EXHIBIT 15A
`EXHIBIT 15A
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`EXHIBIT 15A
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`IPR2022-00716
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`EXHIBIT 15A
`Complainant’s Proof of Infringement
`U.S. Patent No. 9,705,400 — Claims 1, 8, 13, and 15
`
`No part of this exemplary chart construes, or is intended to construe, the claims, specification, or prosecution history of the ’400
`patent. The claims have not yet been construed. The following claims and claim limitations are satisfied literally and/or under the
`doctrine of equivalents unless specifically noted. This exemplary chart does not limit, and is not intended to limit, Ericsson’s
`positions or contentions on claim construction, infringement, domestic industry, or validity. Further, Ericsson reserves the right to rely
`on other claims and/or products to establish the technical prong of the domestic industry requirement or to establish infringement. This
`chart should not be construed as providing any positions on claim construction, such as, for example, whether any claim preamble
`should be limiting or whether any claim element is subject to 35 U.S.C. Section 112(f). The evidence cited to is exemplary and non-
`limiting. Ericsson reserves the right to update its infringement and domestic industry contentions through discovery.
`
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`1. An output stage adapted
`The Broadcom 59365EA1 in an iPhone 13 corresponds to the output stage. The Broadcom 59365EA1 in
`to operate in at least a first
`an iPhone 13 is used for wireless reverse charging (e.g., first operating state) and wireless charging (e.g.,
`operating state and a
`second operating state).
`second operating state, the
`
`output stage comprising:
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
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`
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`Ex. 15A.1 (How to use your MagSafe Battery Pack)1 at 1:
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`1 https://support.apple.com/en-us/HT212174
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`2
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`a first, a second, a third and
`Metal layer of Broadcom 59635EA1:
`a fourth configurable
`4th input/
`input/output terminals; and,
`output
`terminal
`
`3rd input/
`output
`terminal
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`1st input/
`output
`terminal
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`2nd input/
`output
`terminal
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Die image of Broadcom 59365EA1:
`
`
`4th terminal
`connections
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`2nd terminal
`connections
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`4
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`1st terminal
`connections
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`3rd terminal
`connections
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`4th switch
`
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`a first, a second, a third and
`The marked-up die image of a Broadcom 59365EA1 shows the first, second, third, and fourth switches:
`a fourth switches, each
`3rd switch
`having a first main
`terminal, a second main
`terminal and a control
`terminal, the control
`terminal being adapted to
`receive a control signal for
`controlling the open or
`closed state of the switch,
`
`2nd switch
`
`1st switch
`
`5
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The marked-up die image below shows the first main terminal, second main terminal, and control
`terminal of the first, second, third, and fourth switches:
`
`
`
`
`second main
`
`terminal
`
`second main
`terminal
`
`control terminal
`control terminal
`
`control terminal
`control terminal
`
`first main
`terminal
`
`second main
`terminal
`
`first main
`terminal
`
`first main
`terminal
`
`second main
`terminal
`
`first main
`terminal
`
`
`Each control terminal of each switch is adapted to receive a control signal for controlling the open or
`closed state of the switch.
