Trials@uspto.gov
`571-272-7822
`
`Paper 31
`Date: July 31, 2023
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE, INC.,
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`____________
`
`IPR2022-00573
`Patent 7,825,537 B2
`____________
`
`Record of Oral Hearing
`Held: June 15, 2023
`____________
`
`Before JAMESON LEE, KRISTINA M. KALAN, and MICHELLE N.
`WORMMEESTER, Administrative Patent Judges.
`
`
`
`

`

`IPR2022-00573
`Patent 7,825,537 B2
`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`SCOTT JARRATT, ESQUIRE
`ANDREW EHMKE, ESQUIRE
`Haynes and Boone LLP
`6000 Headquarters Drive Suite 200
`Plano, Texas 75024
`(214) 651-5116
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`BRETT COOPER, ESQ.
`JOHN PETRSORIC, ESQ.
`Russ, August, & Kabat
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`(310) 826-7474
`
`
`
`
` The above-entitled matter came on for hearing on Thursday, June 15,
`2023, commencing at 1:00 p.m., via the WebEx platform.
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`IPR2022-00573
`Patent 7,825,537 B2
`
`
`P R O C E E D I N G S
`- - - - -
`JUDGE WORMMEESTER: -- Good afternoon, everyone. We have
`our final hearing in IPR2022-00573, Apple v Scramoge Technology, which
`concerns US patent number 7,825,537. I'm Judge Wormmeester. Also
`appearing remotely are my colleagues, Judges Lee and Kalan. Thank you
`for being here today. We want to start off by clarifying a few items. First,
`our primary concern is your right to be heard. If at any time during the
`proceedings you encounter technical or other difficulties that undermine
`your ability to adequately represent your client, please let us know
`immediately. For example, by contacting the team members who provided
`you with connection information. Second, for the benefit of the judges,
`opposing counsel, and court reporter, please identify yourself each time you
`speak. When not speaking, please mute yourself. Third, we have the entire
`record, including demonstratives. When referring to demonstratives, papers,
`or exhibits, please be explicit and identify any slide numbers or page
`numbers. Finally, please note that members of the public may be listening to
`this oral hearing. Does anyone have any concerns about that?
`MR. COOPER: No, Your Honor.
`MR. JARRATT: No, Your Honor.
`JUDGE WORMMEESTER: Great. Okay, let's get the parties’
`appearances, please. Who do we have for petitioner?
`MR. JARRATT: Good afternoon, Your Honors. This is Scott Jarratt
`with Haynes and Boone. I'm lead counsel for Petitioner, Apple. And also
`appearing for petitioner is Andy Ehmke, also with Haynes and Boone. And
`Mr. Emke will be presenting today.
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`IPR2022-00573
`Patent 7,825,537 B2
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`
`JUDGE WORMMEESTER: Great. Thank you. Welcome. And for
`Patent Owner, who do we have?
`MR. COOPER: Thank you, Your Honors. This is Brett Cooper. I am
`lead counsel for the Patent Owner of the ‘537 patent. With me is my
`colleague, John Petrsoric. And Mr. Petrsoric will be handling the argument
`today on the ‘537.
`JUDGE WORMMEESTER: Thank you. Welcome. We set forth the
`procedure for today's hearing, but just to remind everyone the way this will
`work, each party will have 60 minutes to present arguments. Petitioner will
`go first and may reserve rebuttal time. Patent Owner will then present its
`response and may reserve sur-rebuttal time. Please remember that the
`demonstratives you submitted are not part of the record. The record of the
`hearing will be the transcript. We will maintain the clock and give you a
`warning when you're reaching the end of your argument. Are there any
`questions before we proceed?
`MR. JARRATT: No, Your Honor.
`MR. COOPER: No, Your Honor.
`JUDGE WORMMEESTER: Counsel, will you be reserving any
`time?
`MR. EHMKE: Yes, Your Honor. This is Andy Ehmke. Petitioner
`will be reserving 10 minutes for rebuttal time.
`JUDGE WORMMEESTER: Ten minutes. Okay. So, you will have
`50 minutes of argument time here. You may begin when you're ready.
`MR. EHMKE: Thank you, Your Honors. Referring to Petitioner’s
`demonstratives, we'll start with slide two, and what we wanted to do here is
`provide an overview of what we believe are the remaining issues in this
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`IPR2022-00573
`Patent 7,825,537 B2
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`proceeding. The initial petition included six grounds broken into two sets.
