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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00529
`U.S. Patent No. 10,193,392
`
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
`
`
`
`
`
`

`

`
`
`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
`
`TABLE OF CONTENTS
`
`PETITIONER’S EXHIBIT LIST .............................................................................. 5
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 6
`
`GROUNDS FOR STANDING ........................................................................ 6
`
`III. NOTE ............................................................................................................... 6
`
`IV. BACKGROUND ............................................................................................. 7
`
`V.
`
`SUMMARY OF THE ’392 PATENT ............................................................. 8
`
`VI. PROSECUTION HISTORY .........................................................................13
`
`VII. LEVEL OF ORDINARY SKILL IN THE ART ...........................................15
`
`VIII. CLAIM CONSTRUCTION ..........................................................................16
`
`IX. RELIEF REQUESTED AND THE REASONS FOR THE
`REQUESTED RELIEF .................................................................................17
`
`X. DISCRETIONARY DENIAL WOULD BE INAPPROPRIATE .................17
`
`A. Discretionary denial under the Fintiv factors is not appropriate ........ 17
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`No evidence regarding a stay ................................................... 18
`
`Parallel proceeding trial date ................................................... 18
`
`Investment in the parallel proceeding ...................................... 18
`
`Overlapping issues with the parallel proceeding ..................... 19
`
`Petitioner is a defendant ........................................................... 19
`
`Other circumstances ................................................................. 20
`
`B.
`
`The Fintiv Framework Should Be Overturned................................... 20
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`2
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`C.
`
`Discretionary denial under General Plastic is not appropriate .......... 20
`
`D. Discretionary denial under 35 U.S.C. § 325(d) is not appropriate .... 20
`
`XI.
`
`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE ....21
`
`A.
`
`B.
`
`C.
`
`Challenged Claims ............................................................................. 21
`
`Statutory Grounds for Challenges ...................................................... 21
`
`Ground 1: Claims 1 and 6 are obvious in view of Hui (Figs. 1a
`and 5b). ............................................................................................... 23
`
`1.
`
`2.
`
`3.
`
`Summary of Hui ....................................................................... 23
`
`Claim 1 ..................................................................................... 28
`
`Claim 6 ..................................................................................... 55
`
`D. Ground 2: Claims 2-4 are obvious in view of Hui (Figs. 1a and 5b)
`and Taylor. .......................................................................................... 59
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Summary of Taylor .................................................................. 59
`
`Reasons to Combine Hui and Taylor ....................................... 60
`
`Claim 2 ..................................................................................... 65
`
`Claim 3 ..................................................................................... 71
`
`Claim 4 ..................................................................................... 73
`
`E.
`
`Ground 3: Claims 1, 5, and 7-8 are obvious in view of Hui (Figs.
`1b and 2a) ........................................................................................... 75
`
`1.
`
`2.
`
`3.
`
`Summary of Hui (Figs. 1b and 2a) .......................................... 75
`
`Claim 1 ..................................................................................... 77
`
`Claim 5 ................................................................................... 105
`
`3
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`4.
`
`5.
`
`Claim 7 ................................................................................... 108
`
`Claim 8 ................................................................................... 111
`
`XII. CONCLUSION ............................................................................................115
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`XIII. MANDATORY NOTICES .........................................................................116
`
`A.
`
`B.
`
`C.
`
`Real Party-in-Interest ....................................................................... 116
`
`Related Matters ................................................................................. 116
`
`Lead and Back-up Counsel and Service Information ...................... 117
`
`CERTIFICATE OF WORD COUNT ....................................................................118
`
`CERTIFICATE OF SERVICE ..............................................................................119
`
`4
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`PETITIONER’S EXHIBIT LIST
`
`U.S. Patent No. 10,193,392
`
`Prosecution History of U.S. Patent No. 10,193,392
`
`Declaration of Dr. Joshua Phinney under 37 C.F.R. § 1.68
`Curriculum Vitae of Dr. Joshua Phinney
`
`U.S. Patent Publication No. 2011/0199045 to Hui et al. (“Hui”)
`U.S. Patent No. 9,461,479 to Chae et al. (“Chae”)
`
`U.S Patent No. 9,509,168 to Ye et al. (“Ye”)
`
`McGraw-Hill Dictionary of Scientific and Technical Terms: Sixth
`Edition, 2003 (“Dictionary”).
