Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and GOOGLE LLC
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.
`Patent Owner
`
`Patent No. 9,843,215
`
`______________________________________________
`
`DECLARATION OF DR. GARY WOODS
`
`Petitioner Samsung and Google Ex-1002, 0001
`
`
`Declaration of Gary Woods
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and GOOGLE LLC
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.
`Patent Owner
`
`Patent No. 9,843,215
`
`______________________________________________
`
`DECLARATION OF DR. GARY WOODS
`
`Petitioner Samsung and Google Ex-1002, 0001
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`
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`
`
`I.
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`Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
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`I, Gary Woods, hereby declare as follows.
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`INTRODUCTION
`1.
`I have been retained as an expert witness on behalf of Google LLC,
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`Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
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`(“Petitioner”) for the above-captioned inter partes review (IPR). I understand that
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`Petitioner challenges the validity of Claims 1, 4, 5, 8-13, and 17-22 of U.S. Patent
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`No. 9,843,215.
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`2.
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`I am over the age of eighteen (18) and otherwise competent to make
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`this declaration. I am being compensated for my time in connection with this IPR
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`at my standard consulting rate.
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`3.
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`I understand that the petition for inter partes review involves U.S.
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`Patent No. 9,843,215 (the “’215 Patent”), Ex-10011, which resulted from U.S.
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`Application No. 14/636,347 (the “’347 Application”). The ’347 Application was
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`filed on March 3, 2015 and claims priority to Korean Patent Application No. 10-
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`2014-0025290, filed on March 4, 2014, and names Jai Hoon Yeom, Sang Won
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`Lee, Seok Bae, So Yeon Kim, Jin Mi Noh, Ji Yeon Song, and Hee Jung Lee as the
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`inventors. See Ex-1001 at Cover. The ’215 Patent issued on December 12, 2017,
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`1 All exhibit citations refer to the exhibits attached to the Petition for Inter Partes
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`Review of U.S. Patent No. 9,843,215, filed concurrently herewith.
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`1
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`Petitioner Samsung and Google Ex-1002, 0002
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`Declaration of Gary Woods
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`from the ’347 application. I further understand that, according to USPTO records,
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`the ’215 Patent is currently assigned to Scramoge Technology Limited (“Patent
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`Owner” or “Scramoge”).
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`4.
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`I have been asked to assume that the earliest date to which the ’215
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`Patent is entitled to priority is March 4, 2014.
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`5.
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`In preparing this Declaration, I have reviewed the ’215 Patent and
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`considered each of the documents cited herein, in light of general knowledge in the
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`art. In formulating my opinions, I have relied upon my experience in the relevant
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`art and have also considered the viewpoint of a person of ordinary skill in the art.
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`6.
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`I am familiar with the technology at issue as of March 4, 2014, the
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`earliest claimed priority date of the ’215 Patent. I am also familiar with a person of
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`ordinary skill in the art with respect to the technology at issue as of the March 4,
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`2014 earliest claimed priority date of the ’215 Patent.
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`II. MY BACKGROUND AND QUALIFICATIONS
`7.
`Since 2008, I have been employed as a Professor in the Practice in the
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`Department of Electrical and Computer Engineering at Rice University in Houston,
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`Texas. Since 2020, my title has been Distinguished Professor in the Practice.
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`Before that, I worked as a postdoctoral fellow at the University of California, Santa
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`Barbara (1996-1998); at Intel Corporation (1998-2000); at Spectralane Inc. (2000-
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`2002); at Optonics (later Credence Systems Corp.) (2003-2006); and as an
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`independent consultant (2006-present). In the summers of 1988 and 1989 I worked
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`at Texas Instruments.
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`8. My educational background includes undergraduate degrees in
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`Physics and Electrical Engineering from Rice University in 1988 and an MS
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`(1991) and Ph.D. (1997) in Applied Physics from Stanford University.
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`9.
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`I am familiar with patents both as an inventor and as chief technology
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`officer in charge of the patent portfolio of a company I co-founded, Spectralane. I
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`am an inventor on 16 issued and one pending US utility patents. These patents deal
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`with otpo-electronics, integrated circuits, signal processing, and
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`telecommunications.
