`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`IPR2022-00529
`U.S. Patent No. 10,193,392
`_____________________
`
`
`DECLARATION OF DR. JOSHUA PHINNEY,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
`
`
`
`
`
`
`
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`1
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`Phinney Declaration
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`Inter Partes Review of U.S. 10,193,392
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`TABLE OF CONTENTS
`
`Introduction ...................................................................................................... 4
`I.
`Qualifications and Professional Experience .................................................... 5
`II.
`Level of Ordinary Skill in the Art ................................................................... 9
`III.
`IV. Relevant Legal Standards .............................................................................. 10
`Background .................................................................................................... 13
`V.
`VI. Overview of the ’392 Patent .......................................................................... 17
`VII. Claim Construction ........................................................................................ 21
`VIII. Identification of how the Claims are Unpatentable ....................................... 22
`Ground 1: Claims 1 and 6 are obvious in view of Hui (Figs. 1a
`A.
`and 5b). ................................................................................................ 23
`Summary of Hui ............................................................ 23
`1.
`Claim 1 ........................................................................... 27
`2.
`Claim 6 ........................................................................... 55
`3.
`Ground 2: Claims 2-4 are obvious in view of Hui (Figs. 1a and
`5b) and Taylor. .................................................................................... 58
`1.
`Summary of Taylor ........................................................ 58
`Reasons to Combine Hui and Taylor ............................. 61
`2.
`Claim 2 ........................................................................... 65
`3.
`Claim 3 ........................................................................... 72
`4.
`Claim 4 ........................................................................... 74
`5.
`Ground 3: Claims 1, 5, and 7-8 are obvious in view of Hui
`(Figs. 1b and 2a) .................................................................................. 75
`6.
`Summary of Hui (Figs. 1b and 2a) ................................ 76
`
`C.
`
`B.
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`2
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`Claim 1 ........................................................................... 78 
`7. 
`Claim 5 ......................................................................... 107 
`8. 
`Claim 7 ......................................................................... 110 
`9. 
`Claim 8 ......................................................................... 113 
`10. 
`IX.  Conclusion ................................................................................................... 117 
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`3
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`I, Joshua Phinney, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
`
`Inter Partes Review of U.S. 10,193,392
`
`
`
`1.
`
`I am making this declaration at the request of Apple, Inc. in the matter
`
`of the Inter Partes Review of U.S. Patent No. 10,193,392 (“the ’392 patent”) to
`
`Bae et al.
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate. 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.
`
`3.
`
`I have been asked to provide my opinions regarding whether claims 1-
`
`8 (“the Challenged Claims”) of the ’392 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 ’392 Patent, Ex.1001;
`
`the prosecution history of the ’392 Patent (“’392 File History”),
`
`4.
`
`a.
`
`b.
`
`Ex.1002;
`
`c.
`
`U.S. Patent Publication No. 2011/0199045 to Hui et al. (“Hui”),
`
`Ex.1005; and
`
`
`
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`4
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`Inter Partes Review of U.S. 10,193,392
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`d.
`
`5.
`
`U.S. Patent No. 10,250,083 to Taylor et al. (“Taylor”).
`
`In forming the opinions expressed below, I have considered:
`
`the documents listed above;
`
`the relevant legal standards, including the standard for obviousness,
`
`and any additional authoritative documents as cited in the body of this
`
`declaration; and
`
`my own knowledge and experience based upon my work in the field
`
`of networking as described below, as well as the following materials.
`
`a.
`
`b.
`
`c.
`
`U.S. Patent No. 9,461,479 to Chae et al. (“Chae”), Ex.1006;
`
`U.S Patent No. 9,509,168 to Ye et al. (“Ye”), Ex.1007;
`
`IEEE 100: The Authoritative Dictionary of IEEE Standards Terms
`
`(Seventh Edition), 2000, Ex.1008;
`
`d.
`
`U.S. Patent No. 8,129,864 to Baarman et al. (“Baarman”), Ex.1009;
`
`and
`
`e.
`
`f.
`
`6.
`
`added.