`Grounds 1A and 1B were based off of the Baarman primary reference.
`Grounds 2A through 2D were based off the Flowerdew reference.
`With respect to ground 2A, there are no open issues, and there's
`nothing for us to address today in the oral argument. Regarding 1A and 1B,
`Patent Owner has disputed the relevance of the Baarman reference as a
`primary reference, as well as the combinations associated with Baarman.
`For grounds 2B, 2C and 2D, Patent Owner’s disputed the combinations of
`Flowerdew with the secondary references. In terms of the claims at issue,
`we're only down to a handful of claims where there are substantive grounds
`raised. Ground 1A, there's claims 5 and 16. Through ground 2B, there are
`claims 4, 5, 15 and 16.
`So to address these issues, we'll start with slide three, whether or not
`Baarman is entitled to its priority date with respect to the provisional. As we
`have stated in the petition reply, Baarman would be entitled to its priority
`date through the Drinkware test to establish that the provisional provides
`support for the claims in accordance with one. Well, we addressed that on
`slide four. In the petition, where we say that in accordance with Drinkware,
`the Baarman provisional provides support for at least one claim of Baarman.
`The support for the provisional –-- or, the utility of Baarman was set forth in
`the petition in a chart citing to the provisional correlating each limitation to
`the location of the provisional where the necessary support for the utility
`was provided. This was the evidence that shows that the provisional
`provides the support for the utility. That evidence included not just these
`citations, but referenced the wiring diagrams and circuit diagrams contained
`in the provisional.
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`IPR2022-00573
`Patent 7,825,537 B2
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`
`We have some examples of those set forth on slides six and seven.
`Precise wiring diagrams showing the resistors, the capacitors, the inputs, the
`outputs, the sizes of the resistors and capacitors. All of this was the
`evidence included in the petition that showed the provisional provides
`support for the utility that established that the Baarman utility would have
`been entitled to the provisional priority date.
`JUDGE LEE: Mr. Ehmke, it's Judge Lee. Can you clarify, are you
`arguing the word “support” as mentioned in Dynamic Drinkware refers only
`to written description, or are you saying support means both written
`description and enabling disclosure, and -- but nevertheless, you provided
`both. Which is it?
`MR. EHMKE: I apologize for over talking you, Judge Lee. If we
`revert back to slide three, we see the language from Drinkware and the
`language in Drinkware uses the word ‘provide support’. This is the quote
`from the Federal Circuit in reference to how a provisional will provide
`support for the claims in compliance with section 112. So, we believe that
`when referencing Drinkware and using the word “support,” that's
`referencing the test of 35 USC 112, which would both be the written
`description as well as enablement. So, when we said the word “support” in
`accordance with Drinkware, that is both written description and enablement
`because that's what support for 35 USC 112 requires.
`JUDGE LEE: Thank you.
`MR. EHMKE: And referring back to slide six and seven, again we
`see the evidence that our expert relied upon to correlate the disclosure in the
`provisional to the corresponding claims in utility. Again, we believe that
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`IPR2022-00573
`Patent 7,825,537 B2
`
`circuit diagrams are evidence establishing support that the provisional
`supports the utility.
`With that in hand, we'll then start using the Baarman reference with
`respect to the combinations. We introduced this on slide eight, addressing
`Baarman being combined with the Partovi 002 reference. Now, this
`combination, we begin on slide nine, where we're looking at the disclosure
`in Baarman. Baarman is describing an invention that does inductive power
`supply. So, we have a base unit, we have a secondary unit, we're going to
`inductively transfer power from the base unit to the second unit. And when
`we do that, Baarman says that we want to maintain a high transfer
`efficiency. We want this efficiency to be optimized. So that's the stated
`goal in Baarman of its inductance power supply system. We want to have a
`highly optimized power transfer system.
`Baarman notes as we turn to slide 10, that when we're trying to do this
`efficient transfer of energy, there are things that can affect that transfer of
`energy. For example, if you detect that there's a movement or a change of
`orientation of that second device, that's affecting our optimization. So
`there's a stated goal in Baarman, if we want optimized, we want efficient
`power transfer, but yet there's this potential issue that we need to address or
`correct if we have this movement or placement or orientation of the second
`device.