`
`
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`6
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The first input/output terminal is connected to the first main terminal of the first switch and the second
`wherein,
`the first input/output
`input/output terminal is connected to the first main terminal of the second switch
`terminal is connected to the
`
`first main terminal of the
`first switch;
`
`the second input/output
`terminal is connected to the
`first main terminal of the
`second switch;
`
`2nd input/
`output
`terminal
`
`Connection
`to first main
`terminal of
`2nd switch
`
`
`
`7
`
`1st input/
`output
`terminal
`
`Connection
`to first main
`terminal of
`1st switch
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The second main terminal of the first switch is connected to the first main terminal of the third switch
`the second main terminal
`through a first branch and the second main terminal of the second switch is connected to the first main
`of the first switch is
`connected to the first main
`terminal of the fourth switch through a second branch
`terminal of the third switch
`
`through a first branch,
`
`
`
`
`Connection
`to first main
`terminal of
`fourth switch
`
`the second main terminal
`of the second switch is
`connected to the first main
`terminal of the fourth
`switch through a second
`branch;
`
`second branch
`
`first branch
`
`Connection
`to first main
`terminal of
`third switch
`
`Connection to
`second main
`terminal of
`second switch
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`8
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`Connection to
`second main
`terminal of
`first switch
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The third input/output terminal is connected to the first branch and the fourth input / output terminal is
`the third input/output
`terminal is connected to the
`connected to the second branch
`first branch and the fourth
`
`input/output terminal is
`
`connected to the second
`
`branch;
`
`second branch
`
`first branch
`
`4th input/
`output
`terminal
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`
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`9
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`3rd input/
`output
`terminal
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`the second main terminals
`of the third and fourth
`switches are both
`connected to a common
`node receiving a reference
`potential; and,
`
`second main
`terminal of
`fourth switch
`
`
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`10
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`second main
`terminal of
`third switch
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
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`2nd main terminal of the 4th
`switch connected to solder balls
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`2nd main terminal of the 3rd
`switch connected to solder balls
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Solder balls connected to second main terminal of third switch and solder balls connected second
`main terminal of fourth switch are all connected to a common node receiving a reference potential, in
`this case a common ground (G)
`
`
`PCB ground
`connected to
`solder balls
`connected to 2nd
`main terminal of
`the 3rd switch
`
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`12
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`PCB ground
`connected to
`solder balls
`connected to 2nd
`main terminal of
`the 4th switch
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`wherein,
`The “first and second input/output terminals are configured to operate as input terminals, the third and
`when the first and second
`fourth input/output terminals are configured to operate as output terminals” corresponds to the wireless
`input/output terminals are
`reverse charging mode, where the Broadcom 59365EA1 is operating in transmit power mode. The “first
`configured to operate as
`and second input/output terminals are configured to operate as output terminals, the third and fourth
`input terminals, the third
`input/output terminals are configured to operate as input terminals” corresponds to the wireless charging
`and fourth input/output
`mode, where the Broadcom 59365EA1 is operating in receive power mode.
`terminals are configured to
`
`operate as output terminals;
`The wireless charging coil of the iPhone 13 has two connections labeled 3 and 4.
`and,
`
`when the first and second
`input/output terminals are
`configured to operate as
`output terminals, the third
`and fourth input/output
`terminals are configured to
`operate as input terminals;
`and,
`
`
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`13
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Connection 4 is connected directly to the fourth input/output terminal of the Broadcom 59365EA1.
`Connection 3 is connected via capacitors to the third input/output terminal of the Broadcom 59365EA1.
`
`
`4th input/
`output terminal
`
`
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`3rd input/
`output terminal
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The first and second input/output terminals are connected to a common node that is connected to
`battery of the iPhone 13.
`
`
`1st and 2nd
`input/output
`terminals
`connected in
`metal layer
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`15
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`
`1st and 2nd
`input/output
`terminals connected
`to common node on
`PCB
`
`
`An iPhone 13 was placed into the wireless reverse charging mode by connecting a charger to the
`lightning connector of the iPhone 13 and magnetically attaching a MagSafe Battery Pack to the
`wireless charging coil of the iPhone 13. The below screenshot of the iPhone 13 while in this
`configuration confirms that the charger is charging the iPhone 13 and the iPhone 13 is charging the
`MagSafe Battery Pack via the wireless charging coil, which means the Broadcom 59365EA1 is
`operating in transmit power mode.
`
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`
`wherein,
`in the first operating state,
`the output stage is arranged
`in a first electrical
`configuration; and
`in the second operating
`state wherein the output
`stage is arranged in a
`second electrical
`configuration different
`from the first
`configuration.
`
`
`The same iPhone 13 was placed into wireless charging mode by disconnecting the charger from the
`lightning connector of the iPhone 13 while the MagSafe Battery Pack remained magnetically attached. The
`below screenshot of the iPhone 13 while in this configuration confirms that the MagSafe Battery Pack is
`charging the iPhone 13, which means the Broadcom 59365EA1 is operating in receive power mode.
