Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`SHENZHEN APALTEK CO., LTD.
`
`Petitioner,
`
`v.
`
`ASETEK DANMARK A/S,
`
`Patent Owner
`
`_________________
`
`Case No. IPR2022-01317
`U.S. Patent No. 8,245,764
`_________________
`
`DECLARATION OF GEORGIOS KARAMANIS, PH.D.
`
`Dated: August 1, 2022
`
`Respectfully submitted,
`
`______________________
`Georgios Karamanis, Ph.D.
`
`ACTIVE 681051191
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 1 of 168
`Shenzhen Apaltek Co., Ltd. v. Asetek Danmark A/S
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`TABLE OF CONTENTS
`
`INTRODUCTION AND QUALIFICATIONS .............................................. 1
`I.
`II. MATERIALS CONSIDERED ....................................................................... 2
`III. OVERVIEW AND LEGAL STANDARDS .................................................. 4
`A.
`Priority Date ......................................................................................... 4
`B.
`Person Having Ordinary Skill in the Art .............................................. 4
`C.
`CLAIM CONSTRUCTION ................................................................. 7
`1.
`“reservoir” .................................................................................. 7
`2.
`“chamber” .................................................................................. 7
`3.
`“underside” and “upper side” of the “chassis” .......................... 7
`4.
`“below” ...................................................................................... 8
`5.
`“below … vertically” ................................................................. 8
`6.
`Other Terms ............................................................................... 8
`LEGAL STANDARDS .................................................................................. 9
`IV.
`OVERVIEW OF THE ’764 PATENT ......................................................... 11
`V.
`VI. OVERVIEW OF PRIOR ART ..................................................................... 15
`A.
`Duan (Ex-1006) .................................................................................. 15
`B.
`Duan I (Ex-1007) ................................................................................ 16
`C.
`Batchelder (Ex-1008) ......................................................................... 16
`D.
`Laing (Ex-1015) ................................................................................. 16
`VII. CLAIM ELEMENT NUMBERING KEY ................................................... 17
`VIII. ANALYSIS ................................................................................................... 31
`A.
`GROUND 1: Claims 1-19, 21-27, and 29-30 are rendered
`obvious over Duan by itself or in view of Duan I. ............................. 32
`1.
`Duan by itself or in view of Duan I discloses or suggests
`each limitation of claim 1 and renders it obvious. ................... 32
`Duan by itself or in view of Duan I teaches each
`limitation of claims 2-9. ........................................................... 55
`-i-
`
`2.
`
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`3.
`
`6.
`
`7.
`
`2.
`3.
`
`4.
`
`5.
`
`6.
`7.
`
`4.
`5.
`
`Duan and Duan I disclose or teach each limitation of
`claim 10 and render it obvious. ................................................ 72
`Duan teaches each limitation of claims 11-14. ........................ 77
`Duan and Duan I teach each limitation of claim 15 and
`render it obvious....................................................................... 80
`Duan teaches each limitation of claims 16-19, 21-27, and
`29. ............................................................................................. 88
`Duan by itself or in view of Duan I teaches each
`limitation of claim 30. .............................................................. 97
`GROUNDS 3 and 4: Claim 8 is obvious over Duan in view of
`Laing or Duan in view of Duan-I and further in view of Laing. ....... 97
`GROUND 5: Claims 1-30 are rendered obvious over
`Batchelder in view of Duan. ............................................................... 99
`1.
`Batchelder in view of Duan teaches each limitation of
`claim 1 and renders it obvious. ................................................ 99
`Batchelder teaches each limitation of claims 2-9. ................. 124
`Batchelder and Duan teach each limitation of claim 10
`and render it obvious. ............................................................. 135
`Batchelder and Duan disclose or teach each limitation of
`claims 11-14. .......................................................................... 140
`Batchelder and Duan disclose or teach each limitation of
`claim 15 and render it obvious. .............................................. 145
`Batchelder teaches each limitation of claims 16-29. ............. 149
`Batchelder discloses or teaches each limitation of claim
`30. ........................................................................................... 158
`GROUND 6: Claim 8 is obvious over Batchelder in view of
`Duan and further in view of Laing. .................................................. 159
`IX. CONCLUDING STATEMENT ................................................................. 160
`
`B.
`
`C.
`
`D.
`
`-ii-
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`I, Georgios Karamanis, Ph.D., declare as follows:
`I.
`INTRODUCTION AND QUALIFICATIONS
`1.