`
`U.S. Patent No. 9,384.885 to Karalis et al. (“Karalis”);
`
`U.S. Patent No. 9,425,864 to Staring et al. (“Staring”).
`
`Unless otherwise noted, all emphasis in any quoted material has been
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`
`7. My complete qualifications and professional experience are described
`
`
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`5
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`in my Curriculum Vitae, a copy of which can be found in Exhibit 1004. The
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`Inter Partes Review of U.S. 10,193,392
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`following is a brief summary of my relevant qualifications and professional
`
`experience.
`
`8.
`
`I am a Principal Engineer in the Electrical Engineering and Computer
`
`Science practice at Exponent, an engineering and scientific consulting firm
`
`headquartered at 149 Commonwealth Drive, Menlo Park, California 94025. I
`
`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.
`
`9. My master’s thesis at MIT focused on the miniaturization of power
`
`converters, by reducing the energy storage and improving the performance of
`
`inductors. As part of this work, I designed, tested, and constructed ferrite, iron-
`
`powder, and air-core inductors, while minimizing magnetic losses. During this
`
`time, I invented with my advisor, Dr. David Perreault, an electrical component
`
`with a capacitive impedance and an inductance-cancellation feature provided by
`
`magnetically coupled windings. A filter having a capacitor with inductance
`
`cancellation provides enhanced performance over frequency compared with
`
`conventional capacitors. This work was later extended to a second patent, with
`
`magnetically coupled windings used to improve EMI filters and common-mode
`
`
`
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`6
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`chokes.
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`Inter Partes Review of U.S. 10,193,392
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`10. My doctoral work at MIT centered on miniaturization of power
`
`converters and magnetics. As part of my doctoral work, I constructed and modeled
`
`planar magnetic systems, including magnetically coupled, printed magnetic coils.
`
`By incorporating such compact, magnetic structures into power converters, the
`
`resulting converter enjoyed multiple benefits, including waveform-shaping and
`
`reduction of switch stresses. Through the modeling associated with this
`
`dissertation, I become proficient in methods for analyzing the inductances of
`
`packages and interconnects, especially planar or filamentous systems of
`
`conductors.
`
`11.
`
` For my publications related to both my Master’s and Ph.D. thesis, I
`
`received the William M. Portnoy Prize Paper Award (2003) and the IEEE Power
`
`Electronics Society Transactions Prize Paper Award (2004).
`
`12. After earning my Ph.D., I joined Exponent and have led technical
`
`investigations to portable electronic devices, microcomputers, as well as industrial
`
`and consumer devices with embedded controllers. My job functions include
`
`analyzing hardware and software of these devices to understand their modes of
`
`failure, and testifying regarding these devices in legal matters involving patents
`
`and trade secrets.
`
`13. 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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`Inter Partes Review of U.S. 10,193,392
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`
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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
`
`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
`
`failures due to wear, dimensional changes, and triboelectric charging. In addition
`
`to testifying regarding resonant and inductive wireless-power transfer, I have
`
`consulted for industry regarding coil design, RFID and near-field communication
`
`(NFC) integrated circuits, modulation methods, and on-metal RFID tags.
`
`14.
`
`I have testified regarding the software-defined features, internal
`
`circuitry, and physical embodiments of electronic equipment. Regarding
`
`electronics, I have testified regarding power electronics in communication systems,
`
`wind turbines, grid-scale photovoltaic plants, and consumer electronics. In
`
`addition, I have testified regarding control and compensation in industrial
`
`controllers, voltage regulators, and switched-mode power converters. My
`
`experience with wireless RF circuitry includes failure analysis of amplifiers, power
`
`supplies, matching networks, and multiplexers in satellites, semiconductor-
`
`processing equipment, and medical devices.
`
`15. Regarding the mechanical elements of electronic equipment, I have
`
`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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`
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`housings for computerized equipment and peripherals. In particular, I have
`
`testified regarding detachable components as they are constructed in relation to the
`
`housing and underlying electronic assemblies, including printed circuit boards, flex
`
`printed circuits, and other connector assemblies within the housing of electronic
`
`equipment.