`
`
`
`
`
`In wireless reverse charging / transmit power mode, the Broadcom 59365EA1 is arranged in a first
`electrical configuration and in wireless charging / receive power mode, the Broadcom 59365EA1 is
`arranged in a second electrical configuration different from the first configuration.
`
`Ex. 15A.1 (How to use your MagSafe Battery Pack) at 1:
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`8. A control apparatus
`The Broadcom 59365EA1 in an iPhone 13 corresponds to the control stage and the output stage. The
`comprising:
`Broadcom 59365EA1 in an iPhone 13 is used for wireless reverse charging (e.g., first operating state) and
`wireless charging (e.g., second operating state).
`a control stage configured
`
`to control an output stage
`adapted to operate in at
`least a first operating state
`and a second operating
`state, the output stage
`including:
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`
`
`Ex. 15A.1 (How to use your MagSafe Battery Pack) at 1:
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`a first, a second, a third and
`Metal layer of Broadcom 59635EA1:
`a fourth configurable
`4th input/
`input/output terminals; and,
`output
`terminal
`
`3rd input/
`output
`terminal
`
`1st input/
`output
`terminal
`
`2nd input/
`output
`terminal
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
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`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Die image of Broadcom 59365EA1:
`
`
`4th terminal
`connections
`
`2nd terminal
`connections
`
`
`
`
`
`
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`
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`21
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`1st terminal
`connections
`
`3rd terminal
`connections
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`a first, a second, a third and
`The marked-up die image of a Broadcom 59365EA1 shows the first, second, third, and fourth switches:
`a fourth switches, each
`
`3rd switch
`4th switch
`having a first main
`
`terminal, a second main
`terminal and a control
`terminal, the control
`terminal being adapted to
`receive a control signal for
`controlling the open or
`closed state of the switch,
`
`2nd switch
`
`1st switch
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The marked-up die image below shows the first main terminal, second main terminal, and control
`terminal of the first, second, third, and fourth switches:
`
`
`
`
`second main
`
`terminal
`
`second main
`terminal
`
`control terminal
`control terminal
`
`control terminal
`control terminal
`
`first main
`terminal
`
`second main
`terminal
`
`first main
`terminal
`
`first main
`terminal
`
`second main
`terminal
`
`first main
`terminal
`
`
`Each control terminal of each switch is adapted to receive a control signal for controlling the open or
`closed state of the switch.
`
`
`
`23
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The first input/output terminal is connected to the first main terminal of the first switch and the second
`wherein,
`the first input/output
`input/output terminal is connected to the first main terminal of the second switch
`terminal is connected to the
`
`first main terminal of the
`first switch;
`the second input/output
`terminal is connected to the
`first main terminal of the
`second switch;
`
`2nd input/
`output
`terminal
`
`1st input/
`output
`terminal
`
`Connection
`to first main
`terminal of
`2nd switch
`
`
`
`
`
`
`
`
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`24
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`Connection
`to first main
`terminal of
`1st switch
`
`
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`IPR2022-00716
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The second main terminal of the first switch is connected to the first main terminal of the third switch
`the second main terminal
`through a first branch and the second main terminal of the second switch is connected to the first main
`of the first switch is
`connected to the first main
`terminal of the fourth switch through a second branch
`terminal of the third switch
`
`through a first branch,
`
`
`the second main terminal
`
`of the second switch is
`connected to the first main
`terminal of the fourth
`switch through a second
`branch;
`
`Connection
`to first main
`terminal of
`fourth switch
`
`second branch
`
`first branch
`
`Connection
`to first main
`terminal of
`third switch
`
`Connection to
`second main
`terminal of
`second switch
`
`
`
`
`
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`25
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`Connection to
`second main
`terminal of
`first switch
`
`
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`IPR2022-00716
`Apple EX1013 Page 26