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`10. With regard to wireless charging and wireless communication
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`specifically, I have worked on a number of design projects at Rice in this field.
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`Many of them were year-long capstone design projects, where I was the technical
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`mentor on the project. Before the priority date, I have worked on projects involving
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`wireless power delivery such as transcutaneous charging of biomedical implants,
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`wirelessly powering a CO2 sensor for the International Space Station, using RFID
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`to track bikers in a relay race, and treating cancer with microwave-absorbing
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`implants. Projects with a significant charging but not wireless aspect include
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`charging cellphones with supercapacitors and with human-powered generators, and
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`harvesting energy from a shock absorber. I have supervised numerous projects
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`Declaration of Gary Woods
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`involving significant wireless networking aspects, including antenna design,
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`covering protocols including Bluetooth, WiFi, ZigBee, and Bluetooth Low Energy.
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`11. After the priority date I have continued working in the wireless space.
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`I have supervised a number of capstone projects involving significant wireless
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`aspects, including wirelessly powering a multi-element pacemaker; an 11 GHz
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`real-time 4x4 imaging radar array; sending video over cellphone links for
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`ambulance telemedicine; ultra-low power wireless EEG transmission; several off-
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`grid internet-of-things (IOT) systems; and several wirelessly transmitting medical
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`devices.
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`12. Outside of capstone projects, I have been involved in research
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`activities related to this case including developing an experimental setup with the
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`highest magnetic field in Texas, developing a solar-powered, IOT flood-sensor
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`network for Houston, and developing a terahertz generation and detection system.
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`13.
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`In my educational activities, I regularly teach a laboratory course that
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`includes a final project of building and testing a near-field communication system.
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`I have also developed educational demonstrations for classroom use involving
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`original “crystal” AM radios based on homemade cuprous-oxide rectifiers.
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`14.
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`In formulating my opinions, I have relied upon my training,
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`knowledge, and experience in the relevant art. A copy of my current curriculum
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`vitae is provided as Ex-1003, and it provides a comprehensive description of my
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`academic, employment, research, and professional history.
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`15. With my extensive experience in the field of wireless charging and
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`wireless communication systems, I am qualified to provide an opinion as to what a
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`person of ordinary skill in the art would have understood, known, or concluded as
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`of March 4, 2014. I have been asked to opine on the state of the art as of March 4,
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`2014, which I understand is the earliest claimed priority date of the ’215 Patent.
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`III. LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS
`16.
`In formulating my opinions, I have considered the Exhibits to the ’215
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`IPR Petition and all documents cited in this declaration.
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`IV. RELEVANT LEGAL STANDARDS
`17.
`I am not an attorney. For the purposes of this declaration, I have been
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`informed about certain aspects of the law that are relevant to my opinions. My
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`understanding of the law was provided to me by Petitioner’s attorneys. Counsel has
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`provided me with various legal standards that I understand apply to my analysis.
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`A.
`18.
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`Prior Art and Anticipation
`I understand that the petitioner for inter partes review may request the
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`cancelation of one or more claims of a patent based on grounds available under 35
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`U.S.C. § 102 and 35 U.S.C. § 103 using prior art that consists of patents and
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`printed publications.
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`19.
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`I understand that § 102 specifies when a challenged claim is invalid
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`
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`for lacking novelty over the prior art, and that this concept is also known as
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`“anticipation.” I understand that a prior art reference anticipates a challenged
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`claim, and thus renders it invalid by anticipation, if all elements of the challenged
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`claim are disclosed in the prior art reference. I understand the disclosure in the
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`prior art reference can be either explicit or inherent, meaning it is necessarily
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`present or implied. I understand that the prior art reference does not have to use the
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`same words as the challenged claim, but all of the requirements of the claim must
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`be disclosed so that a person of ordinary skill in the art could make and use the
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`claimed subject-matter.
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`20.