`And that's where the Partovi reference on slide 11 comes in. Partovi
`said if we want to enhance the ability of that second device, if we want to
`enhance the ability of the receiver to receive power, it's desirable to control
`the distance between the two coils and it's beneficial to align the coils using
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`IPR2022-00573
`Patent 7,825,537 B2
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`magnets. So, we have the stated problem in Baarman of orientation and
`positioning, but then we have a stated solution to that problem in Partovi.
`Further, as we turn to slide 12, we see that the reason that you want to
`use this technique and feature in Partovi, is actually set forth in Partovi itself.
`If you have a battery, you can include magnetic or mechanical optimal
`methods of alignment. And if you do that, you're going to obtain optimum
`power transfer. So, we have the known system in Baarman of a base unit
`with a secondary unit where we're doing inductive power transfer. We have
`the known problem of orientation and positioning. We then have the known
`technique, in Partovi, that you can solve that problem of petitioning --
`excuse me, of positioning by using magnets for the stated goal of achieving
`optimum power, which is the precise goal desired in Baarman. We have a
`known system applying a known technique to achieve the desired
`predictable result of optimum power transfer.
`And our expert further testified, as we say -- as we show in the bottom
`of slide 12, that not only would this combination optimize the power transfer
`as desired by both of the references, but using the magnets would have it be
`a user friendly method of positioning and reduce the likelihood of errors. So
`we have the additional benefit in the record with respect to this combination.
`We believe Baarman and Partovi are an obvious combination in light of
`these teachings.
`Turning to the combination of Baarman and Partovi on slide 13.
`Again, Baarman is this inductive power supply system, but to provide that
`power, Baarman says it's suitable for use of a wide variety of inductive
`power supply. We wanted to provide power wirelessly, the plurality of
`frequencies at the bottom. It specifically says the present invention may be
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`IPR2022-00573
`Patent 7,825,537 B2
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`implemented with essentially any inductive power supply. So, Baarman is
`leaving it to the POSITA to use essentially any inductive power supply. But
`what were the known power supplies that Baarman was referencing? It
`could be essentially any inductive power supply. Partovi on slide 15 shows
`us the answer to that question. Partovi is the evidence of the record showing
`what were the known power supplies at the time. And the power supplies
`used today, the common geometries were the boost buck, flyback, boost, or
`a variation of those types. We have a specific answer to the question, what
`were the power supplies that were known? What were essentially any of the
`power supplies? We have specific examples in the record.
`Further on slide 16, our expert testified that in his review of Partovi,
`he agreed that the circuits included in Partovi were the common and well-
`studied circuits, and moreover, that they were demonstrated to be applied in
`an inductive power supply circuit, that's the circuit of Baarman. Baarman is
`an inductive power supply circuit. So, Barman says it's an inductive power
`supply circuit and is designed to be used with essentially any known power
`supply. And Partovi provides the evidence of what the POSITAs knew in
`terms of those power supplies. We have the known system of Baarman, the
`known techniques of Partovi to achieve the predictable result of using a
`known power supply in an inductor power supply circuit.
`Further, we have additional evidence in the record, as shown on slide
`17, that our expert, when analyzing these references, noted that if you were
`to go so far as to actually do the physical incorporation of the two teachings
`that if you did so, you'd actually be able to use less circuitry with Baarman,
`and it would provide an opportunity for cost and space savings. So, we had
`an additional reason to combine and benefit associated with it. We believe
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`IPR2022-00573
`Patent 7,825,537 B2
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`the evidence reflects that Baarman and Partovi 413 would be a proper
`combination.
`With the combinations in hand, we turn to slide 18 to address the few
`claims that were -- had issues raised with them. The first one is claim five.
`And we have claim five shown here on the slide, and it's an additional
`limitation and it is a dependent claim. We're adding this additional step of
`comparing. And we're comparing two things. We're comparing said
`measured current or voltage to a constant reference value. Now, we have the
`antecedent basis questionnaire of the said measured current or voltage, and
`we see the answer to that question in the latter half of claim four above,
`where we're selecting said parameter to be a measured current or voltage
`associated with said load. We then have the antecedent basis question of the
`said load. We see that in the first half of claim four where we're
`communicating a current to a load and a base unit.
`So, if we untangle that spaghetti, we're looking at a limitation where
`we're going to be comparing a current or voltage associated with a load in
`the base unit. We're going to compare that measured current associated with
`the load to a constant reference value. So, if we turn to slide 19, we can start
`seeing the discussion --
`JUDGE LEE: Mr. Ehmke, it's Judge Lee, let's go back to your slide
`
`18.
