`
`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.
`
`U.S. Patent No. 7,825,537
`
`______________________________________________
`
`DECLARATION OF DR. GARY WOODS
`
`GOOGLE AND SAMSUNG EXHIBIT 1002, 001
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`

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`TABLE OF CONTENTS
`
`
`Page
`
`
`INTRODUCTION .......................................................................................... 1
`I.
`II. MY BACKGROUND AND QUALIFICATIONS ........................................ 2
`III. LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS ...................................................................................................... 5
`IV. RELEVANT LEGAL STANDARDS ............................................................ 5
`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 ’537 PATENT ......................................................... 16
`VII. PROSECUTION HISTORY OF THE ’537 PATENT ................................. 19
`VIII. PRIORITY DATE OF THE ’537 PATENT ................................................ 20
`IX. CLAIM CONSTRUCTION ......................................................................... 20
`X. GROUNDS FOR FINDING THE CHALLENGED CLAIMS
`INVALID ...................................................................................................... 21
`A. Overview of Inductive Power Transfer Systems ............................... 21
`B.
`Overview of Prior Art References ...................................................... 23
`1.
`Overview of Cook (Ex-1005) .................................................. 23
`2.
`Overview of Baarman (Ex-1008)............................................. 27
`3.
`Overview of Partovi (Ex-1009) ............................................... 31
`Detailed Explanation of the Unpatentability Grounds ....................... 32
`C.
`D. Ground 1: Claims 1-5, 9-16, 20-22, and 28 Are Anticipated By
`Cook (Ex-1005) .................................................................................. 33
`1.
`Claim 1 ..................................................................................... 33
`2.
`Claim 2 ..................................................................................... 49
`3.
`Claim 3 ..................................................................................... 49
`4.
`Claim 4 ..................................................................................... 51
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`TABLE OF CONTENTS
`(continued)
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`Page
`
`Claim 5 ..................................................................................... 53
`5.
`Claim 9 ..................................................................................... 54
`6.
`Claim 10 ................................................................................... 56
`7.
`Claim 11 ................................................................................... 58
`8.
`Claim 12 ................................................................................... 59
`9.
`10. Claim 13 ................................................................................... 64
`11. Claim 14 ................................................................................... 64
`12. Claim 15 ................................................................................... 65
`13. Claim 16 ................................................................................... 66
`14. Claim 20 ................................................................................... 67
`15. Claim 21 ................................................................................... 67
`16. Claim 22 ................................................................................... 68
`17. Claim 28 ................................................................................... 68
`Ground 2: Claims 5 and 16 Are Rendered Obvious By Cook
`(Ex-1005) in view of Baarman (Ex-1008) ......................................... 71
`1.
`Dependent Claims 5 and 16 ..................................................... 71
`Ground 3: Claims 1-5, 9, 10, and 28 Are Anticipated By
`Baarman (Ex-1008) ............................................................................ 75
`1.
`Claim 1 ..................................................................................... 75
`2.
`Claim 2 ..................................................................................... 91
`3.
`Claim 3 ..................................................................................... 91
`4.
`Claim 4 ..................................................................................... 93
`5.
`Claim 5 ..................................................................................... 94
`6.
`Claim 9 ..................................................................................... 95
`7.
`Claim 10 ................................................................................... 97
`8.
`Claim 28 ................................................................................... 98
`
`ii
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`
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`E.
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`F.
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`GOOGLE AND SAMSUNG EXHIBIT 1002, 003
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`TABLE OF CONTENTS
`(continued)
`
`Page
`
`
`
`G. Ground 4: Claims 1-5, 9-16, 20-22, and 28 Are Rendered
`Obvious By Baarman (Ex-1008) in view of Partovi (Ex-1009) ...... 100
`1.
`Claim 12 ................................................................................. 100
`2.
`Claim 13 ................................................................................. 110
`3.
`Claim 14 ................................................................................. 110
`4.
`Claim 15 ................................................................................. 111
`5.
`Claim 16 ................................................................................. 112
`6.
`Claim 20 ................................................................................. 112
`7.
`Claim 21 ................................................................................. 113
`8.
`Claim 22 ................................................................................. 113
`9.