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`I understand that § 102 also defines what is available for use as a prior
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`art reference to a challenged claim. Under § 102(a)(1), a challenged claim is
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`anticipated if it was patented, described in a printed publication, or in public use,
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`on sale, or otherwise available to the public before the effective filing date of the
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`claimed invention. Under § 102(a)(2), I understand a challenged claim is
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`anticipated if it was described in a patent issued under section 151, or in an
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`application for patent published or deemed published under section 122(b), in
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`which the patent or application, as the case may be, names another inventor and
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`was effectively filed before the effective filing date of the claimed invention.
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`21.
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`I understand that a challenged claim’s date of invention is presumed
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`
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`to be the challenged patent’s filing date.
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`22.
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`I understand that the filing date of patent is generally the filing date of
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`the application filed in the United States that issued as the patent. However, I
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`understand that a patent may be granted an earlier effective filing date if the patent
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`owner properly claimed priority to an earlier patent application.
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`23.
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`I understand that when a challenged claim covers several structures,
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`either generically or as alternatives, the claim is deemed anticipated if any of the
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`structures within the scope of the claim is found in the prior art reference.
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`24.
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`I understand that when a challenged claim requires selection of an
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`element from a list of alternatives, the prior art teaches the element if one of the
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`alternatives is taught by the prior art.
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`B. Obviousness
`25.
`I understand that a claim is unpatentable if it would have been obvious
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`to a person of ordinary skill in the art at the time the alleged invention was made,
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`even if that claim is not anticipated. I understand that a claim could have been
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`obvious from a single prior art reference or from a combination of two or more
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`prior art references.
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`26.
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`I understand that an obviousness analysis requires an understanding of
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`the scope and content of the prior art, any differences between the alleged
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`invention and the prior art, and the level of ordinary skill in evaluating the
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`pertinent art.
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`27.
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`I further understand that certain factors may support or rebut the
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`obviousness of a claim. I understand that such secondary considerations include,
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`among other things, commercial success of the patented invention, skepticism of
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`those having ordinary skill in the art at the time of invention, unexpected results of
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`the invention, any long-felt but unsolved need in the art that was satisfied by the
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`alleged invention, the failure of others to make the alleged invention, praise of the
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`alleged invention by those having ordinary skill in the art, and copying of the
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`alleged invention by others in the field. I understand that there must be a nexus,
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`that is, a connection, between any such secondary considerations and the alleged
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`invention. I also understand that contemporaneous and independent invention by
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`others is a secondary consideration tending to show obviousness.
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`28.
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`I further understand that a claim would have been obvious if it unites
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`old elements with no change to their respective functions, or alters prior art by
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`mere substitution of one element for another known in the field, and that
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`combination yields predictable results. Also, I understand that obviousness does
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`not require physical combination/bodily incorporation, but rather consideration of
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`what the combined teachings would have suggested to persons of ordinary skill in
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`the art at the time of the alleged invention.
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`29. While it may be helpful to identify a reason for this combination, I
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`
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`understand that there is no rigid requirement of finding an express teaching,
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`suggestion, or motivation to combine within the references. When a product is
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`available, design incentives and other market forces can prompt variations of it,
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`either in the same field or a different one. If a person of ordinary skill in the art can
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`implement a predictable variation, obviousness likely bars its patentability. For the
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`same reason, if a technique has been used to improve one device and a person of
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`ordinary skill in the art would recognize that it would improve similar devices in
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`the same way, using the technique would have been obvious. I understand that a
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`claim would have been obvious if a person of ordinary skill in the art would have
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`had reason to combine multiple prior art references or add missing features to
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`reproduce the alleged invention recited in the claims.
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`30.
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`I am not aware of any allegations by the named inventors of the ’215
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`Patent or any assignee of the ’215 Patent that any secondary considerations tend to
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`rebut the obviousness of any claim of the ’215 Patent discussed in this declaration.
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`31.
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`I understand that in considering obviousness, it is important not to
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`determine obviousness using the benefit of hindsight derived from the patent being
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`considered.
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`32. The analysis in this declaration is in accordance with the above-stated
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`legal principles.