`
`16.
`
`In addition to the forgoing, I perform electromagnetic assessment of
`
`utility and communication infrastructure. These issues include permitting,
`
`interference, and environmental impact of radar, AC and HVDC transmission
`
`lines, substations, photovoltaic installations, generators, broadcast antennas, and
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`electrified mass transit systems.
`
`17.
`
`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
`
`parties thereto.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`
`18.
`
`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;
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`and (4) the prior art solutions to those problems.
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`19. A person of ordinary skill in the art (“POSITA”) in the field of the
`
`’392 Patent, as of its earliest possible filing date of January 8, 2014, would have
`
`been someone knowledgeable and familiar with the wireless charging arts that are
`
`pertinent to the ’392 Patent. That person would have a 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.
`
`20. 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
`
`priority date of the ’392 Patent (i.e., January 8, 2014). Unless otherwise stated,
`
`when I provide my understanding and analysis below, it is consistent with the level
`
`of a POSITA prior to the alleged priority date of the ’392 Patent.
`
`IV. RELEVANT LEGAL STANDARDS
`
`21.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’392 Patent, I am relying on certain basic
`
`legal principles that counsel have explained to me. These principles are discussed
`
`below.
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`
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`10
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`22.
`
`I understand that prior art to the ’392 Patent includes patents and
`
`printed publications in the relevant art that predate the alleged priority date of the
`
`alleged invention recited in the ’392 Patent. For purposes of this Declaration, I am
`
`applying January 8, 2014 as the earliest possible alleged priority date of the ’392
`
`
`
`Patent.
`
`23.
`
`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
`
`matter pertains. I have also been informed by counsel that the obviousness analysis
`
`takes into account factual inquiries including the level of ordinary skill in the art,
`
`the scope and content of the prior art, and the differences between the prior art and
`
`the claimed subject matter.
`
`24.
`
`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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`11
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`
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`choosing from a finite number of identified, predictable solutions, with a
`
`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.
`
`25.
`
`I further understand that certain factors may support or rebut the
`
`obviousness of a claim. I understand that such secondary considerations include,
`
`among other things, commercial success of the patented invention, skepticism of
`
`those having ordinary skill in the art at the time of invention, unexpected results of
`
`the invention, any long-felt but unsolved need in the art that was satisfied by the
`
`alleged invention, the failure of others to make the alleged invention, praise of the
`
`alleged invention by those having ordinary skill in the art, and copying of the
`
`alleged invention by others in the field. I understand that there must be a nexus—a
`
`connection—between any such secondary considerations and the alleged invention.
`
`I also understand that contemporaneous and independent invention by others is a
`
`secondary consideration tending to show obviousness.
`
`26.
`
`I am not aware of any allegations by the named inventor of the ’392
`
`Patent or any assignee of the ’392 Patent that any secondary considerations are
`
`relevant to the obviousness analysis of any Challenged Claim of the ’392 Patent.
`
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`V. BACKGROUND
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`Inter Partes Review of U.S. 10,193,392
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`
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`27. Mobile devices such as smartphones provide users with a wide variety
`
`of communication mechanisms such as phone calls, text messages, internet access,
`
`as well as providing other features. Mobile devices typically include a battery pack
`
`that is chargeable. See e.g., Ye, 1:21-23. Some types of devices may be charged
`
`wirelessly using principles of magnetic induction. See e.g., 4:58-67. Specifically, a
`
`coil on the charger is inductively coupled with a coil in a phone or other wirelessly
`
`chargeable device. See Chae, 5:1-6. To transfer power, an AC signal is applied to
`
`the primary coil. The AC signal is often generated using an inverter. See e.g., Ye,
`
`2:22-25.
`
`28.
`
`Inverters are used to transform a Direct Current (DC) signal into an
`
`AC signal. See Chae 10:52-59. One common type of inverter is a full-bridge
`
`inverter, which is made up of four transistors. Examples of such inverters are
`
`shown below.
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`Hui, Fig. 1a (partial).
`
`Chae, Fig. 23 (partial).
