UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00351
`U.S. Patent No. 10,622,842
`_____________________
`
`DECLARATION OF DR. JOSHUA PHINNEY,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
`
`1
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`Ex.1003
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`Phinney Declaration
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`Inter Partes Review of U.S. 10,622,842
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`
`
`TABLE OF CONTENTS
`Introduction ...................................................................................................... 4 
`I. 
`Qualifications and Professional Experience .................................................... 6 
`II. 
`III.  Level of Ordinary Skill in the Art ................................................................. 10 
`IV.  Relevant Legal Standards .............................................................................. 11 
`V. 
`Background .................................................................................................... 12 
`VI.  Overview of the ’842 Patent .......................................................................... 13 
`VII.  Claim Construction ........................................................................................ 15 
`VIII.  Identification of how the Claims are Unpatentable ....................................... 15 
`A.  Ground 1: Claims 1, 2, 5-7, 14-16, and 19-20 are obvious under
`35 U.S.C. § 103(a) over Suzuki. ......................................................... 16 
`1. 
`Summary of Suzuki ....................................................... 16 
`2. 
`Claim 1 ........................................................................... 18 
`3. 
`Claim 2 ........................................................................... 30 
`4. 
`Claim 5 ........................................................................... 31 
`5. 
`Claim 6 ........................................................................... 32 
`6. 
`Claim 7 ........................................................................... 34 
`7. 
`Claim 14 ......................................................................... 37 
`8. 
`Claim 15 ......................................................................... 39 
`9. 
`Claim 16 ......................................................................... 39 
`10. 
`Claim 19 ......................................................................... 40 
`11. 
`Claim 20 ......................................................................... 42 
`Ground 2: Claim 7 is obvious under 35 U.S.C. § 103(a) over
`Suzuki in view of Park ........................................................................ 42 
`
`B. 
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`2
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`Inter Partes Review of U.S. 10,622,842
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`Support for the claims of the ’842 patent. ..................... 43 
`1. 
`Summary of Park ........................................................... 50 
`2. 
`Reasons to Combine Park with Suzuki .......................... 52 
`3. 
`Claim 7 ........................................................................... 54 
`4. 
`IX.  Conclusion ..................................................................................................... 58 
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`3
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`Phinney Declaration
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`Inter Partes Review of U.S. 10,622,842
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`
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`I, Dr. Joshua Phinney, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
`1.
`
`I am making this declaration at the request of Cisco Systems, Inc. in
`
`the matter of the Inter Partes Review of U.S. Patent No. 10,622,842 (“the ’842
`
`Patent”) to Lee et al.
`
`2.
`
`I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the outcome of this matter or the specifics of my testimony, and I
`
`have no other interest in this case or the parties thereto.
`
`3.
`
`I have been asked to provide my opinions regarding whether claims 1,
`
`2, 5, 6, 7, 14-16, 19, and 20 (“the Challenged Claims”) of the ’842 Patent are
`
`unpatentable as they would have been obvious to a person having ordinary skill in
`
`the art (“POSITA”) at the time of the alleged invention, in light of the prior art. It
`
`is my opinion that all of the limitations of the challenged claims would have been
`
`obvious to a POSITA.
`
`In the preparation of this declaration, I have studied:
`
`the ’842 Patent, Ex.1001;
`
`the prosecution history of the ’842 Patent (“’842 File History”),
`
`4.
`
`a.
`
`b.
`
`Ex.1002;
`
`c.
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`U.S. Patent No. 8,421,574 to Suzuki et al. (“Suzuki”), Ex.1005; and
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`4
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`Phinney Declaration
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`Inter Partes Review of U.S. 10,622,842
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`d.
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`5.
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`U.S. Patent No. 8,922,162 to Park et al. (“Park”), Ex.1006.
`
`In forming the opinions expressed below, I have considered:
`
`the documents listed above;
`
`the relevant legal standards, including the standard for obviousness,
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`and any additional authoritative documents as cited in the body of this
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`declaration; and
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`my own knowledge and experience based upon my work in the field
`
`of networking as described below, as well as the following materials.
`
`e.
`
`f.
`
`g.
`
`Prosecution History of U.S. Patent No. 10,153,666, Ex.1007;
`
`U.S. Patent No. 10,069,346, Ex.1008;
`
`U. S. Patent Publication No. 2010/0203831 to Muth (“Muth”),
`
`Ex.1009; and
`
`h.
`
`i.