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`C.
`33.
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`Claim Construction
`I understand that a patent may include two types of claims,
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`independent claims and dependent claims. I understand that an independent claim
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`stands alone and includes only the limitations it recites. I understand that a
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`dependent claim depends from an independent claim or another dependent claim. I
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`understand that a dependent claim includes all the limitations that it recites in
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`addition to the limitations recited in the claim (or claims) from which it depends.
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`34.
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`In comparing the challenged claims to the prior art, I have carefully
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`considered the patent and its file history in light of the understanding of a person of
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`skill at the time of the alleged invention.
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`35.
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`I understand that to determine how a person of ordinary skill would
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`have understood a claim term, one should look to sources available at the time of
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`the alleged invention that show what a person of skill in the art would have
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`understood disputed claim language to mean. It is my understanding that this may
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`include what is called “intrinsic” evidence as well as “extrinsic” evidence.
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`36.
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`I understand that, in construing a claim term, one should primarily
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`rely on intrinsic patent evidence, which includes the words of the claims
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`themselves, the remainder of the patent specification, and the prosecution history. I
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`understand that extrinsic evidence, which is evidence external to the patent and the
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`prosecution history, may also be useful in interpreting patent claims when the
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`intrinsic evidence itself is insufficient. I understand that extrinsic evidence may
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`include principles, concepts, terms, and other resources available to those of skill
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`in the art at the time of the invention.
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`37.
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`I understand that words or terms should be given their ordinary and
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`accepted meaning unless it appears that the inventors were using them to mean
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`something else or something more specific. I understand that to determine whether
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`a term has special meaning, the claims, the patent specification, and the
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`prosecution history are particularly important, and may show that the inventor gave
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`a term a particular definition or intentionally disclaimed, disavowed, or
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`surrendered claim scope.
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`38.
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`I understand that the claims of a patent define the scope of the rights
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`conferred by the patent. I understand that because the claims point out and
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`distinctly claim the subject matter which the inventors regard as their invention,
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`claim construction analysis must begin with and is focused on the claim language
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`itself. I understand that the context of the term within the claim as well as other
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`claims of the patent can inform the meaning of a claim term. For example, because
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`claim terms are normally used consistently throughout the patent, how a term is
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`used in one claim can often inform the meaning of the same term in other claims.
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`Differences among claims or claim terms can also be a useful guide in
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`understanding the meaning of particular claim terms.
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`39.
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`I understand that a claim term should be construed not only in the
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`
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`context of the particular claim in which the disputed term appears, but in the
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`context of the entire patent, including the entire specification. I understand that
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`because the specification is a primary basis for construing the claims, a correct
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`construction must align with the specification.
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`40.
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`I understand that the prosecution history of the patent as well as art
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`incorporated by reference or otherwise cited during the prosecution history are also
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`highly relevant in construing claim terms. For instance, art cited by or incorporated
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`by reference may indicate how the inventor and others of skill in the art at the time
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`of the invention understood certain terms and concepts. Additionally, the
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`prosecution history may show that the inventors disclaimed or disavowed claim
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`scope, or further explained the meaning of a claim term.
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`41. With regard to extrinsic evidence, I understand that all evidence
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`external to the patent and prosecution history, including expert and inventor
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`testimony, dictionaries, and learned treatises, can also be considered. For example,
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`technical dictionaries may indicate how one of skill in the art used or understood
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`the claim terms. However, I understand that extrinsic evidence is considered to be
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`less reliable than intrinsic evidence, and for that reason is generally given less
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`weight than intrinsic evidence.
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`42.
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`I understand that in general, a term or phrase found in the introductory
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`
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`words or preamble of the claim, should be construed as a limitation if it recites
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`essential structure or steps, or is necessary to give meaning to the claim. For
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`instance, I understand preamble language may limit claim scope: (i) if dependence
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`on a preamble phrase for antecedent basis indicates a reliance on both the preamble
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`and claim body to define the claimed invention; (ii) if reference to the preamble is
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`necessary to understand limitations or terms in the claim body; or (iii) if the
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`preamble recites additional structure or steps that the specification identifies as
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`important.
