UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`GOOGLE LLC, SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.
`Patent Owner
`
`Patent No. 10,193,392
`
`______________________________________________
`
`DECLARATION OF DR. GARY WOODS
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`GOOGLE AND SAMSUNG EXHIBIT 1002
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`Inter Partes Review of U.S. Patent No. 10,193,392
`Declaration of Gary Woods
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`TABLE OF CONTENTS
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`I.
`INTRODUCTION ............................................................................... 1
`II. My background and qualifications ........................................................ 2
`III. List of Documents Considered in Formulating My Opinions ..................... 5
`IV. Relevant Legal Standards .................................................................... 6
`A.
`Prior Art and Anticipation .......................................................... 6
`B. Obviousness .............................................................................. 8
`C.
`Claim Construction .................................................................. 10
`PERSON OF ORDINARY SKILL IN THE ART ..................................... 15
`V.
`VI. OVERVIEW OF THE ’392 PATENT ................................................... 16
`VII. PROSECUTION HISTORY OF THE ’392 PATENT .............................. 20
`VIII. Priority Date Of The ’392 Patent ........................................................ 22
`IX. CLAIM CONSTRUCTION ................................................................. 22
`X. GROUNDS FOR FINDING THE CHALLENGED CLAIMS INVALID ..... 22
`A. Overview of the Prior Art References ......................................... 22
`1.
`Overview of Sadakata (Ex-1005)....................................... 22
`2.
`Overview of Schulman (Ex-1006) ...................................... 26
`B. Ground 1: Claims 1, 2, and 5-8 are disclosed by Sadakata ............ 28
`1.
`Claim 1 ......................................................................... 28
`2.
`Claim 2 ......................................................................... 58
`Claim 5 ......................................................................... 61
`3.
`4.
`Claim 6 ......................................................................... 64
`5.
`Claim 7 ......................................................................... 68
`6.
`Claim 8 ......................................................................... 71
`C. Ground 2: Claims 1, 2, and 5-8 Are Disclosed or Suggested by
`Sadakata................................................................................. 73
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`D. Ground 3: Claims 1, 2, and 5-8 Are Disclosed or Suggested by
`Sadakata in View of Schulman ................................................... 77
`XI. CONCLUSION ................................................................................. 81
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`Inter Partes Review of U.S. Patent No. 10,193,392
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`I, Gary Woods, hereby declare as follows:
`
`I.
`
`INTRODUCTION
`I have been retained as an expert witness on behalf of Google LLC,
`1.
`
`Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
`
`(“Petitioner”) for the above-captioned inter partes review (IPR). I understand that
`
`Petitioner challenges the validity of Claims 1, 2, and 5-8 of U.S. Patent No.
`
`10,193,392.
`
`2.
`
`I am over the age of eighteen (18) and otherwise competent to make
`
`this declaration. I am being compensated for my time in connection with this IPR
`
`at my standard consulting rate.
`
`3.
`
`I understand that the petition for inter partes review involves U.S.
`
`Patent No. 10,193,392 (the “’392 Patent”), Ex-10011, which resulted from U.S.
`
`Application No. 15/110,665 (“the ’665 application”). The ’665 Application was
`
`filed on July 8, 2016 as a national stage application of PCT KR2015/00163, filed
`
`January 7, 2015. The ’392 Patent also claims priority to Korean Patent Applications
`
`10-2014-0002327 and 10-2014-0009243, filed January 8, 2014, and January 24,
`
`
`1 All exhibit citations refer to the exhibits attached to the Petition for Inter Partes
`
`Review of U.S. Patent No. 10,193,392, filed concurrently herewith.
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`2014, respectively. The ’392 Patent names Su Ho Bae as the inventor and issued on
`
`January 29, 2019, from the ’665 application. See Ex-1001 at Cover. I further
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`understand that, according to USPTO records, the ’392 Patent is currently assigned
`
`to Scramoge Technology Limited (“Patent Owner” or “Scramoge”).
`
`4.
`
`I have been asked to assume that the earliest date to which the ’392
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`Patent is entitled to priority is January 8, 2014.
`
`5.