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The third input/output terminal is connected to the first branch and the fourth input / output terminal is
`the third input/output
`terminal is connected to the
`connected to the second branch
`first branch and the fourth
`
`input/output terminal is
`
`connected to the second
`
`branch;
`
`second branch
`
`first branch
`
`4th input/
`output
`terminal
`
`
`
`
`
`
`
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`26
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`3rd input/
`output
`terminal
`
`
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`Apple EX1013 Page 27
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`the second main terminals
`of the third and fourth
`switches are both
`connected to a common
`node receiving a reference
`potential; and,
`
`second main
`terminal of
`fourth switch
`
`
`
`
`
`
`
`
`
`
`
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`27
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`second main
`terminal of
`third switch
`
`
`
`IPR2022-00716
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`
`
`
`
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`2nd main terminal of the 4th
`switch connected to solder balls
`
`2nd main terminal of the 3rd
`switch connected to solder balls
`
`
`
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Solder balls connected to second main terminal of third switch and solder balls connected second
`main terminal of fourth switch are all connected to a common node receiving a reference potential, in
`this case a common ground (G)
`
`
`PCB ground
`connected to
`solder balls
`connected to 2nd
`main terminal of
`the 3rd switch
`
`
`
`
`
`
`
`
`
`29
`
`PCB ground
`connected to
`solder balls
`connected to 2nd
`main terminal of
`the 4th switch
`
`
`
`IPR2022-00716
`Apple EX1013 Page 30
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`
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`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`wherein,
`The “first and second input/output terminals are configured to operate as input terminals, the third and
`when the first and second
`fourth input/output terminals are configured to operate as output terminals” corresponds to the wireless
`input/output terminals are
`reverse charging mode, where the Broadcom 59365EA1 is operating in transmit power mode. The “first
`configured to operate as
`and second input/output terminals are configured to operate as output terminals, the third and fourth
`input terminals, the third
`input/output terminals are configured to operate as input terminals” corresponds to the wireless charging
`and fourth input/output
`mode, where the Broadcom 59365EA1 is operating in receive power mode.
`terminal are configured to
`
`operate as output terminals;
`The wireless charging coil of the iPhone 13 has two connections labeled 3 and 4.
`and,
`
`when the first and second
`input/output terminals are
`configured to operate as
`output terminals, the third
`and fourth input/output
`terminals are configured to
`operate as input terminals;
`and,
`
`
`
`30
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`
`
`IPR2022-00716
`Apple EX1013 Page 31
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`
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`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Connection 4 is connected directly to the fourth input/output terminal of the Broadcom 59365EA1.
`Connection 3 is connected via capacitors to the third input/output terminal of the Broadcom 59365EA1.
`
`
`4th input/
`output terminal
`
`
`
`3rd input/
`output terminal
`
`
`
`
`
`
`
`
`
`31
`
`IPR2022-00716
`Apple EX1013 Page 32
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`
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`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The first and second input/output terminals are connected to a common node that is connected to
`battery of the iPhone 13.
`
`
`1st and 2nd
`input/output
`terminals
`connected in
`metal layer
`
`
`
`
`
`
`32
`
`IPR2022-00716
`Apple EX1013 Page 33
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`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`
`1st and 2nd
`input/output
`terminals connected
`to common node on
`PCB
`
`
`An iPhone 13 was placed into the wireless reverse charging mode by connecting a charger to the
`lightning connector of the iPhone 13 and magnetically attaching a MagSafe Battery Pack to the
`wireless charging coil of the iPhone 13. The below screenshot of the iPhone 13 while in this
`configuration confirms that the charger is charging the iPhone 13 and the iPhone 13 is charging the
`MagSafe Battery Pack via the wireless charging coil, which means the Broadcom 59365EA1 is
`operating in transmit power mode.
