throbber
Apple Inc.
`v.
`Scramoge Technology Ltd.
`
`IPR2022-00351, U.S. Patent No. 10,622,842
`
`Patent Owner’s Demonstrative Exhibits
`
`May 3, 2023
`
`Exhibit 2021
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 1
`
`

`

`Ground 1: A POSITA Would Not Combine Separate
`Incompatible Embodiments of Suzuki
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 2
`
`

`

`Why Petition Fails
`
`• Suzuki describes each embodiment
`separately, “in accordance with the
`[nth] embodiment of the present
`invention.”
`
`• The 2nd and 6th embodiments of Suzuki
`would not be combined.
`
`Suzuki, 2nd embodiment
`
`Suzuki, 6th embodiment
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Paper 17 at 5, 7-15; Paper 23 at 2-4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 3
`
`

`

`Why Petition Fails
`
`• The only embodiment of Suzuki with a
`radiation layer is the 2nd embodiment.
`
`• There is no radiation layer in the 6th
`embodiment of Suzuki.
`
`• There is no shield layer in the 6th
`embodiment of Suzuki.
`
`• The 6th embodiment magnetic layers
`171H, 171L and 155 are not a claimed
`first layer.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Suzuki, 2nd embodiment
`
`Suzuki, 6th embodiment
`
`Exhibit 2017, ¶ 56; Exhibit 1005, 9:16-23; Paper 17 at 5, 7-15
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 4
`
`

`

`Suzuki: No Short Range Comm Antenna in
`First through Fifth Embodiments
`
`Suzuki, 2nd embodiment
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Exhibit 1005; Paper 2 at 24; Paper 17 at 12-14
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`Patent Owner: ‘740 Patent, Fig. 11
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 5
`
`

`

`Claim 7 depends from and includes the shielding
`unit and 1st and 2nd layers of claim 1
`
`1. A wireless power receiver, comprising:
`[1.1] a shielding unit;
`[1.2] a first layer on the shielding unit;
`[1.3]a wireless power receiving coil on the first layer;
`[1.4] a second layer on the wireless power receiving coil;
`[1.5 a first region in which at least one of the first layer and the second layer overlaps the wireless
`power receiving coil in a vertical direction perpendicular to an upper surface of the shielding unit; and
`[1.6] a second region in which at least one of the first layer and the second layer does not overlap
`the wireless power receiving coil in the vertical direction,
`[1.7]wherein a first distance, measured in the vertical direction, between the first layer and the
`second layer in the first region is greater than a second distance, measured in the vertical direction, between
`the first layer and the second layer in the second region.
`
`Exhibit 1001, ’842 Patent, 10:66 – 11:15
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 6
`
`

`

`Petitioner identifies Suzuki’s second embodiment as
`having a shielding layer and 1st and 2nd layers
`
`Suzuki, 2nd embodiment
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`Exhibit 1003, ¶50; Paper 2 at 24; Paper 17 at 5
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 7
`
`

`

`Suzuki’s sixth embodiment is missing claim 1 limitations
`
`• The 6th embodiment of Suzuki does not
`have a shield.
`
`• The 6th embodiment of Suzuki does not
`have a single magnetic layer [1st layer].
`
`• The 6th embodiment of Suzuki does not
`have a radiation layer [2nd layer].
`
`• The 6th embodiment’s magnetic layers
`171H, 171L and 155 are not a claimed
`first layer.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Suzuki, 6th embodiment
`
`Paper 17 at 14-15. NOT TO SCALE
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 8
`
`

`

`Suzuki’s sixth embodiment drawings are not to scale
`
`Suzuki, 6th embodiment
`
`• Figure 21 of Suzuki is not to scale.
`
`• Wireless receiving coil 170 is NOT the
`same size as short range
`communications antenna 154
`
`• The 6th embodiment’s magnetic layers
`171L and 171H and 155 are not a
`claimed first layer.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Exhibit 2017, ¶¶ 77-78, Paper 17 at 14-17. NOT TO SCALE
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 9
`
`

`

`Suzuki’s sixth embodiment has a plurality of magnetic layers
`
`Suzuki, 6th embodiment
`
`• The 6th embodiment of Suzuki has a
`plurality of magnetic layers 171L and
`171H.
`
`• A shield is not necessary in the 6th
`embodiment because of multiple
`magnetic layers 171L and 171H
`shielding the receiving coil 170.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Exhibit 1005, Fig. 17A; Exhibit 2017, ¶¶ 79-81, 92; Paper 17 at 14, 17-18, 26
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 10
`
`

`

`Ground 2: A POSITA Would Not Combine Suzuki with Park
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 11
`
`

`

`Why Petition Fails
`
`• A POSITA would not combine Suzuki and
`Park.
`
`• A POSITA would not use Park’s
`contiguous paramagnetic shielding in
`combination with Suzuki.
`
`• Park is not prior art to the ’842 Patent
`
`Suzuki, 2nd embodiment
`
`Park
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Exhibit 1005; Exhibit 1006, Paper 17 at 24-26
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 12
`
`

`

`A POSITA Would Not Use Park’s Shielding Member
`
`• A POSITA would not combine Suzuki and
`Park.
`
`• A POSITA would not use Park’s
`contiguous paramagnetic shielding
`member 131 in combination with
`Suzuki.
`
`• Suzuki already provides shielding 172
`around the circumference of the coil
`170.
`
`Park
`
`Suzuki
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Exhibit 1005; Fig. 7A; Exhibit 1006, Fig. 3; Paper 17 at 25-27
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 13
`
`

`

`A POSITA Would Not Use Park’s Shielding Member
`
`• A POSITA would not combine Suzuki and
`Park.
`
`• A contiguous shielding layer would
`couple the magnetic fields of the data
`coil and the power receiving coil.
`
`Park
`
`Suzuki
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`Exhibit 1005; Fig. 7A, Exhibit 1006, Fig. 3; Paper 17 at 25-27
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 14
`
`

`

`A POSITA Would Not Use Park’s Shielding Member
`
`• A POSITA would not combine Suzuki and
`Park.
`
`• Suzuki already has magnetic layer 155
`that surrounds data coil 154 and
`provides a shielding effect between it
`and receiving coil 170.
`
`Park
`
`Suzuki
`
`Suzuki
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Exhibit 1005; Fig. 21, Exhibit 1006, Fig. 3; Exhibit 2017, ¶ 93; Paper 17 at 25-27
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 15
`
`

`

`Ground 2: Park is not Prior Art
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 16
`
`

`

`File History:
`The Examiner agreed there was no new matter
`
`Applicant-Initiated Interview Summary (underlining original), Exhibit 1007 at 63, Paper 17 at 21.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 17
`
`

`

`The applicants’ summary
`confirms there was no new matter
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Amendment Under 37. C.F.R. § 1.111, Exhibit 1007 at 36, Paper 17 at 21.
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 18
`
`

`

`File History: The Amendment was not new matter.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Amendment Under 37. C.F.R. § 1.111, Exhibit 1007 at 34, Paper 17 at 22.
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 19
`
`

`

`File History: Notice of Allowance.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`Notice of Allowance, Exhibit 1007 at 24, Paper 17 at 22.
`
`Scramoge Technology Ltd.
`Exhibit 2021, Page 20
`
`

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