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`U.S. Patent No. 8,687,537 to Michaelis (“Michaelis”), Ex.1010; and
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`A redline comparison between U.S. Patent No. 10,069,346
`
`specification in the issued patent (text taken from USPTO website) with the as-
`
`filed specification of U.S. Patent No. 10,153,666 (text taken from publication
`
`2017/0338697 on the USPTO website, which represents the as-filed specification
`
`of the ’666 patent); Ex.1011.
`
`6.
`
`Unless otherwise noted, all emphasis in any quoted material has been
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`added.
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`5
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`Phinney Declaration
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`7. My complete qualifications and professional experience are described
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`Inter Partes Review of U.S. 10,622,842
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`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
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`following is a brief summary of my relevant qualifications and professional
`
`experience.
`
`8. My complete qualifications and professional experience are described
`
`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
`
`following is a brief summary of my relevant qualifications and professional
`
`experience.
`
`9.
`
`I am a Principal Engineer in the Electrical Engineering and Computer
`
`Science practice at Exponent, an engineering and scientific consulting firm
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`headquartered at 149 Commonwealth Drive, Menlo Park, California 94025. I
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`received a Ph.D. in Electrical Engineering from the Massachusetts Institute of
`
`Technology (“MIT”) in 2005. I also earned S.M. and B.S. degrees in Electrical
`
`Engineering from MIT and the University of Illinois, Chicago (“UIC”),
`
`respectively.
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`10. My master’s thesis at MIT focused on the miniaturization of power
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`converters, by reducing the energy storage and improving the performance of
`
`inductors. As part of this work, I designed, tested, and constructed ferrite, iron-
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`powder, and air-core inductors, while minimizing magnetic losses. During this
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`6
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`time, I invented with my advisor, Dr. David Perreault, an electrical component
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`Inter Partes Review of U.S. 10,622,842
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`with a capacitive impedance and an inductance-cancellation feature provided by
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`magnetically coupled windings. A filter having a capacitor with inductance
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`cancellation provides enhanced performance over frequency compared with
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`conventional capacitors. This work was later extended to a second patent, with
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`magnetically coupled windings used to improve EMI filters and common-mode
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`chokes.
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`11. My doctoral work at MIT centered on miniaturization of power
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`converters and magnetics. As part of my doctoral work, I constructed and modeled
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`planar magnetic systems, including magnetically coupled, printed magnetic coils.
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`By incorporating such compact, magnetic structures into power converters, the
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`resulting converter enjoyed multiple benefits, including waveform-shaping and
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`reduction of switch stresses. Through the modeling associated with this
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`dissertation, I become proficient in methods for analyzing the inductances of
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`packages and interconnects, especially planar or filamentous systems of
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`conductors.
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`12.
`
` For my publications related to both my Master’s and Ph.D. thesis, I
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`received the William M. Portnoy Prize Paper Award (2003) and the IEEE Power
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`Electronics Society Transactions Prize Paper Award (2004).
`
`13. After earning my Ph.D., I joined Exponent and have led technical
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`7
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`investigations to portable electronic devices, microcomputers, as well as industrial
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`Inter Partes Review of U.S. 10,622,842
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`
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`and consumer devices with embedded controllers. My job functions include
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`analyzing hardware and software of these devices to understand their modes of
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`failure, and testifying regarding these devices in legal matters involving patents
`
`and trade secrets.
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`14. As part of my employment at Exponent, I have performed design,
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`design reviews, and failure analysis for wireless charging and communication
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`systems. The focus of this work has been (1) coupling between transmitter and
`
`receiver coils from the standpoint of efficiency and magnetic-field exposure to
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`users, in particular for the Power Matters Alliance; (2) coupling of interrogators
`
`and transponder coils in printed magnetic cards; and (3) integrated-circuit and coil
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`failures due to wear, dimensional changes, and triboelectric charging. In addition
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`to testifying regarding resonant and inductive wireless-power transfer, I have
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`consulted for industry regarding coil design, RFID and near-field communication
`
`(NFC) integrated circuits, modulation methods, and on-metal RFID tags.
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`15.
`
`I have testified regarding the software-defined features, internal
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`circuitry, and physical embodiments of electronic equipment. Regarding
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`electronics, I have testified regarding power electronics in communication systems,
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`wind turbines, grid-scale photovoltaic plants, and consumer electronics. In
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`addition, I have testified regarding control and compensation in industrial
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`8
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`controllers, voltage regulators, and switched-mode power converters. My
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`Inter Partes Review of U.S. 10,622,842
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`
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`experience with wireless RF circuitry includes failure analysis of amplifiers, power
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`supplies, matching networks, and multiplexers in satellites, semiconductor-
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`processing equipment, and medical devices.
