Inter Partes Review of U.S. Patent No. 10,804,740
`Declaration of Gary Woods
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
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`GOOGLE LLC
`Petitioner
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`v.
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`SCRAMOGE TECHNOLOGY LTD.
`Patent Owner
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`Patent No. 10,804,740
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`______________________________________________
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`DECLARATION OF DR. GARY WOODS
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`Page 1 of 176
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`GOOGLE EXHIBIT 1002
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`Declaration of Gary Woods
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
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`GOOGLE LLC
`Petitioner
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`v.
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`SCRAMOGE TECHNOLOGY LTD.
`Patent Owner
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`Patent No. 10,804,740
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`______________________________________________
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`DECLARATION OF DR. GARY WOODS
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`Page 1 of 176
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`GOOGLE EXHIBIT 1002
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`I.
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`Inter Partes Review of U.S. Patent No. 10,804,740
`Declaration of Gary Woods
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`I, Gary Woods, hereby declare as follows.
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`INTRODUCTION
`1.
`I have been retained as an expert witness on behalf of Google LLC
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`(“Petitioner”) for the above-captioned inter partes review (IPR). I understand that
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`Petitioner challenges the validity of Claims 1-10 of U.S. Patent No. 10,804,740.
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`2.
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`I am over the age of eighteen (18) and otherwise competent to make
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`this declaration. I am being compensated for my time in connection with this IPR
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`at my standard consulting rate.
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`3.
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`I understand that the petition for inter partes review involves U.S.
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`Patent No. 10,804,740 (the “’740 Patent”), Ex-10011, which resulted from U.S.
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`Application No. 16/264,360 (the “’360 Application”). The ’360 Application was
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`filed on January 31, 2019, and is a continuation of U.S. Patent App. No.
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`15/430,173 (now U.S. Patent No. 10,277,071), filed February 10, 2017, which is a
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`continuation of U.S. Patent App. No. 15/360,425 (now U.S. Patent No.
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`10,270,291), filed November 23, 2016, which is a continuation of U.S. Patent App.
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`No. 13/663,012 (now U.S. Patent No. 9,806,565), filed October 29, 2012. The
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`1 All exhibit citations refer to the exhibits attached to the Petition for Inter Partes
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`Review of U.S. Patent No. 10,804,740, that I am informed will be filed concurrent
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`with my declaration.
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`1
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`’740 patent also claims priority to Korean Patent Applications 10-2012-0029987
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`and 10-2012-0079004, filed March 23, 2012, and July 19, 2012, respectively. The
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`’740 patent names Jeong Wook An, Jung Oh Lee, Sung Hyun Leem, and Yang
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`Hyun Kim as the inventors. See Ex-1001 at Cover. The ’740 Patent issued on
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`October 13, 2020, from the ’360 application. I further understand that, according
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`to USPTO records, the ’740 Patent is currently assigned to Scramoge Technology
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`Limited (“Patent Owner” or “Scramoge”).
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`4.
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`I have been asked to assume that the earliest date to which the ’740
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`Patent is entitled to priority is March 23, 2012.
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`5.
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`In preparing this Declaration, I have reviewed the ’740 Patent and
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`considered each of the documents cited herein, in light of general knowledge in the
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`art. In formulating my opinions, I have relied upon my experience in the relevant
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`art and have also considered the viewpoint of a person of ordinary skill in the art.
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`6.
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`I am familiar with the technology at issue as of March 23, 2012, the
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`earliest claimed priority date of the ’740 Patent. I am also familiar with a person of
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`ordinary skill in the art with respect to the technology at issue as of the March 23,
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`2012 earliest claimed priority date of the ’740 Patent.
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`II. MY BACKGROUND AND QUALIFICATIONS
`7.
`Since 2008, I have been employed as a Professor in the Practice in the
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`Department of Electrical and Computer Engineering at Rice University in Houston,
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`Texas. Since 2020, my title has been Distinguished Professor in the Practice.