`Counsel for Shenzhen Apaltek CO., LTD. (“Apaltek”) has retained me
`
`as an expert to offer my opinion regarding the validity of U.S. Patent No. 8,245,764
`
`(“’764 patent”). I submit this declaration based on my personal knowledge and in
`
`support of Apaltek’s inter partes review Petition against the ’764 patent.
`
`2.
`
`In 2018, I received my Ph.D. from Tufts University in Mechanical
`
`Engineering. My Ph.D. thesis was entitled “Nusselt Numbers for Superhydrophobic
`
`Microchannels and Shrouded Longitudinal-Fin Heat Sinks.”
`
`3.
`
`In October 2018, I began working at Transport Phenomena
`
`Technologies, LLC (TPT) in Medford, MA where I am co-founder and managing
`
`member.
`
`4.
`
`I am currently a Chief Engineer at TPT and responsible for R&D in the
`
`area of thermal management of electronics and heat/mass/momentum transfer
`
`modeling.
`
`5.
`
`I am the PI on a National Science Foundation Phase I and its successor
`
`Phase II SBIR award (#2025882) and before that on a Massachusetts Clean Energy
`
`Center Catalyst award (Spring 2019) relevant to development of software and
`
`hardware for thermal management of electronics.
`
`6.
`
`I have 10 journal publications most of which are related to thermal
`-1-
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 4 of 168
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`management of electronics and liquid cooling. A copy of my Curriculum Vitae
`
`(“CV”) is submitted herewith as Appendix A, which describes my education,
`
`training, and experience in greater detail.
`
`7.
`
`My primary consulting client is Apaltek, acting as an expert on thermal
`
`management in general, including liquid cooling to cool CPUs.
`
`8.
`
`I have not previously testified as an expert witness in any court or
`
`administrative proceeding.
`
`9.
`
`I am billing my work in this matter at $200 per hour, with
`
`reimbursement for actual expenses. My payment is not contingent upon my
`
`testimony or the outcome of the case. I have no personal interest in the outcome of
`
`the case.
`
`II. MATERIALS CONSIDERED
`10.
`The analysis provided in this declaration is based on my education as
`
`well as my experience in the field. In addition to relying upon my knowledge based
`
`on written materials and other information that was known as of May 6, 2005, I have
`
`considered the exhibits to the Petition (Exs. 1001-1015), shown below.
`
`Exhibit
`1001
`
`Description
`U.S. Patent No. 8,245,764 (“’764 patent”)
`
`-2-
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`Exhibit
`1002
`
`Description
`Inter Partes Reexamination Certificate, Reexamination Request
`95/002,386, U.S. Patent No. 8,245,764
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`File history of U.S. Patent No. 8,245,764 (“’764-FH”)
`
`Defendants’ Reply Claim Construction Brief filed on April 12,
`2022 in Asetek Danmark A/S v. Shenzhen Apaltek Co., Ltd., Case
`No. 6:21-cv-501-ADA (W.D. Tex.) (Doc. 61)
`
`U.S. Patent Publication No. 2006/0185830 (“Duan”)
`
`U.S. Patent Publication No. 2006/0185829 (“Duan-I”)
`
`U.S. Patent No. 6,019,165 to Batchelder (“Batchelder”)
`
`Patent Owner’s Response, Paper No. 21 in IPR2020-00523 (Nov.
`30 2020) (“’354-POR”)
`
`U.S. Patent No. 10,078,354 (the “’354 patent”)
`
`Final Written Decision in IPR2020-00523, Paper No. 36 (Aug. 19,
`2021) (“’354-FWD”)
`
`File history of Reexamination Request 95/002,386, U.S. Patent
`No. 8,245,764 (“’764-Rexam-FH”)
`
`Institution Decision, Paper No. 10, IPR2021-01196 (Dec. 28,
`2021) (“’196-Institution”)
`
`Certified Translation of Japanese Unexamined Patent App. Pub.
`No. 2002-151638 to Takayuki Shin (“Shin”)
`
`
`
`
`
`
`
`-3-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`Exhibit
`1015
`
`
`
`Description
`U.S. Patent Publication No. 2004/0052663 (“Laing”)
`
`III. OVERVIEW AND LEGAL STANDARDS
`Priority Date
`A.
`11. Counsel for Apaltek has explained to me that I should assume the
`
`effective filing date of the ’764 patent is May 6, 2005. I have, therefore, applied this
`
`date in considering the prior art and the viewpoint of a person of ordinary skill in the
`
`art (“POSITA”).
`
`12.
`
`I understand Petitioner may argue that the ’764 patent is not entitled to
`
`a 2005 effective filing date. Even if this were true, my opinions would not change.
`
`B.
`13.