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`16. Regarding the mechanical elements of electronic equipment, I have
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`testified regarding buttons and touch interfaces, connectors, linear and rotary
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`actuators, position-measuring devices, and the design and construction of modular
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`housings for computerized equipment and peripherals. In particular, I have testified
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`regarding detachable components as they are constructed in relation to the housing
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`and underlying electronic assemblies, including printed circuit boards, flex printed
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`circuits, and other connector assemblies within the housing of electronic
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`equipment.
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`17.
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`In addition to the forgoing, I perform electromagnetic assessment of
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`utility and communication infrastructure. These issues include permitting,
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`interference, and environmental impact of radar, AC and HVDC transmission
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`lines, substations, photovoltaic installations, generators, broadcast antennas, and
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`electrified mass transit systems.
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`18.
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`I am being compensated for my work associated with this case plus
`
`reimbursement of reasonable expenses. My compensation is not contingent on my
`
`opinions or the outcome of the case, and I have no other interest in this case or the
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`9
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`parties thereto.
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`Inter Partes Review of U.S. 10,622,842
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`
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`19.
`
`I understand there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
`
`experience of persons working in the field at the time of the invention; (2) the
`
`sophistication of the technology; (3) the types of problems encountered in the field;
`
`and (4) the prior art solutions to those problems.
`
`20. A person of ordinary skill in the art (“POSITA”) in the field of the
`
`’842 Patent, as of its alleged priority date of November 4, 2011 (or August 10,
`
`20171), would have been someone knowledgeable and familiar with the wireless
`
`charging arts that are pertinent to the ’842 Patent. That person would have a
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`master’s degree in electrical engineering, or equivalent training, and approximately
`
`two years of experience working in the electrical engineering field. Lack of work
`
`experience can be remedied by additional education, and vice versa.
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`21. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the alleged
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`1 See section VIII.B.1.
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`10
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`Phinney Declaration
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`priority date of the ’842 Patent (i.e., November 4, 2011). Unless otherwise stated,
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`when I provide my understanding and analysis below, it is consistent with the level
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`of a POSITA prior to the alleged priority date of the ’842 Patent.
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`IV. RELEVANT LEGAL STANDARDS
`22.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’842 Patent, I am relying on certain basic
`
`legal principles that counsel have explained to me. These principles are discussed
`
`below.
`
`23.
`
`I understand that prior art to the ’842 Patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the alleged
`
`invention recited in the ’842 Patent. As will be explained in further detail below, it
`
`is my understanding that the appropriate priority date for the ’842 patent is no
`
`earlier than August 10, 2017. For purposes of this Declaration, I am applying
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`August 10, 2017 as the earliest possible priority date, though the first ground in my
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`analysis relies entirely on art that predates the claimed priority date of November
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`4, 2011.
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`24.
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`I have been informed that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the
`
`invention was made to a person having ordinary skill in the art to which the subject
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`11
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`matter pertains. I have also been informed by counsel that the obviousness analysis
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`takes into account factual inquiries including the level of ordinary skill in the art,
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`the scope and content of the prior art, and the differences between the prior art and
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`the claimed subject matter.
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`25.
`
`I have been informed by counsel that the Supreme Court has
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
`
`obtain predictable results; (c) use of a known technique to improve a similar device
`
`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
`
`in the prior art that would have led one of ordinary skill to modify the prior art
`
`reference or to combine prior art reference teachings to arrive at the claimed
`
`invention.
`
`V. BACKGROUND
`26. Mobile devices such as smart phones provide users with a wide
`
`variety of communication mechanisms such as phone calls, text messages, internet
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`12
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`access, as well as providing other features. Mobile devices typically include a
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`Inter Partes Review of U.S. 10,622,842
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`
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`built-in or detachable battery pack that is chargeable. Some types of devices may
`
`be charged wirelessly using principles of induction. Specifically, a coil on the
`
`charger is inductively coupled with a coil in a phone or other wirelessly chargeable
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`device. As will be described in more detail below, the ’842 Patent claims no more
`
`than what was already known in the art with regard to such coils.