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`Before that, I worked as a postdoctoral fellow at the University of California, Santa
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`Barbara (1996-1998); at Intel Corporation (1998-2000); at Spectralane Inc. (2000-
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`2002); at Optonics (later Credence Systems Corp.) (2003-2006); and as an
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`independent consultant (2006-present). In the summers of 1988 and 1989 I worked
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`at Texas Instruments.
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`8. My educational background includes undergraduate degrees in
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`Physics and Electrical Engineering from Rice University in 1988 and an MS
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`(1991) and Ph.D. (1997) in Applied Physics from Stanford University.
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`9.
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`I am familiar with patents both as an inventor and as chief technology
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`officer in charge of the patent portfolio of a company I co-founded, Spectralane. I
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`am an inventor on 16 issued and one pending US utility patents. These patents
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`deal with opto-electronics, integrated circuits, signal processing, and
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`telecommunications.
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`10. With regard to wireless charging and wireless communication
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`specifically, I have worked on a number of design projects at Rice in this field.
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`Many of them were year-long capstone design projects, where I was the technical
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`mentor on the project. I have worked on projects involving wireless power
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`delivery such as transcutaneous charging of biomedical implants, wirelessly
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`powering a CO2 sensor for the International Space Station, using RFID to track
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`bikers in a relay race, and treating cancer with microwave-absorbing implants. I
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`have also worked on projects with a significant charging, but not wireless, aspect
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`including charging cellphones with supercapacitors and with human-powered
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`generators, and harvesting energy from a shock absorber. I have supervised
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`numerous projects involving significant wireless networking aspects, including
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`antenna design, covering protocols including Bluetooth, WiFi, ZigBee, and
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`Bluetooth Low Energy.
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`11.
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`I have also supervised a number of capstone projects involving
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`significant wireless aspects, including wirelessly powering a multi-element
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`pacemaker; an 11 GHz real-time 4x4 imaging radar array; sending video over
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`cellphone links for ambulance telemedicine; ultra-low power wireless EEG
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`transmission; several off-grid internet-of-things (IOT) systems; and several
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`wirelessly transmitting medical devices.
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`12. Outside of capstone projects, I have been involved in research
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`activities related to the field of the alleged invention, including developing an
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`experimental setup with the highest magnetic field in Texas, developing a solar-
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`powered, IOT flood-sensor network for Houston, and developing a terahertz
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`generation and detection system.
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`13.
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`In my educational activities, I regularly teach a laboratory course that
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`includes a final project of building and testing a near-field communication system.
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`I have also developed educational demonstrations for classroom use involving
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`original “crystal” AM radios based on homemade cuprous-oxide rectifiers.
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`14.
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`In formulating my opinions, I have relied upon my training,
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`knowledge, and experience in the relevant art. A copy of my current curriculum
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`vitae is provided as Ex-1003, and it provides a comprehensive description of my
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`academic, employment, research, and professional history.
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`15. With my extensive experience in the field of wireless charging and
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`wireless communication systems, I am qualified to provide an opinion as to what a
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`person of ordinary skill in the art would have understood, known, or concluded as
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`of March 23, 2012. I have been asked to opine on the state of the art as of March
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`23, 2012, which I understand is the earliest claimed priority date of the ’740 Patent.
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`III. LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS
`16.
`In formulating my opinions, I have considered the following:
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`U.S. Patent No. 10,804,740 (Ex. 1001);
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`Prosecution History of U.S. Patent No. 10,804,740 (Ex. 1004);
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`U.S. Patent Publication No. 2008/0164840 to Kato et al. (“Kato”) (Ex.
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`1005);
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`U.S. Patent Publication No. 2009/0284341 to Okada et al. (“Okada”)
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`(Ex. 1006);
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`Certified English Translation of Japanese Patent Publication JP2011-
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`210937 to Goma et al. (“Goma”), Japanese Language Version of
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`JP2011-210937 and Translation Certificate. (Ex. 1008);
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`U.S. Patent No. 7,852,184 to Yamazaki et al. (“Yamazaki”) (Ex.