`
`Ye, Fig. 3.
`
`
`
`29. Full-bridge inverters more closely approximate a sine wave by
`
`producing a series of positive square pulses offset with a series of negative square
`
`pulses. Examples of the output voltage signals produced by such inverters are
`
`shown below.
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`Hui, Fig. 2a (partial).
`
`Hui, Fig. 5b (partial).
`
`Ye, Fig. 5 (partial).
`
`30. To create such output voltage signals, each of the four transistors in
`
`the inverter is individually controlled. The transistors are controlled to produce
`
`output voltage signals with desired frequency and duty cycle characteristics. See
`
`Ye, 2:25-30 (“In one embodiment the inverter is configured to generate the AC
`
`square wave with a duty cycle that results in a desired equivalent voltage output,
`
`effectively independent of the DC input voltage.”); Chae, 5:55-58 (“the power
`
`conversion unit 111 may further include a circuit for controlling the characteristics
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`of a used frequency”). Examples of the control signals for each of the transistors
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`are shown below.
`
`Hui, Fig. 2a (partial).
`
`Hui, Fig. 5b (partial).
`
`Chae, Fig. 28 (partial).
`
`
`31. As will be described in more detail below, the ’392 Patent claims no
`
`more than the common and well-known functionality of a full-bridge inverter, as
`
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`shown in the examples above.
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`VI. OVERVIEW OF THE ’392 PATENT
`
`32. The ’392 patent generally relates to “a wireless power transfer system
`
`having a receiving part for receiving power from a transmitting part.” ’392 Patent,
`
`abstract. The transmitting part includes “a power conversion part … and a control
`
`part for controlling the power conversion part.” ’392 Patent, abstract. “The power
`
`conversion part 130 may be configured of a full bridge inverter.” ’392 Patent,
`
`10:36-27. “The control part 140 may generate a frequency and a switching
`
`waveforms to drive the power conversion part 130 in consideration of the
`
`maximum power transfer efficiency, controlling the power to be transferred.” ’392
`
`Patent, 10:38-42. The power conversion part 130, which is a full-bridge inverter, is
`
`shown below in Fig. 8.
`
`“first switching
`element”
`
`“second
`switching
`element”
`
`“third
`switching
`element”
`
`“fourth
`switching
`element”
`
`’392 Patent, Fig. 8 (annotated).
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`33. The full-bridge inverter is driven by a set of control signals applied to
`
`
`
`each of the four transistors. “The first to fourth switching elements S1, S2, S3 and
`
`S4 each may conduct when a first to a fourth AC power control signals C11, C12,
`
`C21 and C22 provided from the control part 140 are in a high level, and open when
`
`in a low level.” Ex.1001, 12:21-24. Each of the control signals are associated with
`
`a specific transistor: C11 controls S1, C12 controls S2, C21 controls S3, and C22
`
`controls S4. Ex.1001, 12:62-67. Each control signal is applied to the gate terminal
`
`of a respective transistor to allow (or prevent) electric current flow between the
`
`terminals of that transistor. When the signal applied to a gate is high, electric
`
`current is allowed to flow through the terminals of that transistor. Ex.1001, 12:21-
`
`24. Conversely, when the signal applied to the transistor is low, electric current is
`
`prohibited from flowing through the terminals of the transistor. Ex.1001, 12:21-24.
`
`Depending on the state of the signals (high or low) that are being applied to each of
`
`the switching elements at a given instant in time, the output voltage VO (in purple)
`
`may be positive, near zero, or negative, as shown in the example of Fig. 12 below.
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`“first AC
`power control
`signal”
`
`“second AC
`power control
`signal”
`“third AC
`power control
`signal”
`
`“fourth AC
`power control
`signal”
`“positive
`polarity
`voltage”
`
`“output voltage”
`
`“negative
`polarity
`voltage”
`
`’392 patent, Fig. 12 (annotated).
