UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00573
`U.S. Patent No. 7,825,537
`
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
`
`

`

`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`TABLE OF CONTENTS
`
`
`
` I.
`
`REQUIREMENTS FOR IPR UNDER 37 C.F.R. § 42.104 ............................ 1
` Standing .................................................................................................... 1
` Challenge and Relief Requested ............................................................... 1
`SUMMARY OF THE ’537 PATENT ............................................................. 3
` Brief Description ....................................................................................... 3
` Summary of the Prosecution History ........................................................ 4
` Level of Ordinary Skill in the Art ............................................................. 5
`III. CLAIM CONSTRUCTION UNDER 37 C.F.R. §§ 42.104(b)(3) .................. 5
`IV. THE CHALLENGED CLAIMS ARE UNPATENTABLE ............................ 6
` [Ground 1A]: Obviousness Based on Baarman in view of Partovi-002 .. 6
`1.
`Baarman ........................................................................................... 6
`2.
`Partovi-002 ....................................................................................11
`3.
`Baarman and Partovi-002 Render Claims 1-5, 8-16, 19-22, and 28
`Obvious..........................................................................................12
` [Ground 1B]: Obviousness Based on Baarman in view of Partovi-002
`and Partovi-413 .......................................................................................42
`1.
`Partovi-413 ....................................................................................43
`2.
`Baarman, Partovi-002, and Partovi-413 Render Claims 6-7 and
`17-18 Obvious ...............................................................................43
` [Ground 2A]: Anticipation by Flowerdew .............................................47
`1.
`Flowerdew .....................................................................................47
`2.
`Flowerdew Anticipates Claims 1-2, 8-11, and 28 .........................49
` [Ground 2B]: Obviousness Based on Flowerdew in view of Jang .........61
`1.
`Jang ................................................................................................61
`2.
`Flowerdew in view of Jang Renders Claims 3-5, 12-16, and 19-22
`Obvious..........................................................................................62
` [Ground 2C]: Obviousness Based on Flowerdew in view of Partovi-413
`
`72
`1.
`Flowerdew in view of Partovi-413 Render Claims 6 and 7
`Obvious..........................................................................................72
`[Ground 2D]: Obviousness Based on Flowerdew in view of Jang and
`Partovi-413 ..............................................................................................75
`1.
`Flowerdew in view of Jang and Partovi-413 Render Claims 17 and
`18 Obvious ....................................................................................75
`
`II.
`
`
`
`i
`
`

`

`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`
`V. DISCRETIONARY CONSIDERATIONS ...................................................76
` The Petition’s New Prior Art and Errors Made During Prosecution
`Warrant Institution—35 U.S.C. § 325(d) ...............................................76
` The Fintiv Factors Favor Institution .......................................................76
`VI. CONCLUSION ..............................................................................................78
`VII. MANDATORY NOTICES UNDER 37 C.F.R. §42.8 ..................................80
`A. Real Party-in-Interest ..............................................................................80
`B. Related Matters .......................................................................................80
`C. Lead and Back-up Counsel and Service Information .............................81
`CERTIFICATE OF WORD COUNT ......................................................................83
`Certificate of Service ...............................................................................................84
`
`
`
`
`
`ii
`
`

`

`
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`EXHIBITS
`
`EX1001
`
`U.S. Patent 7,825,537 to Freer (“the ’537 patent”)
`
`EX1002
`
`Prosecution History of the ’537 patent (Serial No. 12/271,023)
`
`EX1003
`
`Declaration of Thomas Szepesi, Ph.D.
`
`EX1004
`
`U.S. Pub. 2009/0174263 (“Baarman”)
`
`EX1005
`
`U.S. Pub. 2007/0279002 (“Partovi-002”)
`
`EX1006
`
`U.S. Pub. 2009/0096413 (“Partovi-413”)
`
`EX1007
`
`U.S. Patent 7,211,986 (“Flowerdew”)
`
`EX1008
`
`U.S. Patent 6,825,620 (“Kuennen”)
`
`EX1009
`
`U.S. Prov. App. Serial No. 61/019,411 (“’411 Provisional”)
`
`EX1010
`
`U.S. Pub. 2004/0218406 (“Jang”)
`
`EX1011
`
`Reserved.
`
`EX1012
`
`U.S. Pub. 2008/0079392 (“Baarman-392”)
`
`EX1013
`
`U.S. Patent 5,600,225 (“Goto”)
`
`EX1014
`
`EX1015
`
`Kim et al., A Contactless Power Supply for Photovoltaic Power
`Generation System, 2008 IEEE Applied Power Electronics
`Conference (pp. 1910-13 in the APEC 2008 Proceedings)
`
`Severns et al., MODERN DC-TO-DC SWITCH MODE POWER
`CONVERTER CIRCUITS, Van Nostrand Reinhold Co. (1985) (selected
`excerpts)
`
`iii
`
`