`
`In preparing this Declaration, I have reviewed the ’392 Patent and
`
`considered each of the documents cited herein, in light of general knowledge in the
`
`art. In formulating my opinions, I have relied upon my experience in the relevant
`
`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 January 8, 2014, the
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`earliest claimed priority date of the ’392 Patent. I am also familiar with a person of
`
`ordinary skill in the art with respect to the technology at issue as of the January 8,
`
`2014 earliest claimed priority date of the ’392 Patent.
`
`II. MY BACKGROUND AND QUALIFICATIONS
`Since 2008, I have been employed as a Professor in the Practice in the
`7.
`
`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. Before
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`that, I worked as a postdoctoral fellow at the University of California, Santa Barbara
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`(1996-1998); at Intel Corporation (1998-2000); at Spectralane Inc. (2000-2002); at
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`Optonics (later Credence Systems Corp.) (2003-2006); and as an independent
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`consultant (2006-present). In the summers of 1988 and 1989 I worked at Texas
`
`Instruments.
`
`8. My educational background includes undergraduate degrees in Physics
`
`and Electrical Engineering from Rice University in 1988 and an MS (1991) and
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`Ph.D. (1997) in Applied Physics from Stanford University.
`
`9.
`
`I am familiar with patents both as an inventor and as chief technology
`
`officer in charge of the patent portfolio of a company I co-founded, Spectralane. I
`
`am an inventor on 16 issued and one pending US utility patents. These patents deal
`
`with
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`otpo-electronics,
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`integrated
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`circuits,
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`signal
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`processing,
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`and
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`telecommunications.
`
`10. With regard to wireless charging and wireless communication
`
`specifically, I have worked on a number of design projects at Rice in this field. Many
`
`of them were year-long capstone design projects, where I was the technical mentor
`
`on the project. I have worked on projects involving wireless power delivery such as
`
`transcutaneous charging of biomedical implants, wirelessly powering a CO2 sensor
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`for the International Space Station, using RFID to track bikers in a relay race, and
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`treating cancer with microwave-absorbing implants. Projects with a significant
`
`
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`3
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`charging but not wireless aspect include charging cellphones with supercapacitors
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`and with human-powered generators, and harvesting energy from a shock absorber.
`
`I have supervised numerous projects involving significant wireless networking
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`aspects, including antenna design, covering protocols including Bluetooth, WiFi,
`
`ZigBee, and Bluetooth Low Energy.
`
`11.
`
`I have supervised a number of capstone projects involving significant
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`wireless aspects, including wirelessly powering a multi-element pacemaker; an 11
`
`GHz real-time 4x4 imaging radar array; sending video over cellphone links for
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`ambulance telemedicine; ultra-low power wireless EEG transmission; several off-
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`grid internet-of-things (IOT) systems; and several wirelessly transmitting medical
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`devices.
`
`12. Outside of capstone projects, I have been involved in research activities
`
`related to this case including developing an experimental setup with the highest
`
`magnetic field in Texas, developing a solar-powered, IOT flood-sensor network for
`
`Houston, and developing a terahertz generation and detection system.
`
`13.
`
`In my educational activities, I regularly teach a laboratory course that
`
`includes a final project of building and testing a near-field communication system. I
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`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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`In formulating my opinions, I have relied upon my training, knowledge,
`
`14.
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`and experience in the relevant art. A copy of my current curriculum vitae is provided
`
`as Ex-1003, and it provides a comprehensive description of my academic,
`
`employment, research, and professional history.
`
`15. With my extensive experience in the field of wireless charging and
`
`wireless communication systems, I am qualified to provide an opinion as to what a
`
`person of ordinary skill in the art would have understood, known, or concluded as
`
`of March 4, 2014. I have been asked to opine on the state of the art as of March 4,
`
`2014, which I understand is the earliest claimed priority date of the ’392 Patent.
`
`III. LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS
`In formulating my opinions, I have considered the following:
`16.
`
`• U.S. Patent No. 10,193,392 (Ex-1001);
`
`• Prosecution History of U.S. Patent No. 10,193,392 (Ex-1004);
`
`• U.S. Patent No. 9,660,514 to Sadakata et al. (“Sadakata”) (Ex-1005);
`
`• U.S. Patent No. 3.942,535 to Schulman (“Schulman”) (Ex-1006); and
`
`• The translation of PCT application PCT Application JP/2013/001540 (Ex-
`
`1007).
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`5
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`IV. RELEVANT LEGAL STANDARDS
`I am not an attorney. For the purposes of this declaration, I have been
`17.