`
`MR. EHMKE: Yes, Your Honor.
`JUDGE LEE: You -- I guess you started with five because the Patent
`Owner essentially didn't say much about your claim four. They complained
`about claim five. But honestly when I read all the briefs, I'm coming to the
`thought that if Patent Owner’s right in Patent Owner’s arguments for claim
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`IPR2022-00573
`Patent 7,825,537 B2
`
`five, then your arguments for claim four also wouldn't pass muster. So, I'm
`not understanding why there's no argument from Patent Owner on claim
`four, because it seems to me the argument on claim five would dictate they
`would have the same problem with claim four.
`But I just want to let you know so you can start with claim four
`perhaps, and then I can appreciate whether there is such a necessary
`relationship or not. Because right now, I'm seeing the two claims are
`inextricably intertwined that you can't have one and being good with the
`other and not good with -- you know, for instance, there are two things.
`Claim four is only four lines long and I already have two problems right off
`the face of it. One, it says comprising communicating said time varying
`electric current to a load. Well, communicating is only in the claim, it's not
`in their patent. But I think everybody reading this will go well,
`communicating that current to the load simply means, you know, send that
`current to the load. Do you agree with that? I mean it's nothing -- not a
`special word. So that just means send that current to the load. Is that true?
`MR. EHMKE: Yes, your Honor, I do not disagree with your
`assessment of communicating to a load.
`JUDGE LEE: Okay, so that's the problem. If you look at the
`reference, let's say in Figure 3, whatever figure it is that shows it all, the time
`varying AC current is split. Only some of it goes to the load. The other
`half, or whatever percentage continues down its path and ends up, as I sense
`-- I mean it's not a series connection. You know, it comes out of the primary
`coil and then to a node and from that node the load hangs off of that, you
`know, the resistor and the capacitor. But another branch goes off
`somewhere else. So, you know, if I recall my engineering study, that's not
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`IPR2022-00573
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`sending the AC current to the load. That's splitting that AC current. Some
`of it goes to the load, and some of it goes elsewhere. So that's my first
`problem. I don't see how the reference meets this part of claim four, so you
`can explain it later. That's one problem in the first two lines.
`The other two lines is, it says selecting said parameter to be a
`measured current or voltage associated with said load. I don't know what
`associated means. The way you explained it in the petition is almost like,
`sounds too broad to me because if that were right, everything on the board is
`associated with everything else, you know, because every component on the
`board literally affects the value of voltage and current somewhere else. You
`know, I remember people telling me everybody on this earth is technically
`related to each other just seven segments removed. You and I are related. If
`we just go seven, you know, I know somebody who knows somebody who
`knows somebody, ultimately that person is going to know you. So, I think
`that's a bit too broad to say, if this component somehow ends up affecting
`the value of the voltage of current over there at that node. That seems to me
`to be too broad, and that seems to be the approach you are taking, you know,
`so tell me what associated with actually means in the context of the patent.
`MR. EHMKE: Okay.
`JUDGE LEE: So, those are the two problems I already have with
`claim four and it will carry through to claim five.
`MR. EHMKE: Okay. And happy to address those. And you're
`actually touching on the very issues that we want to address with respect to
`this. If I might delay a specific answer and talk about Baarman generally,
`but I will make sure that I specifically answer both of those questions
`throughout this discussion, Your Honor.
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`IPR2022-00573
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`
`So, what we want to talk about with Barman, with both the
`communicating and the associated with the load is what's happening in
`Baarman, as you've mentioned. And we start that discussion on slide 19.
`And what's happening in Baarman is, as you're saying, everything affects
`everything in this system. There are multiple feedback loops occurring.
`You see some of them contained here on figure 3D from Baarman. And I
`want to start with the first feedback loop that's occurring. The first feedback
`loop is, there is a current being applied to the primary inductor coil. That
`current that's being applied is then being sensed by current sensor 322. We
`have current sensor 322 highlighted here. As current sensor 322 is sensing
`what's happening at the primary inductor, it is then sending that
`communication of the time varying current on the line, leaving element 322,
`going into element 324. That is the act of communicating the time varying
`current to the load. So that's the first aspect there. We are communicating
`the time varying current to the load. Now --
`JUDGE LEE: You already lost me, I'm sorry. How is the time
`varying current being communicated to the load?
`MR. EHMKE: We are detecting it with the sensor and then sending it
`from the sensor to the load.