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`1009);
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`Prosecution History of U.S. Patent No. 10,277,071 (Ex. 1010);
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`Prosecution History of U.S. Patent No. 10,270,291 (Ex. 1011);
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`Prosecution History of U.S. Patent No. 9,806,565 (Ex. 1012); and
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`any other materials I refer to herein in support of my opinions.
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`IV. RELEVANT LEGAL STANDARDS
`17.
`I am not an attorney. For the purposes of this declaration, I have been
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`informed about certain aspects of the law that are relevant to my opinions. My
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`understanding of the law was provided to me by Petitioner’s attorneys. Counsel
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`has provided me with various legal standards that I understand apply to my
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`analysis.
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`A.
`18.
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`Prior Art and Anticipation
`I understand that the petitioner for inter partes review may request the
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`cancelation of one or more claims of a patent based on grounds available under 35
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`U.S.C. § 102 and 35 U.S.C. § 103 using prior art that consists of patents and
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`printed publications.
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`19.
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`I understand that § 102 specifies when a challenged claim is invalid
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`for lacking novelty over the prior art, and that this concept is also known as
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`“anticipation.” I understand that a prior art reference anticipates a challenged
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`claim, and thus renders it invalid by anticipation, if all elements of the challenged
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`claim are disclosed in the prior art reference. I understand the disclosure in the
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`prior art reference can be either explicit or inherent, meaning it is necessarily
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`present or implied. I understand that the prior art reference does not have to use
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`the same words as the challenged claim, but all of the requirements of the claim
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`must be disclosed so that a person of ordinary skill in the art could make and use
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`the claimed subject-matter.
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`20.
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`I understand that § 102 also defines what is available for use as a prior
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`art reference to a challenged claim. I understand that based on the filing date of the
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`earliest patent application to which the ’740 patent claims priority, the version of
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`§ 102 predating the America Invents Act (AIA) is being applied in this proceeding.
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`Under pre-AIA § 102(a), a challenged claim is anticipated if it known or used by
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`others in this country, or patented or described in a printed publication in this or a
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`foreign country, before the invention thereof by the applicant for patent. Under
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`pre-AIA § 102(b), I understand a challenged claim is anticipated if it was patented
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`or described in a printed publication in this or a foreign country or in public use or
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`on sale in this country, more than one year prior to the date of the application for
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`patent in the United States.
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`21.
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`I understand that the filing date of patent is generally the filing date of
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`the application filed in the United States that issued as the patent. However, I
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`understand that a patent may be granted an earlier effective filing date if the patent
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`owner properly claimed priority to an earlier patent application.
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`22.
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`I understand that when a challenged claim covers several structures,
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`either generically or as alternatives, the claim is deemed anticipated if any of the
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`structures within the scope of the claim is found in the prior art reference.
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`23.
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`I understand that when a challenged claim requires selection of an
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`element from a list of alternatives, the prior art teaches the element if one of the
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`alternatives is taught by the prior art.
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`B. Obviousness
`24.
`I understand that a claim is unpatentable if it would have been obvious
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`to a person of ordinary skill in the art at the time the alleged invention was made,
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`even if that claim is not anticipated. I understand that a claim could have been
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`obvious from a single prior art reference or from a combination of two or more
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`prior art references.
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`25.
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`I understand that an obviousness analysis requires an understanding of
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`the scope and content of the prior art, any differences between the alleged
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`invention and the prior art, and the level of ordinary skill in evaluating the
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`pertinent art.
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`26.
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`I further understand that certain factors may support or rebut the
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`obviousness of a claim. I understand that such secondary considerations include,
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`among other things, commercial success of the patented invention, skepticism of
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`those having ordinary skill in the art at the time of invention, unexpected results of
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`the invention, any long-felt but unsolved need in the art that was satisfied by the
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`alleged invention, the failure of others to make the alleged invention, praise of the
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`alleged invention by those having ordinary skill in the art, and copying of the
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`alleged invention by others in the field. I understand that there must be a nexus,
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`that is, a connection, between any such secondary considerations and the alleged
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`invention. I also understand that contemporaneous and independent invention by
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`others is a secondary consideration tending to show obviousness.