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`43. On the other hand, I understand that a preamble term or phrase is not
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`limiting where a challenged claim defines a structurally complete invention in the
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`claim body and uses the preamble only to state a purpose or intended use for the
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`invention. I understand that to make this determination, one should review the
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`entire patent to gain an understanding of what the inventors claim they invented
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`and intended to encompass in the claims.
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`44.
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`I understand that 35 U.S.C. § 112 ¶ 6 created an exception to the
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`general rule of claim construction called a “means plus function” limitation. These
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`types of terms and limitations should be interpreted to cover only the
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`corresponding structure described in the specification, and equivalents thereof. I
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`also understand that a limitation is presumed to be a means plus function limitation
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`if (a) the claim limitation uses the phrase “means for”; (b) the “means for” is
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`modified by functional language; and (c) the phrase “means for” is not modified by
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`sufficient structure for achieving the specified function.
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`45.
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`I understand that a structure is considered structurally equivalent to
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`the corresponding structure identified in the specification only if the difference
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`between them are insubstantial. For instance, if the structure performs the same
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`function in substantially the same way to achieve substantially the same result. I
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`further understand that a structural equivalent must have been available at the time
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`of the issuance of the claim.
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`V.
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`PERSON OF ORDINARY SKILL IN THE ART
`46.
`I understand that factors that may be considered in establishing the
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`level of ordinary skill in the art relevant to the patent-in-suit include the type of
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`problems encountered in the art, prior art solutions to those problems, rapidity with
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`which innovations are made, sophistication of the technology, and educational
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`level of active workers in the field.
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`47.
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`I understand that a person of ordinary skill in the art (“POSITA”) is
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`one who is presumed to be aware of all pertinent art, thinks along conventional
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`wisdom in the art, and is a person of ordinary creativity. A POSITA would have
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`had knowledge of wireless charging systems and related technologies as of March
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`4, 2014.
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`48. One of ordinary skill in the art would have had a bachelor’s degree in
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`
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`electrical engineering, computer engineering, applied physics, or a related field,
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`and at least one year of experience in the research, design, development, and/or
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`testing of wireless charging systems, or the equivalent, with additional education
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`substituting for experience and vice versa.
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`49. Based on my education and experience, I would have easily exceeded
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`the criteria for a POSITA in March 4, 2014, and I still exceed it today.
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`VI. OVERVIEW OF THE ’215 PATENT
`50. The ’215 Patent, entitled “Wireless Charging and Communication
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`Board and Wireless Charging and Communication Device,” is directed to a
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`“wireless charging and communication board, and a wireless charging and
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`communication device” that includes receiver 100 and transmitter 500 which may
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`enable “wireless power conversion (WPC) and near field communication (NFC).”
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`Ex-1001at 2:53-59. Transmitter 500 may include “the first transmission coil
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`pattern 520 . . . for wireless power conversion (WPC), and the second transmission
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`coil pattern 530 . . . for near field communication (NFC).” Id. at 2:65-3:2.
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`51. As shown in Figure 1 above and Figure 3 below, the wireless charging
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`and communication board includes soft magnetic layers 220, 230 and polymeric
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`material layers 310, 312 “arranged on one surface and the other surface of the soft
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`magnetic layer 220, 230, and extending longer than an exposed portion of the soft
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`magnetic layer 220, 230.” Ex-1001, 5:27-30.
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`Ex-1001, FIG. 3 (annotated).
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`52. The ’215 Patent discloses that “a coil pattern 120, 130 [is] arranged on
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`the polymeric material layer 310, 312.” Id. at 5:30-31. The ’215 Patent also
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`discloses that the wireless charging and communication board includes “a
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`polymeric material connector 313 intended for connecting the first polymeric
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`material layer 310 and the second polymeric material layer 312 and surrounding
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`the exposed portion of the soft magnetic layer 220.” Id. at 5:32-37. The ’215 Patent
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`explains that polymeric material connector 313 may prevent water penetration
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`from the outside. Id. at 5:45-47.