`
`
`
`
`
`34. As can be seen from the signal diagram above, “when the first and
`
`fourth switching elements S1 and S4 are turned on by the first and fourth AC
`
`power control signals C11 and C22 that are PWM control signals provided from
`
`the control part 140 and the second and third switching elements S2 and S3 are
`
`turned off by the second and third AC power control signals C12 and C21, a
`
`positive polarity output voltage Vo” is produced at the output. Ex.1001, 12:61-67.
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`Conversely, “when the first and fourth switching elements S1 and S4 are turned off
`
`by the first and fourth AC power control signals C11 and C22 provided from the
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`control part 140 and the second and third switching elements S2 and S3 are turned
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`on by the second and third AC power control signals C12 and C21, a negative
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`polarity output voltage Vo” is produced at the output. Ex.1001, 13:1-7.
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`35. The ’392 patent describes and claims various characteristics of these
`
`AC power control signals, as well as their relationship to the output voltage. These
`
`characteristics include:
`
`(cid:120) Claim 1: “wherein when the first and fourth switching elements are
`
`turned on … the positive polarity output voltage is generated,” “when the
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`second and third switching elements are turned on … the negative
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`polarity output voltage is generated,” “wherein a duty ratio of the
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`positive polarity output voltage is determined by a falling time of the
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`fourth AC power control signal,” and “wherein a duty ratio of the
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`negative polarity output voltage is determined by a falling time of the
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`third AC power control signal”
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`(cid:120) Claim 3: “wherein the falling time of the fourth AC power control signal
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`is ahead of a falling time of the first AC power control signal”
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`(cid:120) Claim 4: “wherein the falling time of the third AC power control signal
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`is ahead of a falling time of the second AC power control signal”
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`(cid:120) Claim 6: “wherein the second and third switching elements are turned
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`off in a time interval when the first and fourth switching elements are
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`turned on,” “wherein the first and fourth switching elements are turned
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`off in a time interval when the second and third switching elements are
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`turned on”
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`(cid:120) Claim 7: “a first blank interval where high level intervals of the first and
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`second AC power control signals do not exist between a falling time of
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`the first AC power control signal and a rising time of the second AC
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`power control signal”
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`(cid:120) Claim 8: “wherein the control part defines a second blank interval where
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`high level intervals of the third and fourth AC power control signals do
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`not exist between a falling time of the third AC power control signal and
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`a rising time of the fourth AC power control signal”
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`36. As the prior art cited below illustrates, these claimed relationships
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`between the control signals and the output voltage simply describe the standard
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`operation of a full-bridge inverter.
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`VII. CLAIM CONSTRUCTION
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`37.
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`It is my understanding that in order to properly evaluate the ’392
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`Patent, the terms of the claims must first be interpreted. It is my understanding that
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`for the purposes of this inter partes review, the claims are to be construed under the
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`so-called Phillips standard, under which claim terms are given their ordinary and
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`customary meaning as would be understood by one of ordinary skill in the art in
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`light of the specification and prosecution history, unless the inventor has set forth a
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`special meaning for a term. It is my opinion that none of the claim terms require a
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`specific construction for the purposes of this declaration, and all will be given their
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`plain and ordinary meaning.
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`VIII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
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`38.
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`I have been asked to provide my opinion as to whether the Challenged
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`Claims of the ’392 Patent would have been obvious in view of the prior art. The
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`discussion below provides a detailed analysis of how the prior art references
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`identified below teach the limitations of the Challenged Claims of the ’392 Patent.
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`39. As part of my analysis, I have considered the scope and content of the
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`prior art and any differences between the alleged invention and the prior art. I
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`describe in detail below the scope and content of the prior art, as well as any
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`differences between the alleged invention and the prior art, on an element-by-
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`element basis for each Challenged Claims of the ’392 Patent.
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`40. As described in detail below, the alleged invention of the Challenged
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`Claims would have been obvious in view of the teachings of the identified prior art
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`references as well as the knowledge of a POSITA.
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`41. My analysis below explains how each claim of the ’392 patent would
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`have been obvious over various embodiments of Hui (U.S. Patent Publication No.
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`2011/0199045). Different embodiments of Hui describe different aspects of full-
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`bridge inverter control signals. These different aspects relate to various dependent
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`claims.