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`27.
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`I further understand that a claim would have been obvious if it unites
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`old elements with no change to their respective functions, or alters prior art by
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`mere substitution of one element for another known in the field, and that
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`combination yields predictable results. Also, I understand that obviousness does
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`not require physical combination/bodily incorporation, but rather consideration of
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`what the combined teachings would have suggested to persons of ordinary skill in
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`the art at the time of the alleged invention.
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`28. While it may be helpful to identify a reason for this combination, I
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`understand that there is no rigid requirement of finding an express teaching,
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`suggestion, or motivation to combine within the references. When a product is
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`available, design incentives and other market forces can prompt variations of it,
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`either in the same field or a different one. If a person of ordinary skill in the art
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`can implement a predictable variation, obviousness likely bars its patentability.
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`For the same reason, if a technique has been used to improve one device and a
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`person of ordinary skill in the art would recognize that it would improve similar
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`devices in the same way, using the technique would have been obvious. I
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`understand that a claim would have been obvious if a person of ordinary skill in the
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`art would have had reason to combine multiple prior art references or add missing
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`features to reproduce the alleged invention recited in the claims.
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`29.
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`I am not aware of any allegations by the named inventors of the ’740
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`Patent or any assignee of the ’740 Patent that any secondary considerations tend to
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`rebut the obviousness of any claim of the ’740 Patent discussed in this declaration.
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`30.
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`I understand that in considering obviousness, it is important not to
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`determine obviousness using the benefit of hindsight derived from the patent being
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`considered.
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`31. The analysis in this declaration is in accordance with the above-stated
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`legal principles.
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`C.
`32.
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`Claim Construction
`I understand that a patent may include two types of claims,
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`independent claims and dependent claims. I understand that an independent claim
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`stands alone and includes only the limitations it recites. I understand that a
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`dependent claim depends from an independent claim or another dependent claim. I
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`understand that a dependent claim includes all the limitations that it recites in
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`addition to the limitations recited in the claim (or claims) from which it depends.
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`33.
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`In comparing the challenged claims to the prior art, I have carefully
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`considered the patent and its file history in light of the understanding of a person of
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`skill at the time of the alleged invention.
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`34.
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`I understand that to determine how a person of ordinary skill would
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`have understood a claim term, one should look to sources available at the time of
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`the alleged invention that show what a person of skill in the art would have
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`understood disputed claim language to mean. It is my understanding that this may
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`include what is called “intrinsic” evidence as well as “extrinsic” evidence.
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`35.
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`I understand that, in construing a claim term, one should primarily
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`rely on intrinsic patent evidence, which includes the words of the claims
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`themselves, the remainder of the patent specification, and the prosecution history.
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`I understand that extrinsic evidence, which is evidence external to the patent and
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`the prosecution history, may also be useful in interpreting patent claims when the
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`intrinsic evidence itself is insufficient. I understand that extrinsic evidence may
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`include principles, concepts, terms, and other resources available to those of skill
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`in the art at the time of the invention.
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`36.
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`I understand that words or terms should be given their ordinary and
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`accepted meaning unless it appears that the inventors were using them to mean
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`something else or something more specific. I understand that to determine whether
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`a term has special meaning, the claims, the patent specification, and the
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`prosecution history are particularly important, and may show that the inventor gave
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`a term a particular definition or intentionally disclaimed, disavowed, or
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`surrendered claim scope.
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`37.
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`I understand that the claims of a patent define the scope of the rights
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`conferred by the patent. I understand that because the claims point out and
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`distinctly claim the subject matter which the inventors regard as their invention,
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`claim construction analysis must begin with and is focused on the claim language
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`itself. I understand that the context of the term within the claim as well as other
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`claims of the patent can inform the meaning of a claim term. For example, because
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`claim terms are normally used consistently throughout the patent, how a term is
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`used in one claim can often inform the meaning of the same term in other claims.
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`Differences among claims or claim terms can also be a useful guide in
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`understanding the meaning of particular claim terms.