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`VI. OVERVIEW OF THE ’842 PATENT
`27. The ’842 patent generally relates to a “wireless power receiver.” ’842
`
`Patent, Abstract. The claims of the ’842 patent are directed to a wireless power coil
`
`embedded within a plurality of layers. Claim 1 recites “a first layer,” “a wireless
`
`power receiving coil on the first layer,” and “a second layer on the wireless power
`
`receiving coil.” The manner in which the wireless power coil is embedded between
`
`the two layers is captured by reciting two separate regions: “a first region in which
`
`at least one of the first layer and the second layer overlaps the wireless power
`
`receiving coil” and “a second region in which at least one of the first layer and the
`
`second layer does not overlap the wireless power receiving coil.” The claim further
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`recites “a first distance … in the first region is greater than a second distance … in
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`the second region.” This arrangement is shown in Fig. 9 below.
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`second
`region
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`first region
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`second layer
`
`
`
`wireless power
`receiving coil
`
`first layer
`’842 Patent, Fig. 9.
`
`shield layer
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`
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`28. The specification describes “a first region 411,” where “at least one of
`
`the layers can overlap 405 the wireless receiving coil in a vertical direction 400
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`perpendicular to an upper surface of the shielding unit 380.” ’842 Patent, 8:33-36.
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`The ’842 patent also describes “a second region 412,413,” where “at least one of
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`the layers does not overlap the wireless power receiving coil in the vertical
`
`direction 400.” ’842 Patent, 8:36-38. According to the ’842 patent, “a first gap d1
`
`or a first distance d1, measured in the vertical direction 400, between layers in the
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`first region 411 can be greater than a second gap d2 or a second distance d2,
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`measure in the vertical direction, between layers in the second region 412,413.”
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`Phinney Declaration
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`’842 Patent, 8:38-43.2
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`29. As I explain below, the arrangement of a wireless power receiving
`
`coil between layers as claimed in the ’842 patent was not new when the ’842 patent
`
`was filed.
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`VII. CLAIM CONSTRUCTION
`30.
`
`It is my understanding that in order to properly evaluate the ’842
`
`Patent, the terms of the claims must first be interpreted. It is my understanding that
`
`for the purposes of this inter partes review, the claims are to be construed under
`
`the so-called Phillips standard, under which claim terms are given their ordinary
`
`and customary meaning as would be understood by one of ordinary skill in the art
`
`in light of the specification and prosecution history, unless the inventor has set
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`forth a special meaning for a term.
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`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`31.
`
`I have been asked to provide my opinion as to whether the Challenged
`
`Claims of the ’842 Patent would have been obvious in view of the prior art. The
`
`discussion below provides a detailed analysis of how the prior art references
`
`
`2 I note that the language related to the wireless coil being between the layers 301
`
`in this arrangement was added to the specification during the prosecution of the
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`’842 patent. This is relevant to the priority date discussion below at VIII.B.1.
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`identified below teach the limitations of the Challenged Claims of the ’842 Patent.
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`32. As part of my analysis, I have considered the scope and content of the
`
`prior art and any differences between the alleged invention and the prior art. I
`
`describe in detail below the scope and content of the prior art, as well as any
`
`differences between the alleged invention and the prior art, on an element-by-
`
`element basis for each Challenged Claims of the ’842 Patent.
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`33. As described in detail below, the alleged invention of the Challenged
`
`Claims would have been obvious in view of the teachings of the identified prior art
`
`references as well as the knowledge of a POSITA.
`
`A. Ground 1: Claims 1, 2, 5-7, 14-16, and 19-20 are obvious under 35
`U.S.C. § 103(a) over Suzuki.
`1.
`Summary of Suzuki
`34. Like the ’842 patent, Suzuki describes “a secondary side of [a]
`
`contactless power transmission apparatus” that includes “a power receiver 16.”
`
`Suzuki, Abstract, 4:49-50. Suzuki describes a plurality of layers, as illustrated in
`
`Fig. 9 below. Suzuki, Fig. 9.3
`
`
`3 For the sake of illustration, Fig. 9 of Suzuki is shown rotated 180 degrees (i.e.,
`
`upside down) throughout my declaration to be consistent with the orientation
`
`described in the ’842 patent. Specifically, the ’842 patent describes its power
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`16
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`radiation layer 174
`
`secondary coil 170
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`magnetic layer 171
`
`shield layer 172
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`Suzuki, Fig. 9 (annotated).
`
`35. Suzuki explains that its apparatus includes a “secondary coil block
`
`17” that includes “a magnetic layer 171, a shield layer 172 for shielding
`
`electromagnetic noise, and a heat insulation layer 173, which together are unified
`
`with the secondary coil 170.” Suzuki, 6:29-33. Suzuki’s coil 170 is positioned
`
`between two layers—a magnetic layer 171 and a radiation layer. The “radiation
`
`layer 174 [is] intervened between the battery cover 152 and the secondary coil
`
`170.” Suzuki, 9:17-18.