`

`
`EX1016
`
`EX1017
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Baker et al., CMOS CIRCUIT DESIGN, LAYOUT, AND SIMULATION,
`IEEE Press (1998) (selected excerpts)
`
`Erickson, FUNDAMENTALS OF POWER ELECTRONICS, Chapman & Hall,
`International Thomson Publishing (1997) (selected excerpts)
`
`EX1018
`
`Horowitz et al., THE ART OF ELECTRONICS, 2nd Ed., Cambridge
`University Press (1989) (selected excerpts)
`
`EX1019
`
`Daniel M. Mitchell, DC-DC SWITCHING REGULATOR ANALYSIS,
`McGraw-Hill (1986) (selected excerpts)
`
`
`
`
`
`
`
`iv
`
`

`

`
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`CLAIM LISTING
`
`Claim Language
`Element
`[1.P] A method for inductively transferring power from a base unit
`providing input power, to a target unit providing output power, where
`the base unit and the target unit are electrically isolated, comprising:
`
`[1.1]
`
`[1.2]
`
`positioning a second inductive element of said target unit within a
`predetermined distance of a first inductive element of said base unit;
`
`applying a time varying electric current to said first inductive element
`to produce a time varying magnetic field, said time varying magnetic
`field induces an electric current in said second inductive element;
`
`[1.3] monitoring at least one parameter indicative of an efficiency of power
`transfer from said base unit to said target unit;
`
`[1.4]
`
`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.
`
`[2]
`
`[3]
`
`[4]
`
`[5]
`
`The method according to claim 1, wherein said characteristic
`comprises at least one of a frequency of said time varying current and
`a duty cycle of said time varying current.
`
`The method according to claim 1, further comprising producing said
`time varying electric current by switching a DC voltage source using
`an electronically controlled switch element.
`
`The method according to claim 3, further comprising communicating
`said time varying electric current to a load in said base unit, and
`selecting said parameter to be a measured current or voltage
`associated with said load.
`
`The method according to claim 4, further comprising comparing said
`measured current or voltage to a constant reference value.
`
`v
`
`

`

`
`
`Element
`[6]
`
`[7]
`
`[8]
`
`[9]
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Claim Language
`The method according to claim 1, further comprising producing said
`time varying magnetic field with a DC to DC type switching mode
`power supply circuit.
`
`The method according to claim 6, further comprising utilizing said
`first inductive element as a primary energy storage component in a
`DC to DC conversion process of said DC to DC type switching mode
`power supply circuit.
`
`The method according to claim 1, wherein said automatically
`adjusting step further comprises automatically adjusting said
`characteristic to induce an oscillation in said second inductive
`element at a frequency to be approximately equal to a self-resonant
`frequency of said second inductive element.
`
`The method according to claim 1, further comprising responsive to a
`re-positioning of said second inductive element from a first position
`to a second position, automatically selectively re-adjusting said
`characteristic to maximize said efficiency, wherein said first position
`differs from said second position with regard to at least one
`characteristic selected from the group consisting of distance and
`orientation relative to said first inductive element.
`
`[10]
`
`[11]
`
`The method according to claim 1, further comprising responsive to a
`substitution of a target unit with a different target unit, automatically
`selectively re-adjusting said characteristic to maximize said
`efficiency.
`
`The method according to claim 1, further comprising rectifying an
`output current induced in said second inductive element to produce a
`DC output.
`
`[12.P] An inductive power transfer system, comprising:
`
`[12.1]
`
`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;
`
`vi
`
`

