is filled and added to it.
`JUDGE LEE: Oh, I see. I see. So the horizontal segment actually
`does not need to be the receiving space. It's enough to meet the claim if
`material in the via holes are in the receiving space.
`MS. RAJU: Correct, Your Honor, because as Judge Easthom and I
`were talking about earlier, the claim does not require that the entire
`connecting unit be disposed in the receiving space.
`JUDGE LEE: Yeah. Okay. Thank you.
`MS. RAJU: You're welcome. Are there any other questions? If
`not, then I will turn it now -- for the motion to amend sectio
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