`
`informed about certain aspects of the law that are relevant to my opinions. My
`
`understanding of the law was provided to me by Petitioner’s attorneys. Counsel has
`
`provided me with various legal standards that I understand apply to my analysis.
`
`A.
`18.
`
`Prior Art and Anticipation
`I understand that the petitioner for inter partes review may request the
`
`cancelation of one or more claims of a patent based on grounds available under 35
`
`U.S.C. § 102 and 35 U.S.C. § 103 using prior art that consists of patents and printed
`
`publications.
`
`19.
`
`I understand that § 102 specifies when a challenged claim is invalid for
`
`lacking novelty over the prior art, and that this concept is also known as
`
`“anticipation.” I understand that a prior art reference anticipates a challenged claim,
`
`and thus renders it invalid by anticipation, if all elements of the challenged claim are
`
`disclosed in the prior art reference. I understand the disclosure in the prior art
`
`reference can be either explicit or inherent, meaning it is necessarily present or
`
`implied. I understand that the prior art reference does not have to use the same words
`
`as the challenged claim, but all of the requirements of the claim must be disclosed
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`so that a person of ordinary skill in the art could make and use the claimed subject-
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`matter.
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`20.
`
`I understand that § 102 also defines what is available for use as a prior
`
`art reference to a challenged claim. Under § 102(a)(1), a challenged claim is
`
`anticipated if it was patented, described in a printed publication, or in public use, on
`
`sale, or otherwise available to the public before the effective filing date of the
`
`claimed invention. Under § 102(a)(2), I understand a challenged claim is anticipated
`
`if it was described in a patent issued under section 151, or in an application for patent
`
`published or deemed published under section 122(b), in which the patent or
`
`application, as the case may be, names another inventor and was effectively filed
`
`before the effective filing date of the claimed invention.
`
`21.
`
`I understand that a challenged claim’s date of invention is presumed to
`
`be the challenged patent’s filing date.
`
`22.
`
`I understand that the filing date of patent is generally the filing date of
`
`the application filed in the United States that issued as the patent. However, I
`
`understand that a patent may be granted an earlier effective filing date if the patent
`
`owner properly claimed priority to an earlier patent application.
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`I understand that when a challenged claim covers several structures,
`
`23.
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`either generically or as alternatives, the claim is deemed anticipated if any of the
`
`structures within the scope of the claim is found in the prior art reference.
`
`24.
`
`I understand that when a challenged claim requires selection of an
`
`element from a list of alternatives, the prior art teaches the element if one of the
`
`alternatives is taught by the prior art.
`
`B. Obviousness
`I understand that a claim is unpatentable if it would have been obvious
`25.
`
`to a person of ordinary skill in the art at the time the alleged invention was made,
`
`even if that claim is not anticipated. I understand that a claim could have been
`
`obvious from a single prior art reference or from a combination of two or more prior
`
`art references.
`
`26.
`
`I understand that an obviousness analysis requires an understanding of
`
`the scope and content of the prior art, any differences between the alleged invention
`
`and the prior art, and the level of ordinary skill in evaluating the pertinent art.
`
`27.
`
`I further understand that certain factors may support or rebut the
`
`obviousness of a claim. I understand that such secondary considerations include,
`
`among other things, commercial success of the patented invention, skepticism of
`
`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
`
`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 alleged
`
`invention by others in the field. I understand that there must be a nexus, that is, a
`
`connection, between any such secondary considerations and the alleged invention. I
`
`also understand that contemporaneous and independent invention by others is a
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`secondary consideration tending to show obviousness.
`
`28.
`
`I further understand that a claim would have been obvious if it unites
`
`old elements with no change to their respective functions, or alters prior art by mere
`
`substitution of one element for another known in the field, and that combination
`
`yields predictable results. Also, I understand that obviousness does not require
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`physical combination/bodily incorporation, but rather consideration of what the
`
`combined teachings would have suggested to persons of ordinary skill in the art at
`
`the time of the alleged invention.
`
`29. While it may be helpful to identify a reason for this combination, I
`
`understand that there is no rigid requirement of finding an express teaching,
`
`suggestion, or motivation to combine within the references. When a product is
`
`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 can
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`implement a predictable variation, obviousness likely bars its patentability. For the
`
`same reason, if a technique has been used to improve one device and a person of
`
`ordinary skill in the art would recognize that it would improve similar devices in the
`
`same way, using the technique would have been obvious. I understand that a claim
`
`would have been obvious if a person of ordinary skill in the art would have had
`
`reason to combine multiple prior art references or add missing features to reproduce
`
`the alleged invention recited in the claim.