`

`
`
`Element
`[12.2]
`
`[12.3]
`
`[12.4]
`
`[12.5]
`
`[13]
`
`[14]
`
`[15]
`
`[16]
`
`[17]
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Claim Language
`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.
`
`The system of claim 12, wherein said characteristic comprises at least
`one of a frequency of said time varying current and a duty cycle of
`said time varying current.
`
`The system of claim 12, wherein said switch element is electronically
`controlled, and wherein said switch element is configured for
`coupling and decoupling a DC voltage source to said first inductive
`element to produce said time varying current.
`
`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.
`
`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.
`
`The system of claim 12, wherein said base unit further comprises a
`DC to DC type switching mode power supply, said DC to DC type
`
`vii
`
`

`

`
`
`Element
`
`[18]
`
`[19]
`
`[20]
`
`[21]
`
`[22]
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Claim Language
`switching mode power supply producing said time varying magnetic
`field.
`
`The system of claim 17, wherein said first inductive element
`comprises a primary energy storage component of said DC to DC
`type switching mode power supply.
`
`The system of claim 12, wherein said control circuit is further
`configured during said automatically adjusting for automatically
`selectively adjusting a frequency to be approximately equal to a self-
`resonant frequency of said second inductive element.
`
`The system of claim 12, wherein said control circuit is further
`configured during said automatically adjusting for automatically
`selectively re-adjusting a frequency to maximize said efficiency
`responsive to a re-positioning of said second inductive element from a
`first position to a second position, wherein said first position differs
`from said second position with regard to at least one characteristic
`selected from the group consisting of distance and orientation relative
`to said first inductive element.
`
`The system of claim 12, wherein said control circuit is further
`configured during said automatically adjusting for automatically
`selectively re-adjusting a frequency to maximize said efficiency
`responsive to a substitution of a target unit with a different target unit.
`
`The system of claim 12, wherein said target unit further comprises a
`rectifying element configured to produce a DC output by rectifying an
`output current induced in said second inductive element.
`
`[28.P] A method for inductively transferring power from a base unit
`providing input power, to a target unit providing output power, where
`the base unit and the target unit are electrically isolated from each
`other, comprising:
`
`[28.1]
`
`positioning a second inductive element of said target unit within a
`predetermined distance of a first inductive element of said base unit;
`
`viii
`
`

`

`
`
`
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Element
`[28.2]
`
`Claim Language
`applying a time varying electric current to said first inductive element
`to produce a time varying magnetic field having an operating
`frequency, said time varying magnetic field inducing an electric
`current in said second inductive element;
`
`[28.3] monitoring at least one parameter of an electronic component of said
`base unit that is indicative of an efficiency of power transfer from
`said base unit to said target unit; and
`
`[28.4]
`
`automatically adjusting said operating frequency based on a value of
`said parameter to maximize said efficiency of power transfer from
`said base unit to said target unit.
`
`
`
`ix
`
`

`

`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Apple Inc. (“Petitioner” or “Apple”) petitions for Inter Partes Review
`
`
`
`(“IPR”) of claims 1-22 and 28 (“the Challenged Claims”) of U.S. Patent 7,825,537
`
`(“the ’537 patent”). Apple respectfully requests institution of IPR and cancellation
`
`of all Challenged Claims. This petition is identical substantively to the petition
`
`filed by Anker in IPR2022-00499, except for the analysis of discretionary
`
`considerations.
`
`I.
`
`REQUIREMENTS FOR IPR UNDER 37 C.F.R. § 42.104
`Standing
`
`Apple certifies that the ’537 patent is available for IPR. The present Petition
`
`is being filed within one year of service of a complaint against Apple in Scramoge
`
`Technology Ltd. v. Apple Inc., 6-21-cv-01071 (W.D. Tex.). Apple is not barred or
`
`estopped from requesting this review.
`
` Challenge and Relief Requested
`Apple requests IPR of the Challenged Claims on the grounds set forth in the
`
`table shown below. Evidentiary support for each ground is set forth in the
`
`Declaration of Thomas Szepesi, Ph.D. (EX1003) referenced herein.
`
`
`
`1
`
`
`

