Apple Inc.
`
`v.
`
`Scramoge Technology Ltd.
`
`IPR2022-0573, U.S. Patent No. 7,825,537
`
`Patent Owner’s Demonstrative Exhibits
`
`June 16, 2023
`
`Ex. 2011
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 1
`
`
`
`v.
`
`Scramoge Technology Ltd.
`
`IPR2022-0573, U.S. Patent No. 7,825,537
`
`Patent Owner’s Demonstrative Exhibits
`
`June 16, 2023
`
`Ex. 2011
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 1
`
`
`
`Ground 1: Not Obvious Over Baarman
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 2
`
`
`
`Petition Failed to Establish Baarman as Prior Art
`
`January 7, 2008
`Baarman Provisional Application Filed
`
`January 7, 2009
`Baarman Non-Provisional Application Filed
`
`November 14, 2008
`‘537 Patent Application Filed
`
`Jan
`
`Feb
`
`Mar
`
`Apr
`
`May
`
`Jun
`
`Jul
`
`Aug
`
`Sep
`
`Oct
`
`Nov
`
`Dec
`
`Jan
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 3
`
`
`
`Petition Failed to Show Enablement
`
`• “An application for patent … for an invention disclosed in the manner
`provided by section 112 [first paragraph] … in a provisional application …
`shall have the same effect, as to such invention, as though filed on the date
`of the provisional application.”
`
`– 35 U.S.C. § 119(e)(1); see Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800
`F.3d 1375, 1378 (Fed. Cir. 2015)
`
`•
`
`It is well settled that 35 U.S.C. § 112, ¶ 1 contains a written description
`requirement separate from an enablement requirement.
`
`– Ariad Pharm., Inc. v. Eli Lilly & Co., 598 F.3d 1336, 1344 (Fed. Cir. 2010)(en banc)
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`4
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 4
`
`
`
`Petition Failed to Show Enablement
`
`• “The enablement requirement is satisfied when one skilled in the art, after
`reading the specification, could practice the claimed invention without
`undue experimentation.”
`
`– AK Steel Corp. v. Sollac and Ugine, 344 F.3d 1234, 1244 (Fed. Cir. 2003)
`
`• Petition does not address the Wands factors, including the degree of
`experimentation required to ”make and use” the Baarman claims
`
`• Petition merely gives exemplary citations to the Baarman Provisional
`without explanation
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`5
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 5
`
`
`
`Failure to Address Enablement is Fatal
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`Amgen Inc. v. Sanofi, 872 F.3d 1367, 1380 (Fed. Cir. 2017)
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 6
`
`
`
`Baarman Does Not Disclose Claims 5 and 16
`
`12. An inductive power transfer system, comprising:
`a base unit comprising a first inductive element configured for providing input power to a second inductive element of a target unit
`providing output power, said base unit electrically isolated from said target unit;
`a positioning structure provided on at least one of said base unit and said target unit for removably positioning said second inductive
`element at a predetermined orientation and distance relative to said first inductive element;
`a switch element configured for selectively applying a time varying electric current to said first inductive element to produce a time
`varying magnetic field, said time varying magnetic field inducing an electric current in said second inductive element; and
`a control circuit configured for monitoring at least one parameter indicative of an efficiency of power transfer from said base unit
`to said target unit, and automatically adjusting at least one characteristic of said time varying electric current responsive to said
`parameter to maximize an efficiency of power transfer from said base unit to said target unit.
`
`15. The system of claim 14, further comprising
`a load circuit coupled to said first inductive element, and
`where said parameter comprises a current or voltage associated with said load.
`
`16. The system of claim 15, wherein
`said control circuit automatically selectively adjusts said characteristic based on a comparison of said measured current or voltage to
`a constant reference value.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`’537 Patent, Claims 12, 15, and 16; see also Claims 1, 4, and 5.
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 7
`
`
`
`Baarman Does Not Disclose Claims 5 and 16
`
`• Claim 16 requires “a control circuit configured for”:
`
`(1) monitoring a parameter comprising a current or voltage associated
`with a load circuit; and
`
`(2) automatically selectively adjusting at least one characteristic of said
`time varying electric current
`
`(i)
`
`responsive to a comparison of said measured current or voltage to a constant
`reference value
`
`(ii) to maximize an efficiency of power transfer from said base unit to said target
`unit
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 8
`
`
`
`Petitioner’s Shifting Invalidity Theories
`
`Current sensor 322
`
`R-C Circuit R11-C17
`
`Ex. 1004, Fig. 3D (excerpted).
`
`For claim 15, the voltage on R-C circuit R11-C17 from current sensor 322 in the primary unit is the
`“parameter comprising a current or voltage associated with a load circuit.” Petition at 27-28, 38.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 9
`
`
`
`Petitioner’s Shifting Invalidity Theories
`
`Current sensor 322
`
`R-C Circuit R11-C17
`
`Secondary current sensor 418
`
`Secondary voltage sensor 422
`
`Signaling resistor 432
`
`Alternatively for claim 15, the measured secondary current and voltage, as communicated back to the primary via
`signaling resistor 432 in the secondary and R-C circuit R11-C17 in the primary, is the “parameter comprising a
`current or voltage associated with a load circuit.” Petition at 29-30, 38-39.