`Claims 1-5, 9-10, and 28 ........................................................ 115
`10. Claim 11 ................................................................................. 116
`XI. CONCLUSION ........................................................................................... 116
`
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`iii
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`GOOGLE AND SAMSUNG EXHIBIT 1002, 004
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`
`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.
`
`(collectively, “Petitioner”) for the above-captioned inter partes review (IPR). I
`
`understand that Petitioner challenges the validity of Claims 1-5, 9-16, 20-22, and
`
`28 of U.S. Patent No. 7,825,537.
`
`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. 7,825,537 (“the ’537 Patent”), Ex-1001, which resulted from U.S.
`
`Application No. 12/271,023 (the “’023 Application”). The ’023 Application was
`
`filed on November 14, 2008 and names Benjamin Freer as the inventor. See Ex-
`
`1001 at Cover. The ’537 Patent issued on November 2, 2010. I further understand
`
`that, according to USPTO records, the ’537 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 ’537
`
`Patent is entitled to priority is November 14, 2008.
`
`1
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`In preparing this Declaration, I have reviewed the ’537 Patent and
`
`5.
`
`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.
`
`6.
`
`I am familiar with the technology at issue as of November 14, 2008,
`
`the earliest claimed priority date of the ’537 Patent. I am also familiar with a
`
`person of ordinary skill in the art with respect to the technology at issue as of the
`
`November 14, 2008 earliest claimed priority date of the ’537 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,
`
`Texas. Since 2020, my title has been Distinguished Professor in the Practice.
`
`Before that, I worked as a postdoctoral fellow at the University of California, Santa
`
`Barbara (1996-1998); at Intel Corporation (1998-2000); at Spectralane Inc. (2000-
`
`2002); at Optonics (later Credence Systems Corp.) (2003-2006); and as an
`
`independent 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 Ph.D. (1997) in Applied Physics from Stanford University.
`
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`I am familiar with patents both as an inventor and as chief technology
`
`9.
`
`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 otpo-electronics, integrated circuits, signal processing, and
`
`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 for the International Space Station, using RFID to track bikers in a
`
`relay race, and treating cancer with microwave-absorbing implants. Projects with a
`
`significant charging but not wireless aspect include charging cellphones with
`
`supercapacitors and with human-powered generators, and harvesting energy from a
`
`shock absorber. I have supervised numerous projects involving significant wireless
`
`networking 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
`
`wireless aspects, including wirelessly powering a multi-element pacemaker; an 11
`
`GHz real-time 4x4 imaging radar array; sending video over cellphone links for
`
`3
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`ambulance telemedicine; ultra-low power wireless EEG transmission; several off-
`
`grid internet-of-things (IOT) systems; and several wirelessly transmitting medical
`
`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 have also developed educational demonstrations for classroom use involving
`
`original “crystal” AM radios based on homemade cuprous-oxide rectifiers.
`
`14.
`
`In formulating my opinions, I have relied upon my training,
`
`knowledge, 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 November 14, 2008. I have been asked to opine on the state of the art as of
`
`4
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`November 14, 2008, which I understand is the earliest claimed priority date of the
`
`’537 Patent.
`
`III. LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS
`In formulating my opinions, I have considered the following:
`16.
`
`• U.S. Patent No. 7,825,537 (Ex-1001);
`
`• Prosecution History of U.S. Patent No. 7,825,537 (Ex-1004);
`
`• U.S. Patent No. 8,729,734 (“Cook”) (Ex-1005);
`
`• Certified Translation of JP 3692541B2 (“Nagai”) (Ex-1006);
`
`• U.S. Patent Publication No. US20040130916A1 (“Baarman”) (Ex-
`
`1008);
`
`• U.S. Patent Publication No. 20070182367A1 (“Partovi”) (Ex-1009);
`
`• U.S. Patent Publication No. US20050127850A1 (“Baarman 850”)
`
`(Ex-1010);
`
`• U.S. Patent No. 6,849,837 (“Riess”) (Ex-1011);
`
`• U.S. Patent No. 7,002,819 (“Chan”) (Ex-1012);
`
`• G.B. Patent Application No. 2414120A (“Stevens”) (Ex-1013); and
`
`• U.S. Patent No. 6,825,620 (“Kuennen”) (Ex-1014).