`

`
`
`
`
`Ground
`1(A)
`1(B)
`
`2(A)
`2(B)
`2(C)
`2(D)
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Basis for Rejection
`Claims
`1-5, 8-16, 19-22, 28 §103 – Baarman in view of Partovi-002
`6-7, 17-18
`§103 – Baarman in view of Partovi-002 and
`Partovi-413
`§102 – Flowerdew
`§103 – Flowerdew in view of Jang
`§103 – Flowerdew in view of Partovi-413
`§103 – Flowerdew in view of Jang and
`Partovi-413
`
`1-2, 8-11, 28
`3-5, 12-16, 19-22
`6-7
`17-18
`
`
`For purposes of this proceeding, Petitioner treats November 14, 2008 as the
`
`earliest effective filing date (“Critical Date”) of the ’537 patent. As such, the
`
`publications cited in Grounds 1(A)-2(D) qualify as prior art as follows:
`
`Reference
`
`Filed
`
`Published
`
`Baarman
`Partovi-002
`Partovi-413
`Flowerdew
`Jang
`
`01/07/20081
`06/01/2007
`05/07/2008
`07/01/2004
`05/01/2003
`
`07/09/2009
`12/06/2007
`04/16/2009
`05/01/2007
`11/04/2004
`
`Pre-AIA 35 U.S.C. §102
`Prior Art Basis
`§102(e)
`§102(a), (e)
`§102(e)
`§102(a)-(b), (e)
`§102(a)-(b), (e)
`
`
`
`
`1 Baarman claims priority to a provisional application (the ’411 provisional
`
`(EX1009)), filed January 7, 2008. The Baarman reference itself (EX1004) is a
`
`publication of a non-provisional application filed January 7, 2009. EX1003, ¶89.
`
`2
`
`
`

`

`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`None of the references applied in Grounds 1(A)-2(D) were previously cited
`
`
`
`or applied in a rejection during prosecution of the ’537 patent. Infra, Sections II.B,
`
`V.A.
`
`II.
`
`SUMMARY OF THE ’537 PATENT
` Brief Description
`The ’537 patent describes “inductive power transfer” systems. EX1001, 1:6-
`
`8, 1:12-18; EX1003, ¶¶68-83; see also id., ¶¶37-67 (Dr. Szepesi’s detailed
`
`explanation of pertinent technological principles). In such a system, “mutual
`
`inductance generally results in power being wirelessly transferred from a primary
`
`coil (or simply ‘primary’) in a power supply circuit to a secondary coil (or simply
`
`‘secondary’) in a secondary circuit.” EX1001, 1:13-17. “Typically, the secondary
`
`circuit is electrically coupled with a device, such as a lamp, a motor, a battery charger
`
`or any other device powered by electricity.” Id., 1:17-21.
`
`According to the specification, “the amount of power transferred” from the
`
`primary to the secondary depends on “the amount of magnetic coupling” between
`
`the primary and the secondary inductive elements. Id., 4:7-11. The ’537 patent
`
`states that, in purportedly “conventional designs,” “the amount of magnetic coupling
`
`is adjusted by matching the inductor coil design” of the respective inductive
`
`elements of the primary and secondary sides of the system. Id., 4:11-13. “However,
`
`this typically results in a base unit design compatible with only a particular target
`
`3
`
`
`

`

`
`unit design, limiting the flexibility of the base unit to power additional target units,”
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`and “[f]urthermore, because a high degree of inductor coil matching is generally
`
`required, the operational margin for such base unit/target unit combinations is also
`
`limited.” Id., 4:13-19.
`
`In view of these perceived deficiencies, the ’537 patent disclosed techniques
`
`for adjusting the “operating frequency” of the primary inductive element “until [a]
`
`self-resonant oscillation is induced” in the secondary inductive element. Id., 4:34-
`
`42. Specifically, “inducing a self resonant oscillation provides the most efficient
`
`power transfer” between the primary and secondary circuits. Id., 4:57-59. This
`
`adjustment of the operating frequency of the primary inductor (e.g., and separately
`
`the “duty cycle”) purportedly provides control of power transfer characteristics from
`
`the primary circuit to the secondary circuit. Id., 4:20-50.
`
`Summary of the Prosecution History
`
`The ’537 patent was filed November 14, 2008, with 27 original claims.
`
`EX1002, 98-103; EX1003, ¶¶84-86. In the only substantive action issued during the
`
`course of prosecution, the Examiner rejected the original claims as being anticipated
`
`by US6,421,600 (“Ross”). EX1002, 42-50. In response, the applicant argued that
`
`Ross failed to disclose “maximiz[ing] the efficiency of power transfer” from the base
`
`unit to the target unit because Ross instead adjusted a “magnitude” of a magnetic
`
`4
`
`
`