`
`
`receiver with the assumption the associated transmitter is “above” the receiver,
`
`whereas Suzuki describes its power receiver with the assumption the associated
`
`transmitter is “below” the receiver. For readability, the reference numerals have
`
`been flipped as well.
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`17
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`36. As shown in Fig. 9 below, the red double-sided arrow illustrates the
`
`distance between layers (magnetic layer 171 and radiation layer 173) in a first
`
`region (where the layers and coil overlap), which is greater than the distance
`
`between the layers in a second region (where the layers and coil do not overlap).
`
`first region
`
`second region
`
`radiation layer 174
`(second layer)
`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`
`shielding unit
`
`first distance
`between first and
`second layer in the
`first region
`Ex.1005, Fig. 9 (cropped, annotated).
`
`second distance
`between first and
`second layer in
`the second region
`
`37. Accordingly, Suzuki demonstrates that wireless power receivers were
`
`known in the prior art to include a variety of layers arranged with a wireless power
`
`receiving coil between layers as claimed in the ’842 patent.
`
`2.
`
`Claim 1
`
`[1.0] A wireless power receiver, comprising:
`38. Suzuki describes a contactless power transmission apparatus that
`
`includes a power transmitter and a power receiver (“wireless power receiver”):
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`Inter Partes Review of U.S. 10,622,842
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`FIGS. 1A, 1B and 2 show contactless power transmission apparatus
`1 in accordance with a first embodiment of the present invention. The
`apparatus 1 is broadly divided into a power transmitter 11 in a
`primary side and a power receiver 16 in a secondary side. The
`transmitter 11 and the receiver 16 include primary and secondary coils
`120 and 170 capable of electromagnetic coupling, respectively, and are
`configured to transmit electric power from the primary side to the
`secondary side by electromagnetic induction between the primary and
`secondary coils 120 and 170. Accordingly, the transmitter 11 and the
`receiver 16 can be separated from each other. The transmitter 11 and
`the receiver 16 are, but not limited to, a charger 10 (a primary device)
`and a cell phone 15 (secondary device), respectively.
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`Suzuki, 4:46-59.
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`wireless power receiver
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`Suzuki, Fig. 2
`39. Suzuki provides additional details of the secondary coil 170:
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`As shown in FIG. 3, the secondary coil block 17 in the secondary
`side further includes a magnetic layer 171, a shield layer 172 for
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`shielding electromagnetic noise, and a heat insulation layer 173,
`which together are unified with the secondary coil 170. That is, the
`secondary coil 170 is a planar coil and the magnetic layer 171 is
`laminated on at least one side (an upper surface) of the secondary coil
`170. The shield layer 172 is also laminated on at least the upper surface
`of the magnetic layer 171, and the heat insulation layer 173 is laminated
`on the upper surface of the shield layer 172. Thereby, the secondary
`coil block 17 is formed, and the other side (an lower surface) of the
`secondary coil 170 in the block 17 is stuck on the inner face of the
`battery cover 152 through adhesive. However, not limited to this, in the
`present invention, at least the magnetic layer may be laminated on one
`side of the secondary coil and unified with the secondary coil, and also
`the secondary coil block may be located at other part of the secondary
`device.
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`Suzuki, 6:29-46.
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`40. Suzuki’s device is shown in Fig. 9 below.4
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`4 The analysis herein relies on the embodiment of Fig. 9, which adds the radiation
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`layer 174. However, the description of Fig. 3 is applicable to the embodiment of
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`Fig. 9, given the similarity of reference numerals. See Ex.1005, 9:13-15.
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`coil block of
`wireless power
`receiver
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`Suzuki, Fig. 9 (annotated)
`41. Suzuki’s power receiver is a wireless power receiver because it is
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`described as part of a contactless power transmission apparatus.
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`42. Thus, because Suzuki teaches a contactless power transmission
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`apparatus that includes a power receiver, Suzuki renders obvious a “wireless power
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`receiver” as claimed.
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`[1.1] a shielding unit;
`43. Suzuki’s power receiver includes a shield layer 172 (“shielding unit”).