`
`U.S. Patent No. 8,129,864 to Baarman et al. (“Baarman”)
`U.S. Patent No. 9,384,885 to Karalis et al. (“Karalis”)
`
`U.S. Patent No. 10,250,083 to Taylor et al. (“Taylor”)
`
`U.S. Patent No. 9,425,864 to Staring (“Staring”)
`Plaintiff’s Preliminary Disclosure of Asserted Claims and
`Infringement Contentions to Apple Inc., Scramoge Technology
`Limited v. Apple Inc., WDTX-6-21-cv-01071 (served Jan. 28,
`2022)
`
`
`
`
`
`
`
`Ex.1001
`
`Ex.1002
`
`Ex.1003
`Ex.1004
`
`Ex.1005
`Ex.1006
`
`Ex.1007
`
`Ex.1008
`
`Ex.1009
`Ex.1010
`
`Ex.1011
`
`Ex.1012
`
`Ex.1013
`
`5
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`I.
`
`INTRODUCTION
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`U.S. Patent No. 10,193,392 (the “’392 patent,” Ex.1001) describes and
`
`claims well-known concepts related to wireless charging. Specifically, the ’392
`
`patent seeks to protect a “transmitter for generating a wireless power” that includes
`
`four “switching elements” arranged to convert DC voltage to AC power. Ex.1001,
`
`claim 1. This claimed arrangement, however, merely describes a full-bridge
`
`inverter, a well-known component in power transfer systems prior to the ’392
`
`patent. The claimed full-bridge inverter contains no inventive aspects over prior
`
`full-bridge converters, as illustrated in this petition.
`
`Accordingly, pursuant to 35 U.S.C. §§ 311, 314(a), and 37 C.F.R. § 42.100,
`
`Apple Inc. (“Petitioner”) respectfully requests that the Board review and cancel as
`
`unpatentable under 35 U.S.C. §103 claims 1-8 (hereinafter, the “Challenged
`
`Claims”) of the ’392 patent.
`
`II. GROUNDS FOR STANDING
`
`Petitioner certifies that the ’392 patent is eligible for IPR and that Petitioner
`
`is not barred or estopped from requesting IPR challenging the patent claims. 37
`
`C.F.R. § 42.104(a).
`
`III. NOTE
`Petitioner cites to exhibits’ original page numbers. Emphasis in quoted
`
`material has been added. Claim terms are presented in italics.
`
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`IV. BACKGROUND
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`Mobile devices, such as smartphones, typically include a rechargeable
`
`battery. See e.g., Ex.1007, 1:21-23. Prior to the ’392 patent, one way these mobile
`
`device batteries were recharged was through electromagnetic induction. See e.g.,
`
`Ex.1006, 4:58-67. For example, an electric current could be induced in a coil
`
`provided in the mobile device by applying AC power to a corresponding coil in a
`
`charger. See Ex.1006, 5:1-6. The AC signal applied to the charger coil is generated
`
`with an inverter. See e.g., Ex.1007, 2:22-25; Ex.1003, ¶ 27.
`
`Inverters are used to transform a DC signal into an AC signal. See Ex.1006
`
`10:52-59. One common type of inverter prior to the ’392 patent was a full-bridge
`
`inverter, which includes four transistors. Ex.1003, ¶ 28 (describing several
`
`example circuit diagrams of full-bridge inverters). Full-bridge inverters
`
`approximate a sine wave by producing a series of positive square pulses offset with
`
`a series of negative square pulses. Ex.1003, ¶ 29 (citing multiple examples of the
`
`output signal for full-bridge inverters).