`

`
`field merely “to regulate the interior temperature of the target unit 12.” Id., 29;
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`generally id., 20-32.
`
`The Examiner thereafter allowed the application, but provided no explicit
`
`reasons for allowance. Id., 13-16. Critically, the prosecution history provides no
`
`indication that the Examiner previously considered more pertinent references at the
`
`time, such as Baarman, Partovi-002, Flowerdew, Partovi-413, and Jang. If the
`
`predictable combinations of these prior art teachings set forth in Grounds 1(A)-2(D)
`
`had been considered, the ’537 patent never would have issued.
`
` Level of Ordinary Skill in the Art
`For purposes of this IPR, Petitioner submits that a person of ordinary skill in
`
`the art at the time of the alleged invention (“POSITA”) would have had a bachelor’s
`
`degree or higher in electrical engineering, at least 3 years of experience designing or
`
`researching electronic circuits, and familiarity with power electronics and switching
`
`voltage regulator circuits. EX1003, ¶¶17-19.
`
`III. CLAIM CONSTRUCTION UNDER 37 C.F.R. §§ 42.104(b)(3)
`All claim terms should be construed according to the Phillips standard.
`
`Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005); 37 C.F.R. §42.100.
`
`Petitioner has applied the plain meaning of the claim terms recited in the Challenged
`
`Claims according to the Phillips standard, and submits that no formal construction
`
`is “necessary to resolve” the anticipation/obviousness issues raised in this Petition.
`
`5
`
`
`

`

`
`Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011). To the
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`extent the scope of any claim term is later brought into controversy during this
`
`proceeding, Petitioner will timely reply in accordance with due process.
`
`IV. THE CHALLENGED CLAIMS ARE UNPATENTABLE
`[Ground 1A]: Obviousness Based on Baarman in view of
`
`Partovi-002
`Baarman
`1.
`Baarman has an effective filing date of January 7, 2008
`
`i.
`
`Baarman claims the benefit of U.S. Provisional Application No. 61/019,411
`
`(EX1009, the “’411 Provisional”), which was filed January 7, 2008 —i.e., more than
`
`10 months before the Critical Date of the ’537 patent. Baarman qualifies as prior art
`
`to the ’537 patent based on its provisional priority date. See Dynamic Drinkware,
`
`LLC v. National Geographics, Inc., 800 F.3d 1375 (Fed. Cir. 2015); Amgen v. Sanofi,
`
`872 F.3d 1367, 1380 (Fed. Cir. 2017). In accordance with Dynamic Drinkware, the
`
`’411 Provisional provides clear and unambiguous support for at least independent
`
`claim 1 of Baarman. EX1003, ¶89. The following table identifies exemplary
`
`support in the ’411 Provisional for each limitation of Baarman’s claim 1, and the
`
`testimony of Dr. Szepesi (EX1003, ¶¶89-90) also confirms this fact:
`
`
`
`6
`
`
`

`

`
`
`
`
`Baarman (Claim 1)
`
`An inductive power supply for
`providing power wirelessly to a
`remote device, said inductive
`power supply comprising:
`a primary circuit for generating
`a signal at an operating
`frequency and a duty cycle;
`
`a tank circuit in electrical
`communication with said
`primary circuit,
`wherein said primary circuit
`applies said signal to said tank
`circuit to transfer an amount of
`power to said remote device;
`wherein said inductive power
`supply receives feedback from
`said remote device;
`
`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`Exemplary Support
`’411 Provisional (EX1009)
`EX1009, 3 (“inductive power supply”), FIG.
`1; see also p. 4, FIGS. 3A-B; EX1003, ¶89.
`
`EX1009, 3 (primary circuit 100; alternatively,
`the collection of primary controller 110, driver
`circuit 111, and switching circuit 115), FIG. 1;
`see also pp. 4-5, FIGS. 3A-3B; EX1003, ¶89.
`EX1009, 3 (tank circuit 120), FIG. 1; see also
`pp. 6-7, FIGS. 3A-3B (tank circuit 320);
`EX1003, ¶89.
`EX1009, 3 (“transferring power wirelessly to a
`secondary circuit”), FIGS. 1-2; see also pp. 7-
`8; EX1003, ¶89.
`
`EX1009, 1 (“maintains resonant frequency
`and adjusts duty cycle based on feedback from
`a secondary circuit”), 3 (“communicating
`using reflected impedance and an optional
`wireless transmitter”), 16 (“Using feedback
`from the secondary, ...”); EX1003, ¶89.
`
`7
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`
`