`
`As shown in FIG. 3, the secondary coil block 17 in the secondary side
`further includes a magnetic layer 171, a shield layer 172 for shielding
`electromagnetic noise, and a heat insulation layer 173, which together
`are unified with the secondary coil 170. That is, the secondary coil 170
`is a planar coil and the magnetic layer 171 is laminated on at least one
`side (an upper surface) of the secondary coil 170. The shield layer 172
`is also laminated on at least the upper surface of the magnetic layer 171,
`and the heat insulation layer 173 is laminated on the upper surface of
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`the shield layer 172. Thereby, the secondary coil block 17 is formed,
`and the other side (an lower surface) of the secondary coil 170 in the
`block 17 is stuck on the inner face of the battery cover 152 through
`adhesive. However, not limited to this, in the present invention, at least
`the magnetic layer may be laminated on one side of the secondary coil
`and unified with the secondary coil, and also the secondary coil block
`may be located at other part of the secondary device.
`
`Suzuki, 6:29-46.
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`shielding unit
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`Suzuki, Fig. 9 (annotated)
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`44. Suzuki teaches that the “shield layer 172 is, for example, copper foil
`
`or aluminum foil.” Suzuki, 7:40-42.
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`45. Thus, because Suzuki teaches a shield layer, Suzuki renders obvious
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`“a shielding unit” as claimed.
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`[1.2] a first layer on the shielding unit;
`46. Suzuki teaches a magnetic layer 171 (“first layer”) on the shielding
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`unit 172.
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`Inter Partes Review of U.S. 10,622,842
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`As shown in FIG. 3, the secondary coil block 17 in the secondary side
`further includes a magnetic layer 171, a shield layer 172 for shielding
`electromagnetic noise, and a heat insulation layer 173, which together
`are unified with the secondary coil 170. That is, the secondary coil 170
`is a planar coil and the magnetic layer 171 is laminated on at least one
`side (an upper surface) of the secondary coil 170. The shield layer 172
`is also laminated on at least the upper surface of the magnetic layer
`171, and the heat insulation layer 173 is laminated on the upper surface
`of the shield layer 172. Thereby, the secondary coil block 17 is formed,
`and the other side (an lower surface) of the secondary coil 170 in the
`block 17 is stuck on the inner face of the battery cover 152 through
`adhesive. However, not limited to this, in the present invention, at least
`the magnetic layer may be laminated on one side of the secondary coil
`and unified with the secondary coil, and also the secondary coil block
`may be located at other part of the secondary device.
`
`Suzuki, 6:29-46.
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`magnetic layer
`(first layer)
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`shielding unit
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`Suzuki, Fig. 9 (annotated)
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`47. Thus, because Suzuki’s device includes a magnetic layer 171 on the
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`shield layer 172, Suzuki renders obvious “a first layer on the shielding unit” as
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`Inter Partes Review of U.S. 10,622,842
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`claimed.
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`[1.3] a wireless power receiving coil on the first layer;
`48. Suzuki teaches a secondary coil 170 (“wireless power receiving coil”)
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`on the magnetic layer 171.
`
`As shown in FIG. 3, the secondary coil block 17 in the secondary side
`further includes a magnetic layer 171, a shield layer 172 for shielding
`electromagnetic noise, and a heat insulation layer 173, which together
`are unified with the secondary coil 170. That is, the secondary coil
`170 is a planar coil and the magnetic layer 171 is laminated on at
`least one side (an upper surface) of the secondary coil 170. The
`shield layer 172 is also laminated on at least the upper surface of the
`magnetic layer 171, and the heat insulation layer 173 is laminated on
`the upper surface of the shield layer 172. Thereby, the secondary coil
`block 17 is formed, and the other side (an lower surface) of the
`secondary coil 170 in the block 17 is stuck on the inner face of the
`battery cover 152 through adhesive. However, not limited to this, in the
`present invention, at least the magnetic layer may be laminated on one
`side of the secondary coil and unified with the secondary coil, and also
`the secondary coil block may be located at other part of the secondary
`device.
`
`Suzuki, 6:29-46.
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`wireless power
`receiving coil
`magnetic layer
`(first layer)
`
`shielding unit
`
`Suzuki, Fig. 9 (annotated)
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`49. Thus, because Suzuki teaches a secondary coil 170 on the magnetic
`
`layer 171, Suzuki renders obvious a “wireless power receiving coil on the first
`
`layer” as claimed.
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`[1.4] a second layer on the wireless power receiving coil;
`50. Suzuki teaches a “second layer” in the form of a radiation layer 174
`
`on the secondary coil 170, as shown in Fig. 9.
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`The power