`
`
`
`
`33
`
`IPR2022-00716
`Apple EX1013 Page 34
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`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`
`wherein,
`in the first operating state,
`the output stage is arranged
`in a first electrical
`configuration; and
`in the second operating
`state wherein the output
`stage is arranged in a
`second electrical
`configuration different
`from the first
`configuration, and
`
`
`The same iPhone 13 was placed into wireless charging mode by disconnecting the charger from the
`lightning connector of the iPhone 13 while the MagSafe Battery Pack remained magnetically attached. The
`below screenshot of the iPhone 13 while in this configuration confirms that the MagSafe Battery Pack is
`charging the iPhone 13, which means the Broadcom 59365EA1 is operating in receive power mode.
`
`
`
`
`
`In wireless reverse charging / transmit power mode, the Broadcom 59365EA1 is arranged in a first
`electrical configuration and in wireless charging / receive power mode, the Broadcom 59365EA1 is
`arranged in a second electrical configuration different from the first configuration.
`
`Ex. 15A.1 (How to use your MagSafe Battery Pack) at 1:
`
`
`
`
`
`
`
`34
`
`
`
`IPR2022-00716
`Apple EX1013 Page 35
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`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`further wherein, in the first
`The “first operating state” corresponds to wireless reverse charging, when the Broadcom 59365EA1 is
`operating in transmit power mode. As shown above, in the wireless reverse charging state, the first and second
`operating state,
`input/output terminals are configured to operate as input terminals
`the first and second
`
`input/output terminals are
`The wireless charging coil of the iPhone 13 has two connections labeled 3 and 4.
`configured to operate as
`
`input terminals and are
`configured to be connected
`to a common node
`receiving a supply
`potential; and
`the third and fourth
`input/output terminals are
`configured to be connected
`to a load element.
`
`
`
`
`
`
`35
`
`
`
`IPR2022-00716
`Apple EX1013 Page 36
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`
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`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Connection 4 is connected directly to the fourth input/output terminal of the Broadcom 59365EA1.
`Connection 3 is connected via capacitors to the third input/output terminal of the Broadcom 59365EA1.
`
`The first and second input/output terminals are connected to a common node. The third and fourth
`input/output terminals are connected to a load element comprising a series resonant circuit formed by the
`wireless charging coil and series capacitors on the PCB.
`
`
`Series capacitors
`connected to 3rd
`and 4th input/
`output terminals
`
`1st and 2nd
`input/output
`terminals connected
`to common node on
`PCB
`
`
`
`
`
`
`
`
`36
`
`IPR2022-00716
`Apple EX1013 Page 37
`
`
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`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The die image including metal layer and solder balls of the Broadcom 59365EA1 also shows that the
`first and second input/output terminals are connected to a common node in the metal layer.
`
`1st and 2nd
`input/output
`terminals
`connected in
`metal layer
`
`
`
`
`
`
`
`
`
`
`
`
`
`37
`
`IPR2022-00716
`Apple EX1013 Page 38
`
`
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`13. A circuit comprising:
`The Broadcom 59365EA1 in an iPhone 13 is an integrated circuit that corresponds to the output stage. The
`Broadcom 59365EA1 in an iPhone 13 is used for wireless reverse charging (e.g., first operating state) and
`an output stage adapted to
`wireless charging (e.g., second operating state).