`

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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
`
`EX1009, 16 (“the operating frequency may be
`adjusted .to ensure optimum power transfer
`efficiency ...”); see also pp. 3, 12-14, FIGS. 5-
`6; EX1003, ¶89.
`
`wherein, in response to said
`feedback, said primary circuit
`controls said operating
`frequency of said signal to
`optimize power transfer
`efficiency between said
`inductive power supply and said
`remote device; and
`wherein, in response to said
`feedback, said primary circuit
`controls said duty cycle of said
`signal to control said amount of
`power transferred to said remote
`device.
`Even beyond the support for the claims of Baarman, the evidence confirms
`
`EX1009, 16 (“the duty cycle may be adjusted
`to provide additional or less power to meet the
`desired goal”); see also pp. 3, 12-13, FIG. 5;
`EX1003, ¶89.
`
`that Baarman’s teachings cited herein against the ’537 patent were similarly taught
`
`in the ’411 Provisional. Infra, Analysis of Grounds 1(A)-1(B) below (citing to
`
`EX1004 and then corresponding portions of EX1009); see also Ex Parte Mann, No.
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`2015-003571, 2016 WL 7487271, at *6 (PTAB Dec. 21, 2016); Huawei Techs. Co.,
`
`Ltd. v. WSOU Investments, LLC, IPR2021-00222, Paper 10 at 40-42 (PTAB June 7,
`
`2021). Accordingly, Baarman qualifies as prior art to the ’537 patent.
`
`ii.
`
`Overview
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`8
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`Baarman discloses techniques for maximizing efficiency in an inductive
`
`
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`wireless power transfer system. EX1004, [0006]-[0009]; EX1009, 1-2; EX003,
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`¶¶90-99. Specifically, Baarman describes an inductive power transfer system that
`
`provides separate control of the frequency and duty cycle of a switching signal in
`
`the primary circuit. EX1004, [0009]; EX1009, 2. By separately setting the
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`frequency and duty cycle of the switching signal, a controller in the primary circuit
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`is configured to control the amount of power delivered to the secondary through duty
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`cycle adjustments while continuing to maximize power transfer efficiency through
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`frequency adjustments that maintain the circuit at resonance. EX1004, [0009],
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`[0025], [0050]; EX1009, 2, 5, 16.
`
`Figure 6, for example, depicts a process performed by a primary controller to
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`dynamically adjust the operating frequency toward resonance to maintain peak
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`power transfer efficiency:
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`9
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`

`

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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`
`
`EX1004, FIG. 6; [0040]-[0047]; FIGS. 5-7; EX1009, 12-16, FIGS. 5-7.
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`Baarman’s primary controller “establish[es] the operating frequency as a
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`function of input from [a] current sensor 322” that detects current flow through the
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`primary inductor. EX1004, [0029], FIG. 3A, 3D; see also id., [0031]-[0032], FIG.
`
`1; EX1009, 7-9, FIGS. 3A-3B. In some examples, the current sensor is used to detect
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`messages inductively communicated to the primary circuit from the secondary
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`circuit that indicate a “sensed current and/or sensed voltage” induced at the
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`10
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`

`

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`secondary circuit. EX1004, [0038]; EX1009, 11. Using this feedback from the
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`secondary circuit, and “knowing the voltage and/or current provided by the primary
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`circuit, the primary controller can calculate the power transfer efficiency.” EX1004,
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`[0035]; EX1009, 10-11.
`
`To illustrate, Figures 1 and 2 depict block diagrams of Baarman’s disclosed
`
`primary and secondary circuits, respectively:
`
`
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`
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`EX1004, FIGS. 1-2; EX1009, FIGS. 1-2.
`
`Partovi-002
`2.
`Partovi-002, like Baarman, is directed to inductive wireless power transfer
`
`systems. EX1005, Abstract, [0004]; EX1003, ¶100. Partovi-002 further describes
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`11
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`