`JUDGE LEE: Through which path?
`MR. EHMKE: Through the path that goes through diode D6.
`JUDGE LEE: No, but like I said before, only part of it goes down to
`the load, you know, the path continues on. It's a split. It's a current divider
`there. It doesn't all go to the load.
`MR. EHMKE: I guess I will quibble with you then, Your Honor. As
`we look at the length of the claim, we're communicating the current to a
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`IPR2022-00573
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`load. We aren't communicating the current to a load because the load is then
`going to be extracting the high -- excuse me, the peak rectified voltage out of
`that current. In order for it to do that, it needs to have received the
`alternating current waveform.
`JUDGE LEE: That's a little tricky there. So, you're saying
`communicating current to the load does not mean that the entire current goes
`to the load. The load can just draw a part of the current?
`MR. EHMKE: The load is -- yes, yeah, yes, Your Honor. The -- it's
`being used to identify the peak. It's not dividing. I guess I want to sort of
`dive into that a little bit, your notion of dividing it. We're using the diode
`and the rest of the load to extract the peak voltage out of that signal.
`JUDGE LEE: Yeah, but do you agree with me earlier on that
`communicating current to the load means sending the current to the load?
`MR. EHMKE: It does mean sending it to the load so that we can
`express --
`JUDGE LEE: (Inaudible) take it, then you're not sending it to it, you
`know. It's only --
`MR. EHMKE: Some of the current?
`JUDGE LEE: Yeah, it's only some of the current. Then -- then --
`MR. EHMKE: So --
`JUDGE LEE: -- so, it doesn't mean sending that current to the load.
`MR. EHMKE: So, I guess I'm trying to understand where we're going
`with a claim construction here. We're supposed to be communicating the
`current to the load. We're not measuring the current. We're not talking
`about what sine wave we're sending to it. We're communicating it.
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`IPR2022-00573
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`
`JUDGE LEE: Yeah, it makes sense with voltage. You know, if you
`hang a load -- connect a load to that voltage, it gets that voltage exactly
`right. But if you just, you know, the current doesn't all go there. If you look
`at the involved patent figure 1, that's not the case. All of the AC current
`from the primary coil actually goes to the load. In figure 1 of the involved
`patent, you see that 106. That's the load. It receives all of the current
`coming from the primary coil. So, I'm having trouble with your position
`because it’s -- not only it's exactly not what the patent shows, it's also not
`according to the literal language.
`MR. EHMKE: I guess I'm still struggling with this, Your Honor, in
`the sense of what's happening with the load and the diode is we have the AC
`signal coming in and we're extracting from it the DC value, the peak voltage.
`And so how is that --
`JUDGE LEE: You’re adding something more to it. The claim doesn't
`say extracting the peak DC value. The claim just says communicating the
`current to the load. That's all it says. (Inaudible) not sufficient so that I need
`only extract the peak DC value. It doesn't say that. It just says communicate
`the current to the load. (Inaudible) but I'll ask them, you know, if the Patent
`Owner agrees with you, then, there's no issue. That's why I don't understand
`what is going on here. They didn't seem to complain about claim four.
`Maybe they agree with you. Maybe they agree that communicating current
`to the load does not mean send all of that current to the load. So, I'll
`withhold judgment there.
`MR. EHMKE: And to that point, Your Honor, what was included
`with respect to claim four in the petition, there were two things being sent to
`the load and claim four, in the petition. Right, there was an alternative basis.
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`The first basis is the one that you are discussing, which was, there's the
`alternating current being sent to the load. Then there's a second
`measurement that's being sent, which is the measurement that's being used
`for the comparison. And so there appears again --
`JUDGE LEE: Yeah, I mean, here's a related question. You know,
`how you've labeled that node there, just above the load. You labeled a peak
`rectified tank current voltage, right?
`MR. EHMKE: Yes.
`JUDGE LEE: That throws me off, because, you know, current is
`current, voltage is voltage. When you say current voltage, I don't know what
`you're talking about.
`MR. EHMKE: That’s the -- so, the current is coming in, and we're
`extracting the peak voltage from it. So, there's the rectified tank current,
`which is coming in, and then we're going to take the peak voltage from that
`and pass it on.
`JUDGE LEE: Well, you're not really speaking in electrical
`engineering jargon. You can't extract a voltage from a current. Current is
`current. You know, it’s -- you can extract a voltage at a point. You know,
`what's the electrical potential at the point? But that's not taken from the
`current. There doesn't need to be any current at a point that has a voltage.