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`38.
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`I understand that a claim term should be construed not only in the
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`context of the particular claim in which the disputed term appears, but in the
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`context of the entire patent, including the entire specification. I understand that
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`because the specification is a primary basis for construing the claims, a correct
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`construction must align with the specification.
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`39.
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`I understand that the prosecution history of the patent as well as art
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`incorporated by reference or otherwise cited during the prosecution history are also
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`highly relevant in construing claim terms. For instance, art cited by or
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`incorporated by reference may indicate how the inventor and others of skill in the
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`art at the time of the invention understood certain terms and concepts.
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`Additionally, the prosecution history may show that the inventors disclaimed or
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`disavowed claim scope, or further explained the meaning of a claim term.
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`40. With regard to extrinsic evidence, I understand that all evidence
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`external to the patent and prosecution history, including expert and inventor
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`testimony, dictionaries, and learned treatises, can also be considered. For example,
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`technical dictionaries may indicate how one of skill in the art used or understood
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`the claim terms. However, I understand that extrinsic evidence is considered to be
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`less reliable than intrinsic evidence, and for that reason is generally given less
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`weight than intrinsic evidence.
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`41.
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`I understand that in general, a term or phrase found in the introductory
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`words or preamble of the claim, should be construed as a limitation if it recites
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`essential structure or steps, or is necessary to give meaning to the claim. For
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`instance, I understand preamble language may limit claim scope: (i) if dependence
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`on a preamble phrase for antecedent basis indicates a reliance on both the preamble
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`and claim body to define the claimed invention; (ii) if reference to the preamble is
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`necessary to understand limitations or terms in the claim body; or (iii) if the
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`preamble recites additional structure or steps that the specification identifies as
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`important.
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`42. On the other hand, I understand that a preamble term or phrase is not
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`limiting where a challenged claim defines a structurally complete invention in the
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`claim body and uses the preamble only to state a purpose or intended use for the
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`invention. I understand that to make this determination, one should review the
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`entire patent to gain an understanding of what the inventors claim they invented
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`and intended to encompass in the claims.
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`43.
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`I understand that 35 U.S.C. § 112 ¶ 6 created an exception to the
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`general rule of claim construction called a “means plus function” limitation. These
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`types of terms and limitations should be interpreted to cover only the
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`corresponding structure described in the specification, and equivalents thereof. I
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`also understand that a limitation is presumed to be a means plus function limitation
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`if (a) the claim limitation uses the phrase “means for”; (b) the “means for” is
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`modified by functional language; and (c) the phrase “means for” is not modified by
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`sufficient structure for achieving the specified function.
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`44.
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`I understand that a structure is considered structurally equivalent to
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`the corresponding structure identified in the specification only if the difference
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`between them are insubstantial. For instance, if the structure performs the same
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`function in substantially the same way to achieve substantially the same result. I
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`further understand that a structural equivalent must have been available at the time
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`of the issuance of the claim.
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`V.
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`PERSON OF ORDINARY SKILL IN THE ART
`45.
`I understand that factors that may be considered in establishing the
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`level of ordinary skill in the art relevant to the patent-in-suit include the type of
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`problems encountered in the art, prior art solutions to those problems, rapidity with
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`which innovations are made, sophistication of the technology, and educational
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`level of active workers in the field.
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`46.
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`I understand that a person of ordinary skill in the art (“POSITA”) is
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`one who is presumed to be aware of all pertinent art, thinks along conventional
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`wisdom in the art, and is a person of ordinary creativity. A POSITA would have
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`had knowledge of wireless charging systems and related technologies as of March
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`23, 2012.
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`47. A POSITA would have had a bachelor’s degree in electrical
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`engineering, computer engineering, applied physics, or a related field, and at least
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`one year of experience in the research, design, development, and/or testing of
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`wireless charging systems, or the equivalent, with additional education substituting
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`for experience and vice versa.
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`48. Based on my education and experience, I would have easily exceeded
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`the criteria for a POSITA in March 23, 2012, and I still exceed it today.