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`53. The ’215 Patent discloses that “[t]he polymeric material layer 310,
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`312 may be adhered to the soft magnetic layer 220, 230 via an adhesive layer 315.”
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`Ex-1001, 3:52-54. Also, “[t]he polymeric material layer 310, 312 may contain any
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`one material of polyethylene, polyacrylic, polyimide, polyamide, and
`
`polyurethane.” Id. at 3:54-56.
`
`54. As explained in detail below, the ’215 Patent claims are disclosed or
`
`taught in view of the prior art.
`
`VII. PROSECUTION HISTORY OF THE ’215 PATENT
`55.
`I understand the application leading to the ’215 Patent, U.S. Patent
`
`Application No. 14/636,347, was filed on March 3, 2015. It claims priority to
`
`Korean Patent No. 10-2014-0025290 filed on March 4, 2014.
`
`56. On August 25, 2016, the examiner issued a non-final rejection, stating
`
`that Claims 1-8, 12-14, and 16-17 were rejected as being disclosed by Korean
`
`Patent Application 2013-00721810 to Lee (“Lee”). Ex-1004, 132-135. Claim 9 was
`
`rejected as being taught by Lee in view of U.S. 2006/0266435 to Yang et al. Id. at
`
`135-136. Claims 10-11 and 15 were rejected as being taught by Lee in view of
`
`U.S. 6,331,763 to Thomas et al. Id. at 136-137.
`
`57. On November 21, 2016, Applicant amended the Specification and
`
`Claims 1-8 and 10-12. Ex-1004, 144-156. To overcome the references cited by the
`
`examiner, Applicant limited the claims to require encapsulating the magnetic layer
`
`by having the top polymeric layer connect to the bottom polymeric layer. Ex-1004,
`
`150-151.
`
`18
`
`Petitioner Samsung and Google Ex-1002, 0019
`
`
`
`Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
`
`58. After receiving a first Notice of Allowance, the Applicant filed a
`
`
`
`petition to withdraw from issue and a request for continued examination to further
`
`amend the claims to require a device having first and second soft magnetic layers
`
`as part of the claimed plurality of magnetic layers, as well as the type of material
`
`that may comprise the first and second soft magnetic layers. Ex-1004 at 188-189.
`
`The Office issued a second Notice of Allowance on August 11, 2017. Ex-1004 at
`
`211.
`
`VIII. PRIORITY DATE OF THE ’215 PATENT
`59.
`I understand that Petitioner takes no position on the proper priority
`
`date of the ’215 Patent. I have been asked to assume that the earliest date to which
`
`the ’215 Patent is entitled to priority is March 4, 2014. Thus, for the purposes of
`
`this Declaration, I have assumed the priority date of the ’215 Patent is March 4,
`
`2014.
`
`IX. CLAIM CONSTRUCTION
`60.
`I do not believe that any term requires explicit construction to resolve
`
`the issues presented in this Petition. I ascribe the plain meaning to each claim term,
`
`as that plain meaning would have been understood by a POSITA.
`
`61.
`
`I reserve the right to offer opinions on any claim constructions
`
`proposed in this proceeding or to offer opinions on additional constructions in the
`
`district court.
`
`19
`
`Petitioner Samsung and Google Ex-1002, 0020
`
`
`
`Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
`
`
`X. GROUNDS FOR FINDING THE CHALLENGED CLAIMS INVALID
`62.
`I understand that Petitioner requests cancellation of Claims 1, 4, 5, 8-
`
`13, and 17-22 of the ’215 Patent.
`
`A. Overview of the Prior Art References
`1.
`Overview of Sakuma (Ex-1005)
`63. Sakuma, titled “Soft magnetic sheet, module including the sheet and
`
`non-contact power transmission system including the module,” is U.S. Patent
`
`Publication No. 2010/0007215, published on January 14, 2010. Ex-1005 at Cover.
`
`I have been informed that Sakuma qualifies as prior art under at least post-AIA 35
`
`U.S.C. §102(a)(1), based on its publication date.