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`42. My analysis thus presents separate grounds based upon these different
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`embodiments. In particular, the first and second grounds rely on Hui’s phase-shift
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`control embodiment as illustrated in Figs. 1a and 5b and described in
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`accompanying text. The third ground relies on Hui’s duty cycle control
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`embodiment as illustrated in Figs. 1b and 2a and described in accompanying text.
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`A. Ground 1: Claims 1 and 6 are obvious in view of Hui (Figs. 1a and
`5b).
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`1.
`
`Summary of Hui
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`43. Like the ’392 patent, Hui relates to “a power transfer device that
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`wirelessly transfers AC power for charging at least one load.” Hui, abstract. With
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`respect to Hui’s phase-shift control embodiment, Hui describes that “[t]he power
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`transfer device 1 includes a power converter 4 for generating the AC power,
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`and the phase-shift control means 3 controls the power converter.” Hui, [0033].
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`“[T]he power converter 4 is a DC-AC power converter, which is also known as an
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`inverter.” Hui, [0033].
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`power converter
`power transfer device
`control means
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`load
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`Hui, Fig. 1a (annotated).
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`
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`44. Hui’s control means 3 provides signals to the gates of the four
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`transistors. “In further detail, the DC-AC power converter 4 includes two pairs of
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`switches M1, M2, M3, and M4. The off-diagonal switches work as a pair, that is,
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`switches M1 and M4 are one pair and switches M2 and M3 are the other pair.”
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`Hui, [0036]. This arrangement of transistors is identical to the arrangement shown
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`in the ’392 patent, as shown below in the comparison of Hui’s Fig. 1a with Fig. 8
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`of the ’392 patent.1
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`
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`Hui, Fig. 1a
`(partial, annotated).
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`’392 patent, Fig. 8
`(partial, annotated).
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`
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`45. Hui describes various control schemes to control the transistors,
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`including a phase-control scheme and a duty cycle control scheme. “The phase-
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`shift control means 3 varies the AC power by adjusting a phase angle α between
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`1 Hui labels the transistors differently than in the ’392 Patent. Specifically, in Hui,
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`the transistor between node A and ground is labeled the third transistor (M3),
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`whereas the similarly positioned transistor in the ’392 patent is referred to as the
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`second transistor (S2). Likewise, in Hui, the transistor between the input and
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`node B is referred to as the second transistor (M2), whereas the similarly
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`positioned transistor in the ’392 Patent is referred to as the third transistor (S3).
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`gating signals of each pair of switches. Each switch M1, M2, M3, and M4 is
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`operated at a constant frequency and a constant duty-cycle.” Hui, [0036]. An
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`example of the control signals for the phase control scheme is shown below in Fig.
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`5b.
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`“first AC power
`control signal”
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`“third AC power
`control signal”
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`“second AC power
`control signal”
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`“fourth AC power
`control signal”
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`Hui, Fig. 5b (annotated).
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`46. As shown in the following element-by-element analysis, these control
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`signals and their relation to the output voltage VAB illustrated in the embodiment of
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`Fig. 5a have the same timing characteristics as recited in claims 1, 3, 4, and 6 of
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`the ’392 patent. For example, the falling time of Hui’s fourth gating signal
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`corresponds to when the output voltage drops from positive polarity to zero (claim
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`1). Similarly, the falling time of Hui’s third gating signal corresponds to when the
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`output voltage rises from negative polarity to zero (claim 1). Furthermore, like the
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`’392 patent, the falling time of Hui’s fourth gating signal is ahead of the falling
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`time of Hui’s first gating signal (claim 3) and the falling time of Hui’s second
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`gating signal is ahead of a falling time of Hui’s third gating signal (claim 4).
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`2.
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`Claim 1
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`[1.0] A transmitter for generating a wireless power transmitted to a receiver, the
`transmitter comprising:
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`47. To the extent the preamble is limiting, Hui renders it obvious.
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`48. Hui describes a power transfer device (“transmitter”) for generating
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`AC power that is wirelessly transferred to a load (“receiver”)