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`VI. OVERVIEW OF THE ’740 PATENT
`49. The ’740 patent is entitled “Wireless Power Receiver and Method of
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`Manufacturing the Same” and “relates to a wireless power receiver used for
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`wireless power transmission or an antenna to reduce a thickness of the wireless
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`power receiver and to simplify the manufacturing process thereof and a method of
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`manufacturing the same.” Ex-1001, Title, 1:23-27. The ’740 patent purports to
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`reduce thickness of a wireless power receiver “by directly disposing a coil unit on
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`a top surface of a magnetic substrate.” Id., 1:54-56. In some embodiments, an
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`adhesive layer is between the coil unit and the magnetic substrate. Id., 7:36-38.
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`50. The ’740 patent further discloses that connections to the coil on the
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`magnetic substrate can be established using a “connecting unit” that can be, for
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`example, a “flexible printed circuit board,” “tape substrate,” or a “lead frame.” Id.,
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`2:22-24, 2:54-58, 16:14-19. Annotated figure 11 of the ’740 patent below shows
`
`16
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`the coil 200 formed on the magnetic substrate 100, where the connecting unit 300
`
`has a shape corresponding to the receiving space 130 and is disposed in the
`
`receiving space to reduce thickness of the wireless power receiver. Id., 8:19-39,
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`16:4-13, FIG. 11.
`
`
`
`Id., FIG. 11 (annotated).
`
`51. The coil 200 includes a first connection terminal 210 and a second
`
`connection terminal 220 that are connected to the first and second connection
`
`terminals 310 and 320 of the connecting unit, respectively. Id., 9:3-8.
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`
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`17
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`52. As explained in detail below, the ’740 Patent claims are disclosed or
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`
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`suggested in view of the prior art.
`
`VII. PROSECUTION HISTORY OF THE ’740 PATENT
`53.
`I understand the application leading to the ’740 Patent, U.S.
`
`Application No. 16/264,360 (“the ’360 application), was filed on January 31, 2019,
`
`and is a continuation of U.S. App. No. 15/430,173 (Ex. 1010) (now U.S. Patent
`
`No. 10,277,071), filed February 10, 2017, which is a continuation of U.S. Patent
`
`App. No. 15/360,425 (Ex. 1011) (now U.S. Patent No. 10,270,291), filed
`
`November 23, 2016, which is a continuation of U.S. Patent App. No. 13/663,012
`
`(Ex. 1012) (now U.S. Patent No. 9,806,565), filed October 29, 2012. The ’740
`
`patent also claims priority to Korean Patent Applications 10-2012-0029987 and
`
`10-2012-0079004, filed March 23, 2012, and July 19, 2012, respectively.
`
`54. During prosecution of the ’360 application, on March 14, 2019, the
`
`applicant filed a preliminary amendment amending three of the dependent claims
`
`(Ex-1004, 250-255), but then on May 10, 2019, the applicant cancelled then-
`
`pending claims 1-20 and submitted new claims 21-40 (id., 139-150). On June 24,
`
`2020, without issuing any substantive office action or rejection of any of the
`
`pending claims, the examiner allowed all of claims 21-40, indicating the reasons
`
`for allowance were that “the prior art of record does not disclose or suggest a
`
`18
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`wireless power receiver, comprising, inter alia, a connecting unit as claimed.” Id.,
`
`22-28.
`
`VIII. PRIORITY DATE OF THE ’740 PATENT
`55.
`I have been asked to assume that the earliest date to which the ’740
`
`Patent is entitled to priority is March 23, 2012. Thus, for the purposes of this
`
`Declaration, I have assumed the priority date of the ’740 Patent is March 23, 2012.
`
`IX. CLAIM CONSTRUCTION
`56.