`
`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 Ex.1007,
`
`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,
`
`7
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`

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`effectively independent of the DC input voltage.”); Ex.1006, 5:55-58 (“the power
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`conversion unit 111 may further include a circuit for controlling the characteristics
`
`of a used frequency”). The configuration of the control signals for operating a full-
`
`bridge inverter were well known. Ex.1003, ¶ 30 (citing multiple, various control
`
`schemes for operating a full-bridge inverter).
`
`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. Ex.1003,
`
`¶ 31.
`
`V.
`
`SUMMARY OF THE ’392 PATENT
`
`The ’392 patent generally relates to “a wireless power transfer system
`
`having a receiving part for receiving power from a transmitting part.” Ex.1001,
`
`abstract. The transmitting part includes “a power conversion part … and a control
`
`part for controlling the power conversion part.” Ex.1001, abstract. “The power
`
`conversion part 130 may be configured of a full bridge inverter.” Ex.1001, 10:36-
`
`37. “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.” Ex.1001, 10:38-42.
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`The power conversion part 130—a full-bridge inverter—is shown below in Fig. 8.
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`Ex.1003, ¶ 32.
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`“first switching
`element”
`
`“second
`switching
`element”
`
`“third
`switching
`element”
`
`“fourth
`switching
`element”
`
`Ex.1001, Fig. 8 (annotated); Ex.1003, ¶ 32.
`
`
`
`The full-bridge inverter is driven by four control signals respectively 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. See 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. See Ex.1001, 12:44-52. When the signal
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`applied to a gate is high, electric current is allowed to flow through the terminals of
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`that transistor. See 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. See 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. Ex.1003, ¶ 33.
`
`“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”
`
`Ex.1001, Fig. 12 (annotated); Ex.1003, ¶ 33.
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`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.
`
`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
`
`control part 140 and the second and third switching elements S2 and S3 are turned
`
`on by the second and third AC power control signals C12 and C21, a negative
`
`polarity output voltage Vo” is produced at the output. Ex.1001, 13:1-7; Ex.1003, ¶
`
`34.
`
`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:
`
`• Claim 1: “wherein when the first and fourth switching elements are
`
`turned on … the positive polarity output voltage is generated,” “when the
`
`second and third switching elements are turned on … the negative
`
`polarity output voltage is generated,” “wherein a duty ratio of the
`
`positive polarity output voltage is determined by a falling time of the
`
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`fourth AC power control signal,” and “wherein a duty ratio of the
`
`negative polarity output voltage is determined by a falling time of the
`
`third AC power control signal”
`
`• Claim 3: “wherein the falling time of the fourth AC power control signal
`
`is ahead of a falling time of the first AC power control signal”
`
`• Claim 4: “wherein the falling time of the third AC power control signal
`
`is ahead of a falling time of the second AC power control signal”
`
`• Claim 6: “wherein the second and third switching elements are turned
`
`off in a time interval when the first and fourth switching elements are
`
`turned on,” “wherein the first and fourth switching elements are turned
`
`off in a time interval when the second and third switching elements are
`
`turned on”
`
`• Claim 7: “a first blank interval where high level intervals of the first and
`
`second AC power control signals do not exist between a falling time of
`
`the first AC power control signal and a rising time of the second AC
`
`power control signal”
`
`• Claim 8: “wherein the control part defines a second blank interval where
`
`high level intervals of the third and fourth AC power control signals do
`
`not exist between a falling time of the third AC power control signal and
`
`a rising time of the fourth AC power control signal”
`
`12
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`As the prior art cited below illustrates, these claimed relationships between
`
`
`
`the control signals and the output voltage simply describe the standard operation of
`
`a full-bridge inverter. Ex.1003, ¶¶ 35-36.
`
`VI. PROSECUTION HISTORY
`
`The ’392 patent was filed in the U.S. on July 8, 2016 as a national stage
`
`entry of PCT Publication No. WO2015/105334, filed January 7, 2015. The PCT
`
`application claims priority to Korean applications 10-2014-0002327 and 10-
`
`20140009243 which were filed January 8, 2014 and January 24, 2014 respectively.