`

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`structures for positioning a receiving unit (containing a secondary inductor) within
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`a predetermined distance of a primary inductor of a charging unit. EX1005, [0081]
`
`(“To enhance the ability of the receiver to receive power, it may be desirable to
`
`minimize the distance between the charger’s primary coil and the receivers coil or
`
`wire.”), [0082], FIG. 6; infra Elements [1.1], [12.2]. Partovi-002 also describes the
`
`use of magnets to produce a force that brings the secondary coil of a receiving unit
`
`into operable position with respect to a primary coil of a charging pad. EX1005,
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`[0032], [0135], FIG. 13; generally id., [0085]-[0087], [0135]-[0141], FIGS. 13-16.
`
`EX1005, FIG. 13.
`
`3.
`
`Baarman and Partovi-002 Render Claims 1-5, 8-16,
`19-22, and 28 Obvious
`
`
`
`12
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`

`

`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`The predictable combination of Baarman in view of Partovi-002 provides
`
`
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`each element of claims 1-5, 8-16, 19-22, and 28, and would have rendered each of
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`these claims obvious before the Critical Date of the ’537 patent.
`
`Element [1.P]
`To the extent the preamble is a limitation, Baarman discloses a method for
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`inductively transferring power from a “primary circuit” (base unit) providing input
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`power, to a “secondary circuit” (target unit) providing output power. EX1004,
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`[0019] (“create an inductive field for transferring power wirelessly to a secondary
`
`circuit”), [0021] (“present invention is suitable for use with a wide variety of
`
`inductive power supplies”); EX1009, 3-4; EX1003, ¶¶110-111.
`
`Figure 1, for example, depicts a primary circuit 100 (base unit) that
`
`inductively powers a secondary circuit 200 (target unit) (shown in Figure 2):
`
`13
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`

`

`
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`EX1004, FIG. 1; see also id., FIGS. 3A-3D (depicting another embodiment of a
`
`primary circuit 300); EX1009, FIGS. 1, 3A-3B.
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`
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`14
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`

`

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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`
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`EX1004, FIG. 2; see also id., FIG. 4 (depicting another embodiment of a secondary
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`circuit 400); EX1009, FIGS. 2, 4.
`
`The evidence here also confirms that Baarman’s primary circuit and
`
`secondary circuit are electrically isolated. EX1004, [0006]-[0008], [0019]; EX1009,
`15
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`

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`1-2; EX1003, ¶¶111. Indeed, no electrical connection is disclosed between the
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`primary and secondary circuits, and the nature of “wireless” or “inductive” power
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`transfer enables electrical isolation by inducing current flow in the secondary circuit
`
`through magnetic induction. Id.
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`Element [1.1]
`The teachings of Baarman in view of Partovi-002 provide this claim element
`
`[1.1]. To start, Baarman acknowledges the well-understood principle of inductive
`
`systems that the level and efficiency of power transfer from the primary to the
`
`secondary is impacted by the positioning of the secondary inductor relative to the
`
`primary coil. EX1004, [0045] (“a change in orientation of the secondary” changes
`
`its coupling to the primary); EX1009, 14-15. As Dr. Szepesi testified, the strength
`
`of the magnetic field in an inductive power transfer system diminishes with distance
`
`from the primary inductor and thus a stronger magnetic coupling can be achieved by
`
`positioning the secondary inductor in closer proximity to the primary inductor, and
`
`in alignment with the magnetic field lines. EX1003, ¶112; see also id., ¶¶113-117.
`
`Additionally or alternatively, Baarman also incorporates by reference
`
`US6,825,620 (EX1008, “Kuennen”). EX1004, [0028]; EX1009, 6-7. Baarman,
`
`through its incorporation of Kuennen, teaches that “[t]he air gap is the distance
`
`between the inductive coupler and the secondary coil,” and “the air gap provides a
`
`magnetic flux path for inducing sufficient voltage in the secondary coil to establish
`
`16
`
`
`

`

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`and maintain an operating point for the secondary load.” EX1008, 3:22-28.
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`IPR2022-00573 Petition
`Inter Partes Review of U.S. 7,825,537
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`Baarman, through its incorporation of Kuennen, further discloses that the secondary
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`coil (element 52, FIG. 2B) in assembly 14 should be removably seated onto a main
`
`housing 12 at predetermined distance from the primary inductor (electronics
`
`assembly 44 in bottom of base 18, FIG. 2A). Id., FIGS. 2A-2B and 4, 5:34-62, 8:29-
`
`48,15:64-16:44. At a minimum, Baarman thus plainly suggests that a second
`
`inductive element of the target un