`operate in at least a first
`
`operating state and a
`second operating state, the
`output stage including:
`
`
`
`
`
`
`38
`
`
`
`
`
`IPR2022-00716
`Apple EX1013 Page 39
`
`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Ex. 15A.1 (How to use your MagSafe Battery Pack) at 1:
`
`
`a first, a second, a third and
`a fourth configurable
`input/output terminals; and,
`
`Metal layer of Broadcom 59635EA1:
`4th input/
`output
`terminal
`
`2nd input/
`output
`terminal
`
`
`
`39
`
`
`
`3rd input/
`output
`terminal
`
`1st input/
`output
`terminal
`
`
`
`IPR2022-00716
`Apple EX1013 Page 40
`
`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`Die image of Broadcom 59365EA1:
`
`
`1st terminal
`connections
`
`3rd terminal
`connections
`
`
`
`4th terminal
`connections
`
`2nd terminal
`connections
`
`
`
`
`
`
`
`
`
`
`40
`
`IPR2022-00716
`Apple EX1013 Page 41
`
`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`a first, a second, a third and
`The marked-up die image of a Broadcom 59365EA1 shows the first, second, third, and fourth switches:
`a fourth switches, each
`
`3rd switch
`4th switch
`having a first main
`
`terminal, a second main
`terminal and a control
`terminal, the control
`terminal being adapted to
`receive a control signal for
`controlling the open or
`closed state of the switch,
`
`2nd switch
`
`1st switch
`
`
`
`
`
`
`
`
`
`
`
`41
`
`IPR2022-00716
`Apple EX1013 Page 42
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`
`
`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The marked-up die image below shows the first main terminal, second main terminal, and control
`terminal of the first, second, third, and fourth switches:
`
`
`
`
`second main
`
`terminal
`
`second main
`terminal
`
`control terminal
`control terminal
`
`control terminal
`control terminal
`
`first main
`terminal
`
`second main
`terminal
`
`first main
`terminal
`
`first main
`terminal
`
`second main
`terminal
`
`first main
`terminal
`
`
`Each control terminal of each switch is adapted to receive a control signal for controlling the open or
`closed state of the switch.
`
`
`
`42
`
`IPR2022-00716
`Apple EX1013 Page 43
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`
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`
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`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The first input/output terminal is connected to the first main terminal of the first switch and the second
`wherein,
`the first input/output
`input/output terminal is connected to the first main terminal of the second switch
`terminal is connected to the
`
`first main terminal of the
`first switch;
`the second input/output
`terminal is connected to the
`first main terminal of the
`second switch;
`
`2nd input/
`output
`terminal
`
`1st input/
`output
`terminal
`
`Connection
`to first main
`terminal of
`2nd switch
`
`
`
`
`
`
`
`
`
`43
`
`Connection
`to first main
`terminal of
`1st switch
`
`
`
`IPR2022-00716
`Apple EX1013 Page 44
`
`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The second main terminal of the first switch is connected to the first main terminal of the third switch
`the second main terminal
`through a first branch and the second main terminal of the second switch is connected to the first main
`of the first switch is
`connected to the first main
`terminal of the fourth switch through a second branch
`terminal of the third switch
`
`through a first branch,
`
`
`the second main terminal
`
`of the second switch is
`connected to the first main
`terminal of the fourth
`switch through a second
`branch;
`
`Connection
`to first main
`terminal of
`fourth switch
`
`second branch
`
`first branch
`
`Connection
`to first main
`terminal of
`third switch
`
`Connection to
`second main
`terminal of
`second switch
`
`
`
`
`
`
`44
`
`Connection to
`second main
`terminal of
`first switch
`
`
`
`IPR2022-00716
`Apple EX1013 Page 45
`
`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`The third input/output terminal is connected to the first branch and the fourth input / output terminal is
`the third input/output
`terminal is connected to the
`connected to the second branch
`first branch and the fourth
`
`input/output terminal is
`
`connected to the second
`
`branch;
`
`second branch
`
`first branch
`
`4th input/
`output
`terminal
`
`
`
`
`
`
`
`
`45
`
`3rd input/
`output
`terminal
`
`
`
`IPR2022-00716
`Apple EX1013 Page 46
`
`
`
`
`
`EXHIBIT 15A: INFRINGEMENT CLAIM CHART FOR
`APPLE IPHONE – U.S. PATENT NO. 9,705,400
`
`U.S. Patent No. 9,705,400 Apple iPhone 13 and similar products (“Accused Products”)
`the second main terminals
`of the third and fourth
`switches are both
`connected to a common
`node receiving a reference
`potential; and,
`
`second main
`terminal of
`fourth switch
`
`
`
`
`
`
`
`
`
`
`
`
`46
`
`second main
`terminal of
`third switch
`
`
`
`IPR2022-00716
`Apple EX1013 Page 47
`
`
`
`
`
`EXHIBIT 15A: INF
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