`I do not believe that any term requires explicit construction to resolve
`
`the issues presented in this Petition. However, I have been informed that, in
`
`district court, Patent Owner argues that the “receiving space” terms in claims 1 and
`
`6 can be a space that is meant to receive the connecting unit in some fashion, e.g.,
`
`the connecting unit can be positioned with, overlap, or be disposed in the receiving
`
`space. I have also been informed that, in district court, Patent Owner alleges that a
`
`space in a magnetic sheet or adhesive where electrical contact is made to a coil
`
`constitutes the “receiving space” as recited in claims 1 and 6. I have been asked to
`
`apply Patent Owner’s interpretation of the “receiving space” terms recited in
`
`claims 1 and 6 in my analysis herein.
`
`57. For all other terms, I ascribe the plain meaning, as that plain meaning
`
`would have been understood by a POSITA.
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`58.
`
`I reserve the right to offer opinions on any claim constructions
`
`
`
`proposed in this proceeding or to offer opinions on additional constructions in the
`
`district court.
`
`X. GROUNDS FOR FINDING THE CHALLENGED CLAIMS INVALID
`59.
`I understand that Petitioner requests cancellation of Claims 1-10 of the
`
`’740 Patent.
`
`A. Overview of the Prior Art References
`1.
`Overview of Kato (Ex-1005)
`60. Kato, titled “Noncontact Power-Transmission Coil, Portable
`
`Terminal, and Terminal Charging Device,” is U.S. Patent Publication No.
`
`2008/0164840, published on July 10, 2008. Ex-1005 at Cover. I have been
`
`informed that Kato qualifies as prior art under at least pre-AIA 35 U.S.C. § 102(b),
`
`based on its publication date.
`
`61. Kato discloses “a noncontact power-transmission coil for use in power
`
`transmission in a noncontact manner using electromagnetic induction.” Ex-1005,
`
`Title, [0003]. Figure 3 of Kato shows a cradle 1 that includes a primary power-
`
`transmission coil 10 for transmitting power (transmitter coil) to a secondary power-
`
`transmission coil 21 for receiving power (receiver coil) included in a mobile phone
`
`unit 2. Id., [0049], FIG. 3.
`
`20
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`Id., FIG. 3 (annotated).
`
`62. Kato discloses that the secondary power transmission coil 21 receives
`
`power that is used to charge the battery 22 on the mobile phone 2. Id., [0049].
`
`Figures 17-20 of Kato show one embodiment of a power transmission coil 21WD
`
`that can be used for reception of power in a mobile phone like that illustrated in
`
`figure 3 above. Id., [0062], [0080], FIG. 17. As shown in annotated figure 17
`
`below, the power transmission coil includes a coil 40 on the surface of a flexible
`
`printed-circuit board 90 that includes connection terminals 31 and 32 and
`
`conductors 33 and 34 that provide electrical connections between the different
`
`components of the printed-circuit board. Id., [0081]-[0083], FIG. 17.
`
`21
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`Ex-1005, FIG. 17 (annotated).
`
`63. Annotated figure 19 below “is a schematic cross-sectional view of the
`
`noncontact power-transmission coil, where a magnetic layer is formed on both the
`
`flat surface and an outer periphery side portion of the planer coil shown in FIG.
`
`17.” Id., [0035].
`
`22
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`Id., FIG. 19 (annotated).
`
`2.
`Overview of Okada (Ex-1006)
`64. Okada, titled “Coil Unit and Electronic Apparatus Using the Same,” is
`
`U.S. Patent Publication No. 2009/0284341, which published November 19, 2009.
`
`Ex-1006 at Cover. I have been informed that Okada qualifies as prior art under at
`
`least pre-AIA 35 U.S.C. §102(b), based on its publication date.
`
`65. Okada is directed to a coil unit 20 that is included in a cell phone,
`
`where “[t]he cell phone 20 is charged by the charger 10 by means of contactless
`
`power transmission using an electromagnetic induction action generated between a
`
`coil of a coil unit 12 of the charger 10 and a coil of a coil unit 22 of the cell phone
`
`20.” Ex-1006, [0040], [0044], FIG. 1.
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`23
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`Ex-1006, FIG. 1 (annotated).
`
`66. Okada discloses that “power is transmitted from the charger 10 to the
`
`cell phone 20 by electromagnetically coupling a primary coil L1 (power
`
`transmission
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