`So, and you're mixing current and voltage in a way that doesn't make any
`sense to me. I don't think it makes sense to call something current voltage. I
`really don't know what you're talking about. I think what you mean is you're
`taking the voltage at that node, right. You mean the voltage at that node.
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`MR. EHMKE: Based off of the current coming into it. We have the
`current coming in, a certain wavelength coming in through the diode going
`to the load that's affecting the voltage at the load. We have --
`JUDGE LEE: Yeah, exactly. The current changes, and that will
`change the voltage there. Exactly. So that's what you mean, right? You
`actually mean the voltage is what you want, the peak rectified tank current
`voltage. You can actually just delete the word current. You just mean the
`voltage at that spot, which varies according to your AC current.
`MR. EHMKE: Correct. Which means the current is coming to the
`load.
`JUDGE LEE: Exactly. So, I can just read it without the word current
`in there. It's the peak rectified tank voltage that you're talking about.
`MR. EHMKE: Correct. Because that becomes the parameter that
`goes to (inaudible) --
`JUDGE LEE: Okay, so we get that clear. You mean the voltage. All
`right. And then what's left is, I'm not sure I agree with you that the current is
`communicated from the coil to the load, because I think all of it kind of has
`to go before you can say that, but so far the Patent Owner didn't disagree.
`So. I'll ask them about that later. But I understand your view. Thank you.
`MR. EHMKE: Okay. So then the second component of this, as we
`mentioned, there's two feedback loops. The first feedback loop is sensing
`from the primary coil going to the current sensor and then going to the load.
`The second feedback loop is -- starts on slide 21, where we're also
`measuring what's happening in the secondary unit. There's a current sensor
`and secondary unit 218. And that secondary current sensor is trying to
`detect what's being sent to the secondary device. From there, that current
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`sensor 218 on slide 22 as incorporated through the Baarman 392 reference,
`that's a feedback detector as this current sensor. It's wirelessly coupled back
`to the primary tank circuit. That's important because it's communicating
`back down back to the primary inductor coil, which again is being sensed by
`current sensor 322, which then speeds that signal back through the load so
`that we can extract the peak voltage value from it to then impact the system.
`So, we have feedback loop at the base unit that goes from the current sensor
`to the load to the controller. Then we have a second feedback loop from the
`secondary device that goes back to the primary circuit through the current
`sensor back to the load.
`So, we're calling that associated because without the load in that loop
`-- and the load is for both what's being measured at the primary coil as well
`as what's being measured at the secondary coil -- we're having to extract
`from that the voltage value, because that's the parameter being used by the
`controller. Without the load as part of that, without that load analyzing the
`current coming into it, we don't get the parameter going to the controller.
`That's the association that we're referring to. We're not referring to an
`association globally across the device. We're pointing to the association that
`both is the pre- and post-association. We have to measure current that goes
`to the load for extraction, which goes to the controller and goes back to the
`primary coil to be detected again and measured. So, the output of what the
`load outputs gets detected and that has now been sent as an input back to the
`load in this loop. That's the association --
`JUDGE LEE: So, it’s Judge Lee again. So, whichever feedback
`you're talking about, you're saying the load is there in order to extract the
`measured value.
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`MR. EHMKE: Correct.
`JUDGE LEE: And that's why the measured value is associated with
`the load?
`MR. EHMKE: Correct.
`JUDGE LEE: I know what you're saying, but the logic doesn't seem
`to be there. I know it has a role in extracting the measured value, but why
`does that make it associated with the load? You will send the measured
`value to the load for sure, I understand now, but why does that make it create
`an association?
`MR. EHMKE: Because there's a dependency associated with it.
`Right? As you were pointing out, as the current is coming in, it's being
`affected by the load, right. And that's part of the calculus that's occurring to
`pull out the value. So, there's a dependency associated with it.
`JUDGE LEE: Yeah, but it's in the wrong direction. Usually when
`you say something is associated with something else, it's the something else
`will affect the first one, but you have it in the reverse.
`MR. EHMKE: You have to have (phonetic) --
`JUDGE LEE: You know, the measured value is associated with the
`load because the measured value goes to the load. But that's the reverse of
`the normal situation.
`MR. EHMKE: But the circuit keeps going, Your Honor. It is a loop.
`What comes out of the load then impacts the coil, which we are then
`detecting with the