`
`It is unnecessary to determine whether the ’392 patent is entitled to its earliest
`
`alleged priority date because the prior art relied upon herein pre-dates the earliest
`
`alleged priority date.
`
`During prosecution, the applicant responded to a restriction requirement by
`
`electing and amending pending claim 12 as follows:
`
`13
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`
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`Ex.1002, 189-94, 198-206.
`
`The Office then rejected claim 12 as being anticipated by U.S. Patent
`
`Publication No. 2014/0241012 to Lindberg. Ex.1002, 59. The Office also indicated
`
`that claims 13-17 recited allowable subject matter. Ex.1002, 62. The Applicant
`
`then further amended claim 12 to recite the limitations of pending claim 13, which
`
`related to how the duty cycle is controlled:
`
`14
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`Ex.1002, 47, 51.
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`The Office subsequently issued a notice of allowance, and pending claims
`
`12 and 13-20 issued as claims 1-8 on January 29, 2019. Ex.1002, 26-32.
`
`VII. LEVEL OF ORDINARY SKILL IN THE ART
`
`A Person of Ordinary Skill in The Art (“POSITA”) in January of 2014
`
`15
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`would have had a working knowledge of the wireless charging art that is pertinent
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`to the ’392 patent. That person would have a bachelor’s degree in electrical
`
`engineering, or equivalent training, and approximately two years of experience
`
`working in the field of electric circuits and wireless charging. Lack of work
`
`experience can be remedied by additional education, and vice versa. Ex.1003,
`
`¶¶18-20.
`
`VIII. CLAIM CONSTRUCTION
`
`In an inter partes review, claims “shall be construed using the same claim
`
`construction standard that would be used to construe the claim in a civil action
`
`under 35 U.S.C. 282(b), including construing the claim in accordance with the
`
`ordinary and customary meaning of such claim as understood by one of ordinary
`
`skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. §
`
`42.100(b). The Board only construes the claims to the extent necessary to resolve
`
`the underlying controversy. Nidec Motor Corp. v. Zhongshan Broad Ocean Motor
`
`Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017). Petitioner submits that for the purposes
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`of this proceeding, the terms of the Challenged Claims should be given their plain
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`and ordinary meaning, and no terms require specific construction.1 Ex.1003, ¶ 37.
`
`IX. RELIEF REQUESTED AND THE REASONS FOR THE
`REQUESTED RELIEF
`
`Petitioner asks that the Board institute a trial for inter partes review and
`
`cancel the Challenged Claims in view of the analysis below.
`
`X. DISCRETIONARY DENIAL WOULD BE INAPPROPRIATE
`A. Discretionary denial under the Fintiv factors is not appropriate
`
`The six factors considered for § 314 denial strongly favor institution. See
`
`Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020)
`
`(precedential). The district court case is at an early stage and no trial date has been
`
`set. Petitioner has diligently prepared and filed this petition within one week of
`
`being served Patent Owner’s infringement contentions. Ex.1013, 1, 7. The petition
`
`is also well within the one-year timeframe allowed by Congress.
`
`
`1 Petitioner does not concede that any term in the challenged claims meets the
`
`statutory requirements of 35 U.S.C. § 112, or that the challenged claims recite
`
`patentable subject matter under 35 U.S.C. § 101.
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`1. No evidence regarding a stay
`
`No motion to stay has been filed, so the Board should not infer the outcome
`
`of such a motion. Sand Revolution II LLC v. Continental Intermodal Group –
`
`Trucking LLC, IPR2019-01393, Paper 24 at 7 (PTAB June 16, 2020)
`
`(informative); see also Dish Network L.L.C. v. Broadband iTV, Inc., IPR2020-
`
`01359, Paper 15 at 11 (PTAB Feb. 12, 2021) (“It would be improper to speculate,
`
`at this stage, what the Texas court might do regarding a motion to stay…”). Thus,
`
`this factor is neutral on discretionary denial.