`
`30.
`
`I am not aware of any allegations by the named inventors of the ’392
`
`Patent or any assignee of the ’392 Patent that any secondary considerations tend to
`
`rebut the obviousness of any claim of the ’392 Patent discussed in this declaration.
`
`31.
`
`I understand that in considering obviousness, it is important not to
`
`determine obviousness using the benefit of hindsight derived from the patent being
`
`considered.
`
`32. The analysis in this declaration is in accordance with the above-stated
`
`legal principles.
`
`C. Claim Construction
`I understand that a patent may include two types of claims, independent
`33.
`
`claims and dependent claims. I understand that an independent claim stands alone
`
`and includes only the limitations it recites. I understand that a dependent claim
`
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`depends from an independent claim or another dependent claim. I understand that a
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`dependent claim includes all the limitations that it recites in addition to the
`
`limitations recited in the claim (or claims) from which it depends.
`
`34.
`
`In comparing the challenged claims to the prior art, I have carefully
`
`considered the patent and its file history in light of the understanding of a person of
`
`skill at the time of the alleged invention.
`
`35.
`
`I understand that to determine how a person of ordinary skill would
`
`have understood a claim term, one should look to sources available at the time of the
`
`alleged invention that show what a person of skill in the art would have understood
`
`disputed claim language to mean. It is my understanding that this may include what
`
`is called “intrinsic” evidence as well as “extrinsic” evidence.
`
`36.
`
`I understand that, in construing a claim term, one should primarily rely
`
`on intrinsic patent evidence, which includes the words of the claims themselves, the
`
`remainder of the patent specification, and the prosecution history. I understand that
`
`extrinsic evidence, which is evidence external to the patent and the prosecution
`
`history, may also be useful in interpreting patent claims when the intrinsic evidence
`
`itself is insufficient. I understand that extrinsic evidence may include principles,
`
`concepts, terms, and other resources available to those of skill in the art at the time
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`of the invention.
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`I understand that words or terms should be given their ordinary and
`
`37.
`
`accepted meaning unless it appears that the inventors were using them to mean
`
`something else or something more specific. I understand that to determine whether
`
`a term has special meaning, the claims, the patent specification, and the prosecution
`
`history are particularly important, and may show that the inventor gave a term a
`
`particular definition or intentionally disclaimed, disavowed, or surrendered claim
`
`scope.
`
`38.
`
`I understand that the claims of a patent define the scope of the rights
`
`conferred by the patent. I understand that because the claims point out and distinctly
`
`claim the subject matter which the inventors regard as their invention, claim
`
`construction analysis must begin with and is focused on the claim language itself. I
`
`understand that the context of the term within the claim as well as other claims of
`
`the patent can inform the meaning of a claim term. For example, because claim terms
`
`are normally used consistently throughout the patent, how a term is used in one claim
`
`can often inform the meaning of the same term in other claims. Differences among
`
`claims or claim terms can also be a useful guide in understanding the meaning of
`
`particular claim terms.
`
`39.
`
`I understand that a claim term should be construed not only in the
`
`context of the particular claim in which the disputed term appears, but in the context
`
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`of the entire patent, including the entire specification. I understand that because the
`
`specification is a primary basis for construing the claims, a correct construction must
`
`align with the specification.
`
`40.
`
`I understand that the prosecution history of the patent as well as art
`
`incorporated by reference or otherwise cited during the prosecution history are also
`
`highly relevant in construing claim terms. For instance, art cited by or incorporated
`
`by reference may indicate how the inventor and others of skill in the art at the time
`
`of the invention understood certain terms and concepts. Additionally,
`
`the
`
`prosecution history may show that the inventors disclaimed or disavowed claim
`
`scope, or further explained the meaning of a claim term.
`
`41. With regard to extrinsic evidence, I understand that all evidence
`
`external to the patent and prosecution history, including expert and inventor
`
`testimony, dictionaries, and learned treatises, can also be considered. For example,
`
`technical dictionaries may indicate how one of skill in the art used or understood the
`
`claim terms. However, I understand that extrinsic evidence is considered to be less
`
`reliable than intrinsic evidence, and for that reason is generally given less weight
`
`than intrinsic evidence.