`
`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
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`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 so that a person of ordinary skill in the art could make and use the
`
`claimed subject-matter.
`
`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,
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`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.
`
`23.
`
`I understand that when a challenged claim covers several structures,
`
`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.
`
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`
`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
`
`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
`
`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
`
`8
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`invention. I also understand that contemporaneous and independent invention by
`
`others is a 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 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,
`
`either in the same field or a different one. If a person of ordinary skill in the art can
`
`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
`
`9
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`had reason to combine multiple prior art references or add missing features to
`
`reproduce the alleged invention recited in the claims.
`
`30.
`
`I am not aware of any allegations by the named inventors of the ’537
`
`Patent or any assignee of the ’537 Patent that any secondary considerations tend to
`
`rebut the obviousness of any claim of the ’537 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,
`33.
`
`independent 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 depends from an independent claim or another dependent claim. I
`
`understand that a 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.
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`I understand that to determine how a person of ordinary skill would
`
`35.
`
`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 of the invention.
`
`37.
`
`I understand that words or terms should be given their ordinary and
`
`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.
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`I understand that the claims of a patent define the scope of the rights
`
`38.
`
`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 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
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`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
`
`essential structure or steps, or is necessary to give meaning to the claim. For
`
`instance, 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
`
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`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 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
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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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`14
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`GOOGLE AND SAMSUNG EXHIBIT 1002, 018
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`V.
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`PERSON OF ORDINARY SKILL IN THE ART
`I understand that factors that may be considered in establishing the
`46.
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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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`47.
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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
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`November 14, 2008.
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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,
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`and at least one year of experience in the research, design, development, and/or
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`testing 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 November 14, 2008, and I still exceed it today.
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`15
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`
`VI. OVERVIEW OF THE ’537 PATENT
`50. The ’537 Patent is directed to transferring power between an
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`electronically isolated base unit 102 and a target unit 103 through inductive
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`elements on the base unit 112 and target unit 120. Ex-1001 at 3:22-27, 3:59-64.
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`51. As shown in Figure 1 below, the ’537 Patent discloses a DC voltage
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`supply 104 connected to a switching network 114 for directing alternating current
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`to the first inductive element 112.
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`
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`Id. at 3:39-44; FIG. 1.
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`52. The ’537 Patent states that in operation, “the base unit 102 and the
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`target unit 103 are placed and aligned in relative proximity to each other.” Id. at
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`6:56-58. The ’537 Patent does not provide a single distance, but states that “the
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`16
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`first and second inductive elements can to be positioned within a distance of 10-15
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`cm or less to maximize power transfer.” Id. at 6:65-67. The ’537 Patent states that
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`“a positioning structure(s) 115, such as contacting or interlocking protrusions or
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`edges can be provided on a support and/or housing of the base unit 102 and/or the
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`target unit 103 to facilitate alignment.” Id. at 7:13-16.
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`53. The ’537 Patents states that “power can be transferred to the target
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`unit 103 via a secondary coil formed from a second inductive element 120 in the
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`target unit 103.” Id. at 3:62-64. “The second inductive element 120 can be
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`electrically coupled to a rectifying element 122 for generating a DC voltage
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`signal.” Id. at 3:65-67.
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`54. The ’537 Patent states that “[o]ne of ordinary skill in the art will
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`recognize that the amount of power transferred from the base unit 102 to the target
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`unit 103 is dependent on the amount of magnetic coupling between the first
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`inductive element 112 and the second inductive element 120.” Id. at 4:7-11. The
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`’537 Patent alleges that “[i]n conventional designs, the amount of magnetic
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`coupling is adjusted by matching the inductor coil design of the inductive elements
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`112.” Id. at 4:11-13.
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`55. The ’537 Patent states that “in the various embodiments of the present
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`invention, rather than attempting to precisely match the coil characteristics of the
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`first inductive element 112 and the second inductive element 120, as in
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`17
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`Inter Partes Review of U.S. Patent No. 7,825,537
`Declaration of Gary Woods
`conventional designs, the switching network 114 is used to adjust the operating
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`frequency of the existing first inductive el