`
`2. Parallel proceeding trial date
`
`The district court has not yet set a trial date or issued a scheduling order.2
`
`Without a trial date, this factor weighs heavily against discretionary denial.
`
`3. Investment in the parallel proceeding
`
`The co-pending litigation is in its very early stages, and the investment in it
`
`has been minimal. The parties have not exchanged preliminary positions on claim
`
`construction or invalidity, and fact and expert discovery has not begun. Further,
`
`there is no evidence that the district court will conduct a Markman hearing or issue
`
`
`2 If the district court issues a scheduling order before the Board issues its
`
`institution decision, Petitioner respectfully requests an opportunity to address the
`
`impact of the schedule set forth in the scheduling order.
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`a Markman ruling before the prospective date for the Board’s institution decision.
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`This lack of investment favors institution.
`
`Moreover, Petitioner only learned which claims were being asserted on
`
`January 28, 2022. See Ex.1013 (infringement contentions). Under Fintiv,
`
`Petitioner’s prompt filing within one week “weigh[s] against exercising the
`
`authority to deny institution.” Fintiv, Paper 11 at 11 (“If the evidence shows that
`
`the petitioner filed the petition expeditiously, such as promptly after becoming
`
`aware of the claims being asserted, this fact has weighed against exercising the
`
`authority to deny institution under NHK.”).
`
`4. Overlapping issues with the parallel proceeding
`
`There is no present overlap of prior art issues due to the early stage of
`
`district court litigation. For example, Petitioner has not served its preliminary
`
`invalidity contentions in the district court proceeding. Consequently, this factor
`
`favors institution.
`
`5. Petitioner is a defendant
`
`Petitioner is a defendant in the litigation. That is true of most Petitioners in
`
`IPR proceedings. Accordingly, this factor should not be a basis for denying
`
`institution.
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`6. Other circumstances
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`The prior art presented in this Petition renders the Challenged Claims
`
`unpatentable as obvious. The merits of Petitioner’s arguments are strong, and this
`
`factor weighs against discretionary denial.
`
`As such, because the Fintiv factors are either neutral or weigh against
`
`discretionary denial, and because this Petition was filed more than eight months
`
`before the statutory bar date, institution should not be denied on discretionary
`
`factors.
`
`B.
`
`The Fintiv Framework Should Be Overturned
`
`Apart from Petitioner’s showing that the Fintiv factors favor institution, the
`
`Fintiv framework should be overturned because it (1) exceeds the Director’s
`
`authority, (2) is arbitrary and capricious, and (3) was adopted without notice-and-
`
`comment rulemaking.
`
`C. Discretionary denial under General Plastic is not appropriate
`
`The ’392 patent has not been challenged in any prior IPR petition, so none of
`
`the General Plastic discretionary institution factors apply to this Petition. See
`
`General Plastic Indus. Co., Ltd. v. Canon Kabushiki Kaisha, IPR2016-01357,
`
`Paper 19 at 16 (PTAB Sept. 6, 2016) (Section II.B.4.i. precedential).
`
`D. Discretionary denial under 35 U.S.C. § 325(d) is not appropriate
`
`Denial under § 325(d) is not warranted because the challenges presented in
`
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`this petition are neither cumulative nor redundant to the prosecution of the ’392
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`IPR2022-00529 Petition
`Inter Partes Review of U.S. 10,193,392
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`patent. The Examiner did not consider any of the references relied upon in this
`
`petition. Moreover, the challenges in this petition are non-cumulative because they
`
`rely upon prior art that teaches the specific limitations the Examiner found lacking
`
`in the prior art of record during prosecution. Compare Ex.1002, 30, 47 (allowance
`
`based upon duty ratios being determined by falling times of specific control
`
`signals) with Ex.1005, Figs. 2a and 5b (showing that the falling times of specific
`
`control signals determine the duty ratio of positive and negative voltages).