`
`42.
`
`I understand that in general, a term or phrase found in the introductory
`
`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 instance,
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`I understand preamble language may limit claim scope: (i) if dependence on a
`
`preamble phrase for antecedent basis indicates a reliance on both the preamble and
`
`claim body to define the claimed invention; (ii) if reference to the preamble is
`
`necessary to understand limitations or terms in the claim body; or (iii) if the preamble
`
`recites additional structure or steps that the specification identifies as important.
`
`43. On the other hand, I understand that a preamble term or phrase is not
`
`limiting where a challenged claim defines a structurally complete invention in the
`
`claim body and uses the preamble only to state a purpose or intended use for the
`
`invention. I understand that to make this determination, one should review the entire
`
`patent to gain an understanding of what the inventors claim they invented and
`
`intended to encompass in the claims.
`
`44.
`
`I understand that 35 U.S.C. § 112 ¶ 6 created an exception to the general
`
`rule of claim construction called a “means plus function” limitation. These types of
`
`terms and limitations should be interpreted to cover only the corresponding structure
`
`described in the specification, and equivalents thereof. I also understand that a
`
`limitation is presumed to be a means plus function limitation if (a) the claim
`
`limitation uses the phrase “means for”; (b) the “means for” is modified by functional
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`language; and (c) the phrase “means for” is not modified by sufficient structure for
`
`achieving the specified function.
`
`45.
`
`I understand that a structure is considered structurally equivalent to the
`
`corresponding structure identified in the specification only if the difference between
`
`them are insubstantial. For instance, if the structure performs the same function in
`
`substantially the same way to achieve substantially the same result. I further
`
`understand that a structural equivalent must have been available at the time of the
`
`issuance of the claim.
`
`V.
`
`PERSON OF ORDINARY SKILL IN THE ART
`
`46.
`
`I understand that factors that may be considered in establishing the level
`
`of ordinary skill in the art relevant to the patent-in-suit include the type of problems
`
`encountered in the art, prior art solutions to those problems, rapidity with which
`
`innovations are made, sophistication of the technology, and educational level of
`
`active workers in the field.
`
`47.
`
`I understand that a person of ordinary skill in the art (“POSITA”) is one
`
`who is presumed to be aware of all pertinent art, thinks along conventional wisdom
`
`in the art, and is a person of ordinary creativity. A POSITA would have had
`
`knowledge of wireless charging systems and related technologies as of January 8,
`
`2014.
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`48. One of ordinary skill in the art would have had a bachelor’s degree in
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`electrical engineering, computer engineering, applied physics, or a related field, and
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`at least one year of experience in the research, design, development, and/or testing
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`of wireless charging systems, or the equivalent, with additional education
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`substituting for experience and vice versa.
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`49. Based on my education and experience, I would have easily exceeded
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`the criteria for a POSITA in January 8, 2014, and I still exceed it today.
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`VI. OVERVIEW OF THE ’392 PATENT
`50. The ’392 Patent, entitled “Wireless Power Transfer Device and
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`Wireless Power Transfer System,” is directed to a “wireless power transfer device
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`that is capable of minimizing current wasted or consumed and enhancing a wireless
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`power transfer efficiency.” Ex-1001 at Title, 2:39-41. The ’392 Patent discloses a
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`wireless transfer system that includes a wireless power transfer device 100 and a
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`wireless receiving device 200. Id. at 6:22-26. Annotated figure 6 of the ’392 patent
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`below shows one embodiment of a wireless power transfer device 100 that includes
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`antenna system 102, rectifying and filtering part 110, converter 120, power
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`converting part 130, control part 140 and matching part 150. Id. at 9:62-10:2.
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`Ex-1001 at FIG. 6 (annotated).
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`51. As disclosed by the ’392 patent, the rectifying and filtering part 110
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`generates a DC voltage that is provided to the converter 120, where the DC voltage
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`may be converted to a different DC voltage by the converter 120. Ex-1001 at 10:3-
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`19. The power conversion part 130 converts the DC voltage from the converter 120
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`into an AC voltage, whereas the “matching part 150 performs an impedance
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`matching between the transmitting part 100 and the receiving part 200.” Id. at 10:19-
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`21, 10:42-43. As shown in annotated figure 8 below, the power conversion part 130
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`is configured as a full bridge inverter, where the control part 140 generates switching
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`waveforms (AC power control signals) that drive the power conversion part 130. Id.