`
`Person Having Ordinary Skill in the Art
`I understand that my assessment of the claims of the ’764 patent must
`
`be undertaken from the perspective of what would have been known or understood
`
`by a person having ordinary skill in the art, reading the ’764 patent on its relevant
`
`filing date and in light of the specification and file history of the ’764 patent. I will
`
`refer to such a person as a “POSITA.”
`
`14.
`
`I understand that my analysis and opinions expressed in this declaration
`
`must be rendered based on the perspective of a POSITA as of the priority date of the
`
`
`
`
`
`
`-4-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`Challenged Claims. I also understand that a POSITA is a hypothetical person who
`
`is presumed to have known the relevant art at the time of the alleged invention
`
`claimed in the ’764 patent.
`
`15.
`
`I further understand that in determining the level of ordinary skill in the
`
`art, I am to consider factors including:
`
`a) the type of problems encountered in the art or field of invention,
`
`b) prior art solutions to those problems,
`
`c) the rapidity with which innovations are made,
`
`d) sophistication of the technology, and
`
`e) the educational level of active workers in the field.
`
`16.
`
`I understand that a POSITA is a person of ordinary creativity, but not
`
`an automaton, and that a POSITA can often fit multiple patents or prior art references
`
`together like pieces of a puzzle as a result of this ordinary creativity. I also
`
`understand that I may consider the inferences and creative steps that a POSITA
`
`would employ. In addition, I understand that a POSITA would necessarily have been
`
`capable of understanding the scientific and engineering principles applicable to the
`
`pertinent art. I also understand that when I consider what would have been obvious
`
`to a POSITA, I am not considering what would have been obvious to me at the time,
`
`nor to the inventors, judges, laymen, those skilled in other arts, or to geniuses in
`
`
`
`
`
`
`-5-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`the art.
`
`17. Based on my review and analysis of the Challenged Patent, the prior art
`
`cited herein, and the ordinary skill factors described in this section, in my opinion,
`
`POSITA working in the field of liquid cooling systems for computer systems as of
`
`the claimed priority date (May 6, 2005) would have been knowledgeable regarding
`
`liquid cooling systems for computer systems, would have had a Bachelor of Science
`
`(B.S.) in electrical or mechanical engineering, or similar advanced post-graduate
`
`education in this area, or would have possessed at least 2-3 years of experience in
`
`liquid cooling systems for computer systems or similar systems. (See, e.g., Ex-1001
`
`at 1:11-47 (describing the “Background of the Invention” of the ’764 patent).) A
`
`POSITA would be knowledgeable of the concepts, components, and their functions
`
`described as “prior art” in the ’764 patent such as, for example, liquid pumps, heat
`
`radiators, air fans, reservoirs, and other techniques of heat dissipation and liquid
`
`cooling. (Id.) In addition, a POSITA would be knowledgeable about electric motors
`
`and their components such as, for example, electromagnetic coils, rotors, stators, AC
`
`motors, DC motors, etc.
`
`18. A person with less education but more relevant practical experience,
`
`depending on the nature of that experience and degree of exposure to liquid cooling
`
`systems for computer systems could also qualify as a POSITA in the field of the
`
`
`
`
`
`
`-6-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`’764 patent.
`
`C. CLAIM CONSTRUCTION
`“reservoir”
`1.
`I understand that the parties have stipulated, in the pending district court
`
`19.
`
`action, to construe the term “reservoir,” as that term is used in the ’764 patent claims,
`
`to mean “single receptacle defining a fluid flow path.” (Ex-1005 at 2.)
`
`“chamber”
`2.
`I further understand that the parties have also stipulated to construe the
`
`20.
`
`term “chamber,” as that term is used in the ’764 patent claims, to mean
`
`“compartment within the reservoir. (Ex-1005 at 2.)
`
`“underside” and “upper side” of the “chassis”
`3.
`21. Claim 1 recites “a double-sided chassis adapted to mount a pump
`
`configured to circulate a cooling liquid, the pump comprising a stator and an
`
`impeller, the impeller being positioned on the underside of the chassis and the stator
`
`being positioned on the upper side of the chassis and isolated from the cooling
`
`liquid” (emphasis added). Thus, a POSITA would have understood the “upper side
`
`of the chassis” to mean the side isolated from the cooling liquid and the “underside
`
`of the chassis” to mean the other side contacting the cooling liquid.
`
`
`
`
`
`
`
`-7-
`
`
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 10 of 168
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`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`“below”
`4.