`
`64. Sakuma discloses a contactless power transmission system employed
`
`in a hand-held device or an IC tag system for electric power supply. Ex-1005,
`
`¶¶[0002]-[0003], [0026]-[0034].
`
`65. As shown in Figure 1 below, Sakuma’s contactless power
`
`transmission system includes a power receiver 1, which in turn includes a housing
`
`13 which houses a soft magnetic sheet 11, a coil sheet 12, and circuit board 45. Ex-
`
`1005, ¶¶[0026]-[0027], FIG. 1. Figure 1 also shows the power transmitter 2 which
`
`supplies power to the power receiver 1, where the power transmitter 2 includes a
`
`housing 23 which houses a soft magnetic sheet 21, a coil sheet 22, and circuit
`
`board 24. Ex-1005, ¶¶[0033]-[0034], FIG. 1. Power is transmitted from the
`
`20
`
`Petitioner Samsung and Google Ex-1002, 0021
`
`
`
`Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
`
`
`transmitter coil of coil sheet 22 to the receiver coil of coil sheet 12. Ex-1005,
`
`¶[0034], FIG. 1.
`
`
`
`Ex-1005, FIG. 1.
`
`2.
`Overview of Suzuki (Ex-1006)
`66. Suzuki, titled “Mobile Device and Combo Coil Module,” is U.S.
`
`Patent No. 9,515,513, which issued from U.S. Application No. 13/892,930 filed
`
`May 13, 2013. Ex-1006 at Cover. I have been informed that Suzuki qualifies as
`
`prior art under at least post-AIA 35 U.S.C. §102(a)(2), based on its filing date.
`
`67. Suzuki is directed to mobile devices where “a combo coil module [] is
`
`incorporated in such a mobile device, the combo coil combining a near field
`
`communication [NFC] antenna coil for near field communication, and a wireless
`
`21
`
`Petitioner Samsung and Google Ex-1002, 0022
`
`
`
`Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
`
`
`power receiving coil for wireless charging.” Ex-1006, 1:6-15. Suzuki discloses that
`
`its portable device includes an NFC coil 3 to implement the device’s NFC
`
`functionality. Ex-1006, 3:18-21 (“As shown in FIG. 1A, the exemplary combo coil
`
`module 1 may include a wireless power receiving coil 4 concentrically disposed
`
`within an inner edge 3a of an NFC antenna coil 3.”), 1:44-54.
`
`
`
`Ex-1006, FIG. 2B.
`
`3.
`Overview of Hiroki (Ex-1007)
`68. Hiroki, titled “Magnetic Sheet,” is Japanese Patent Publication No.
`
`2008294347, published on December 4, 2008. Ex-1007 at Cover. I have been
`
`informed that Hiroki qualifies as prior art under at least post-AIA 35 U.S.C.
`
`§102(a)(1), based on its publication date. A certified translation of Hiroki is
`
`included as Ex-1007. The original Japanese Patent Publication is included as Ex-
`
`1008.
`
`69. Hiroki discloses “a magnetic sheet for preventing errors in
`
`writing/reading information on a non-contact data receiving and transmitting body
`
`such as a non-contact IC card.” Ex-1007, [0001]. As shown in Figure 3, the
`
`22
`
`Petitioner Samsung and Google Ex-1002, 0023
`
`
`
`Inter Partes Review of U.S. Patent No. 9,843,215
`Declaration of Gary Woods
`
`
`magnetic sheet 10 and a desired non-contact type data receiver / transmitter 21, 22,
`
`23 are stored in a storage body, such as a wallet or case, because magnetic sheet 10
`
`is provided with a magnetic layer and is thin. Id. at [0008], [0025].
`
`
`
`Ex-1007, Fig. 3.
`
`70. As shown in Figure 1(b) below, Hiroki discloses an embodiment of
`
`magnetic sheet 10 that includes “first magnetic layer 12” and “laminated sheet 14
`
`[] composed of a second magnetic layer 13.” Ex-1007, [0010]. The first an
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