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`at 10:36-39.
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`Ex-1001 at FIG. 8 (annotated).
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`52. The power conversion part 130 shown above in annotated figure 8
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`above includes first to fourth switching elements S1, S2, S3, and S4 that are
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`controlled by the first to fourth AC power control signals C11, C12, C21, and C22,
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`respectively, which are provided by the control part 140. Ex-1001 at 12:19-24. As
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`disclosed by the ’392 Patent, each of the switching elements conducts (i.e., current
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`flows through it) when its respective AC power control signal is “high” and is open
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`(i.e., current does not flow through it) when its respective AC power control signal
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`is “low.” Id. Figure 12 below illustrates a waveform diagram showing the assertion
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`and deassertion of the power control signals C11, C12, C21, and C22 in conjunction
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`with an embodiment where the duty ratio of the produced AC voltage is controlled
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`by controlling a blank interval. Id. at 13:28-44.
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`Ex-1001 at FIG. 12 (annotated).
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`53.
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` As can be seen in annotated figure 12 above, the output voltage Vo
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`from the power conversion part 130 is positive when both the first and fourth AC
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`power control signals are “high,” and the output voltage Vo is negative when both
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`the second and third AC power control signals are “high.” Ex-1001 at 12:61-13:8.
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`54. The ’392 patent describes the “duty ratio” of a signal as follows:
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`Meanwhile, an [sic] high level overlapping interval of the
`first and fourth AC power control signals C11 and C22 is
`a power transfer interval, which may be defined as a duty
`ratio (Ton). The duty ratio (Ton) is an interval where a
`power may be transferred for a cycle, the maximum being
`set 50%, which is not limited thereto. For example, when
`a duty ratio is 50%, power can be transferred in a half cycle
`and cannot be transferred in the [remaining] half cycle.
`Further, an overlapped high level interval of the second
`and third AC power control signals C12 and C21 is a
`power transfer available interval, which may be defined as
`a duty ratio (Ton).
`Ex-1001 at 14:65-15:8.
`55. As explained in detail below, the ’392 Patent claims are disclosed or
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`suggested in view of the prior art.
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`VII. PROSECUTION HISTORY OF THE ’392 PATENT
`I understand the application leading to the ’392 Patent, U.S. Patent
`56.
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`Application No. 15/110,665, was filed on July 8, 2016 as the national stage
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`application of PCT KR2015/00163, filed January 7, 2015. The ’392 patent also
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`claims priority to Korean Patent Applications 10-2014-0002327 and 10-2014-
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`0009243, filed January 8, 2014, and January 24, 2014, respectively.
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`57. On August July 8, 2016, Applicant filed a preliminary amendment to
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`correct typographical errors in the specification and insert priority information into
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`the specification. Ex-1004 at 442-445. On December 28, 2017, the Examiner issued
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`a restriction requirement restricting then-pending claims 1-18 into two groups. Ex-
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`1004 at 198-206. In its Response, Applicant canceled Group I claims 1-11, amended
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`independent claim 12 and dependent claims 13, 17 and 18, and added new claims 19
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`and 20. Id. at 189-194.
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`58. On April 5, 2019, the Examiner issued an Office Action rejecting
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`claims 12 and 18-20 and objecting to claims 13-17. Id. at 57-64. The Examiner
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`indicated that claims 13-17 included allowable subject matter. Id. In response to
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`the Office Action, Applicant amended claim 12, which was the only independent
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`claim, to include the additional limitations of allowable claim 13. Id. at 46-52.
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`Following an examiner interview at which Applicant’s attorney authorized an
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`examiner’s amendment to address Section 112 issues (id. at 33), the Examiner issued
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`a notice of allowance. Id. at 24-32.
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`VIII. PRIORITY DATE OF THE ’392 PATENT
`I understand that Petitioner takes no position on the proper priority date
`59.
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`of the ’392 Patent. I have been asked to assume that the earliest date to which the
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`’392 Patent is entitled to priority is January 8, 2014. Thus, for the purposes of this
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`Declaration, I have assumed the priority date of the ’392 Pate