`Ground 2
`Ground 1
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Ex. 1004, Fig. 3D (excerpted), 4.
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 10
`
`
`
`Petitioner’s Shifting Invalidity Theories
`
`Secondary over-current sensor 40
`
`Shunting resistor 44
`
`Secondary over-voltage sensor 36
`
`For claim 16, if “over-current” or “over-voltage” are sensed, resistor 44 is shunted to ground, causing surge in
`secondary coil and, consequently, primary coil that is detected by peak detector 22. The frequency of the signal
`to the primary coil is adjusted to correct the “over-current” or “over-voltage” state. Petition at 30-31, 39-40.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Ex. 1012 (Baarman-392), Fig. 5.
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 11
`
`
`
`Petitioner’s Theories Fail
`
`• Petition’s alternative theory for claim 15 fails
`
`– When Baarman automatically adjusts the operating frequency based on the secondary current and voltage,
`it does so in response to the secondary current and voltage, not the voltage of R-C circuit R11-C17
`
`– Secondary circuit current and voltage are not measured by the R-C circuit R11-C17 in the primary circuit
`
`– Secondary voltage and current are “associated” with the secondary circuit, not the R-C circuit R11-C17
`
`• Petition’s theory for claim 16 fails
`
`– “Over-current” and “over-voltage” are “associated” with the secondary circuit, not the primary R-C circuit
`
`– Baarman does not describe using the “over-current” and “over-voltage” mechanism to adjust a
`characteristic of the time varying electric current to “maximize an efficiency of power transfer”
`
`– Baarman’s “over-current” and “over-voltage” mechanism protects the battery
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 12
`
`
`
`Ground 2: Not Obvious Over Flowerdew
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 13
`
`
`
`Flowerdew Does Not Disclose Claims 4, 5, 15 and 16
`
`’537 Patent, Claim 15; see also Claim 4.
`
`• Claim 15 requires the load circuit to be electrically connected to
`the inductive element
`
`• “Coupled” only used to describe electrical connections in the ’537
`Patent. See Ex. 1001, Figs. 2, 3A, 3B
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 14
`
`
`
`Flowerdew Does Not Disclose Claims 4, 5, 15 and 16
`
`• Claim 14 recites “coupling and decoupling a DC voltage source to said
`first inductive element to produce said time varying current”
`
`• Claim 4 recites “communicating said time varying electric current to
`a load in said base unit”
`
`• Flowerdew does not describe the sense coil as electrically connected
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Ex. 1007, 13:26-29.
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 15
`
`
`
`Proposed Combination with Jang Fails
`
`• Petition asserts that because Flowerdew does not expressly disclose
`how “low-power mode” is implemented, POSITA would be motivated
`to combine with Jang. Petition at 67
`
`• Petition also asserts that POSITA would be motivated to combine with
`Jang to provide feature of maintaining power transfer at a
`predetermined level. Petition at 67-68
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 16
`
`
`
`Flowerdew Fully Describes “Low Power Mode”
`
`• Flowerdew defines “high power” and
`“low power” modes
`
`• “High power mode” maintains
`frequency in defined range; “low power
`mode” outside of that range
`
`•
`
`In “low power mode,” frequency set to
`lowest possible value to reduce power
`
`Ex. 1007, 13:46-51.
`
`Ex. 1007, 13:18-20.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 17
`
`
`
`Jang Renders Flowerdew Inoperable
`
`• In “high power mode,” Flowerdew seeks to maximize feedback from
`the sense coil, which is contrary to maintaining the feedback at a
`predetermined level
`
`• Petition performs no analysis of the benefits or drawbacks to
`modifying Flowerdew
`
`Ex. 1007, 13:29-31.
`
`Scramoge Technology Ltd.
`
`Ground 1
`
`Ground 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 18
`
`
`
`Additional Slides
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 19
`
`
`
`No Motivation to Combine
`
`• The Petition’s profferred reasons to combine are excessively generic and fail
`to identify or adequately explain any benefit gained by combining the
`primary reference with the secondary reference.
`
`• Mere recitation of “predictable benefits,” “predictable results,” or structures
`being “commonly implemented” or ”exceedingly common,” is insufficient
`
`– Combination of Baarman and Partovi-002
`
`– Combination of Baarman and Partovi-002 and Partovi-413
`
`– Combination of Flowerdew and Jang
`
`– Combination of Flowerdew and Partovi-413
`
`– Combination of Flowerdew and Jang and Partovi-413
`
`Scramoge Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`Scramoge Technology Ltd.
`Exhibit 2011, Page 20
`
`
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