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`XI.
`
`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`
`A. Challenged Claims
`
`Petitioner challenges claims 1-8 (all claims) of the ’392 patent. Ex.1003, ¶¶
`
`38-42.
`
`B.
`
`Statutory Grounds for Challenges
`
`This petition challenges the ’392 patent as being obvious over various
`
`embodiments of Hui (U.S. Patent Publication No. 2011/0199045). Different
`
`embodiments of Hui teach different aspects of full-bridge inverter control signals.
`
`These different aspects respectively correspond to various dependent claims. This
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`petition thus presents separate grounds based upon these different embodiments, as
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`noted in the table below. The first and second grounds rely on Hui’s phase-shift
`
`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.
`
`Grounds
`#1
`
`Claims
`1 and 6
`
`#2
`
`#3
`
`2-4
`
`1, 5, 7, and 8
`
`Basis
`35 U.S.C. § 103 in view of Hui (Embodiment of
`Fig. 1a and 5b)
`35 U.S.C. § 103 in view of Hui (Embodiment of
`Fig. 1a and 5b) and Taylor
`35 U.S.C. § 103 in view of Hui (Embodiment of
`Fig. 1b and 2a)
`
`
`
`U.S. Patent Publication No. 2011/0199045 to Hui et al. (“Hui” Ex.1005)
`
`was filed February 15, 2010 and published August 18, 2011. Hui is prior art under
`
`at least 35 U.S.C. § 102(a)(1).
`
`U.S. Patent No. 10,250,083 to Taylor et al. (“Taylor” Ex.1011) was filed
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`March 14, 2013 and issued April 2, 2019. Taylor is prior art under 35 U.S.C.
`
`102(a)(2).
`
`Petitioner’s analysis also cites additional prior art to demonstrate the
`
`background knowledge of a POSITA and to provide contemporaneous context to
`
`support Petitioner’s assertions regarding what a POSITA would have understood
`
`from the prior art. See Yeda Research v. Mylan Pharm. Inc., 906 F.3d 1031, 1041-
`
`1042 (Fed. Cir. 2018) (affirming the use of “supporting evidence relied upon to
`
`support the challenge”); 37 C.F.R. § 42.104(b); see also K/S HIMPP v. Hear-Wear
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`Techs., LLC, 751 F.3d 1362, 1365-66 (Fed. Cir. 2014); Arendi S.A.R.L. v. Apple
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`Inc., 832 F.3d 1355, 1363 (Fed. Cir. 2016).
`
`C. Ground 1: Claims 1 and 6 are obvious in view of Hui (Figs. 1a and
`5b).
`
`1.
`
`Summary of Hui
`
`Like the ’392 patent, Hui relates to “a power transfer device that wirelessly
`
`transfers AC power for charging at least one load.” Ex.1005, abstract. With respect
`
`to Hui’s phase-shift control embodiment, Hui describes that “[t]he power transfer
`
`device 1 includes a power converter 4 for generating the AC power, and the
`
`phase-shift control means 3 controls the power converter.” Ex.1005, [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.” Ex.1005, [0033]; Ex.1003, ¶ 43.
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`power converter
`power transfer device
`control means
`
`load
`
`Ex.1005, Fig. 1a (annotated); Ex.1003, ¶ 43.
`
`
`
`Hui’s control means 3 provides signals to the gates of the four transistors.
`
`“In further detail, the DC-AC power converter 4 includes two pairs of switches
`
`M1, M2, M3, and M4. The off-diagonal switches work as a pair, that is, switches
`
`M1 and M4 are one pair and switches M2 and M3 are the other pair.” Ex.1005,
`
`[0036]. This arrangement of transistors is identical to the arrangement illustrated
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`and claimed in the ’392 patent, as shown below in the comparison of Hui’s Fig. 1a
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`with Fig. 8 of the ’392 patent.3 Ex.1003, ¶ 44.
`
`’392 Patent
`
`Hui
`
`Ex.1001, Fig. 8
`(partial, annotated); Ex.1003, ¶ 44.
`
`Ex.1005, Fig. 1a
`(partial, annotated); Ex.1003, ¶ 44.
`
`
`
`
`3 Although Hui teaches the same full-bridge inverter as the ’392 patent, Hui’s
`
`nomenclature is slightly different. In Hui, the transistor between node A and
`
`ground is referred to as the third transistor (“M3”), whereas the similarly
`
`positioned transistor in the ’392 patent is referred to as the second transistor
`
`(“S2”). Similarly, in Hui, the transistor between the input and node B is referred to
`
`as the second transistor (“M2”), whereas the similarly positioned transistor in the
`
`’392 patent is referred to as the third transistor (“S3”). Ex.1003, ¶ 44.
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`Hui describes various control schemes to control its four transistors,
`
`
`
`including a phase-control scheme. “The phase-shift control means 3 varies the AC
`
`power by adjusting a phase angle α between gating signals of each pair of
`
`switches. Each switch M1, M2, M3, and M4 is operated at a constant frequency
`
`and a constant duty-cycle.” Ex.1005, [0036]. An example of the control signals for
`
`the phase control scheme and the corresponding output Vab (in purple) is shown
`
`below in Hui’s Fig. 5b. Ex.1003, ¶ 45.
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`
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`“AC power”
`
`“first AC power
`control signal”
`
`“third AC power
`control signal”
`
`“second AC power
`control signal”
`
`“fourth AC power
`control signal”
`
`Ex.1005, Fig. 5b (annotated); Ex.1003, ¶ 45.
`
`
`
`As shown in the following element-by-element analysis, these control
`
`signals and their relation to the output voltage VAB illustrated in the embodiment of
`
`Fig. 5a have the same timing characteristics as recited in claims 1, 3, 4, and 6 of
`
`the ’392 patent. For example, the falling time of Hui’s fourth gating signal
`
`corresponds to when the output voltage drops from positive polarity to zero (claim
`
`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
`
`time of Hui’s first gating signal (claim 3) and the falling time of Hui’s second
`
`gating signal is ahead of a falling time of Hui’s third gating signal (claim 4).
`
`Ex.1003, ¶ 46.
`
`Claim 1
`
`2.
`[1.0] A transmitter for generating a wireless power transmitted to a receiver, the
`transmitter comprising:
`
`To the extent the preamble is limiting, Hui renders it obvious. Ex.1003, ¶ 47.
`
`Hui describes a power transfer device (“transmitter”) for providing wireless
`
`power to a load (“receiver”): “[T]here is provided a power transfer device 1 that
`
`wirelessly transfers AC power for charging at least one load 2.” Ex.1005, [0032].
`
`“The power transfer device 1 includes a power converter 4 for generating the AC
`
`power.” Ex.1005, [0033]. “FIGS. 1a, 1b, and 6 show typical circuits for a wireless
`
`power transfer system. FIG. 1a includes the power transfer device 1.” Ex.1005,
`
`[0049]. “A secondary side of the system includes a secondary module (in the form
`
`of the load 2). Ex.1005, [0049]; Ex.1003, ¶ 48.
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`“transmitter”
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`“receiver”
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`Ex.1005, Fig. 1a (annotated); Ex.1003, ¶ 48.
`
`
`
`Thus, because Hui describes a power transfer device for generating AC
`
`power and wirelessly transferring power to a load, Hui renders obvious “a
`
`transmitter for generating a wireless power transmitted to a receiver” as claimed.
`
`Ex.1003, ¶ 49.
`
`[1.1] a control part for generating first to fourth AC power control signals; and
`
`First, Hui’s power transfer device includes a phase-shift control means 3
`
`(“control part”): “The power transfer device 1 includes a power converter 4 for
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`generating the AC power, and the phase-shift control means 3 controls the
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`power converter.” Ex.1005, [0033]; Ex.1003, ¶