`22. The term “below” by itself appears in the following phrase in claim 1:
`
`“a pump chamber including the impeller and formed below the chassis[.]” Because
`
`the “impeller” is positioned on the underside of the chassis (i.e., the side contacting
`
`the cooling liquid) and included in the “pump chamber,” a POSITA would have
`
`understood the “pump chamber” to be “formed below the chassis” on the “underside
`
`of the chassis” contacting the cooling liquid.
`
`“below … vertically”
`5.
`23. The term “below … vertically” appears in the following phrase in claim
`
`1: “a thermal exchange chamber formed below the pump chamber and vertically
`
`spaced apart from the pump chamber[.]” Petitioner and Patent Owner have
`
`stipulated that “vertically spaced apart” means “vertically arranged (with reference
`
`to each other and the heat exchanging interface) chambers” (with “chamber”
`
`construed as above).” (Ex-1005 at 2.) Thus, a POSITA would have understood
`
`“below … vertically” to mean that the “thermal exchange chamber” is “formed
`
`below the pump chamber … vertically” with reference to each other and the heat
`
`exchanging interface.
`
`6. Other Terms
`24. As to other terms, a POSITA would have understood the plain and
`
`
`
`
`
`
`
`-8-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`ordinary meaning of the term “double-sided chassis” to be “two-sided frame or
`
`base.” To the extent applicable, I have rendered my opinions using these
`
`constructions. Although it is my understanding that district court claim construction
`
`proceedings are ongoing, for purposes of these IPRs, I believe no additional specific
`
`constructions are required; I understand that the other claim terms in these IPRs will
`
`be construed according to their ordinary and customary meaning. I further
`
`understand that the claims are read in light of the patent’s specification and that
`
`claims themselves often provide significant guidance as to the meaning of a
`
`particular term.
`
`IV. LEGAL STANDARDS
`I have been asked to opine on whether certain claims are either
`25.
`
`anticipated or rendered obvious by the prior art.
`
`26.
`
`I have been instructed that anticipation means that a single prior art
`
`reference discloses each claim element and discloses the arrangement of each claim
`
`element. To disclose a claim element, the prior art does not have to expressly spell
`
`out the claim element as along as a POSITA, reading the reference, would at once
`
`envisage the claimed arrangement or combination.
`
`27.
`
`I have been instructed that obviousness means that one or more prior
`
`art references disclose each claim element of a claim and that there must be an
`
`
`
`
`
`
`-9-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`apparent reason to combine the known elements to arrive at the claims. The analysis
`
`is a flexible one, accounting for the inferences and creative steps that a person of
`
`ordinary skill in the art would employ. The claims must be read as a whole when
`
`evaluating whether it is obvious.
`
`28.
`
`It is my understanding that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the alleged
`
`invention was made to a person of ordinary skill in the art to which the subject matter
`
`pertains. This is sometimes described as “obviousness.” I understand that an
`
`obviousness analysis considers the level of ordinary skill in the art, the scope and
`
`content of the prior art, and the differences between the prior art and the claimed
`
`subject matter. The analysis may also consider secondary considerations, such as
`
`commercial success, unmet but long felt need and failure of others.
`
`29.
`
`It is my understanding that court cases have recognized several
`
`rationales for combining references or modifying a reference to show obviousness
`
`of the claimed subject matter. Some of these rationales include the following:
`
`combining prior art elements according to known methods to yield predictable
`
`results; simple substitution of one known element for another to obtain predictable
`
`results; a predictable use of prior art elements according to their established
`
`
`
`
`
`
`-10-
`
`
`
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`functions; applying a known technique to a known device to yield predictable
`
`results; choosing from a finite number of identified, predictable solutions, with a
`
`reasonable expectation of success; and some teaching, suggestion, or motivation in
`
`the prior art that would have led a POSITA to modify the prior art or combine prior
`
`art teachings to arrive at the claimed invention.
`
`V. OVERVIEW OF THE ’764 PATENT
`30. The ’764 patent characterizes its field of invention as follows:
`
`“The present invention relates to a cooling system for a central processing
`
`unit (CPU) or other processing unit of a computer system. More
`
`specifically, the invention relates to a liquid-cooling system for a
`
`mainstream computer system such as a PC.” (Ex-1001 at 1:11-15.)
`
`31. The ’764 patent relates to a liquid-cooling system for a computer
`
`system. The specification purports to disclose embodiments of a liquid-cooling
`
`system that is more efficient, easier to use, and more compact with integrated
`
`components than prior art cooling systems. (Ex-1001 at 1:11-2:19.)
`
`32. The ’764 patent further states that these purported improvements may
`
`be achieved by having an integrated element comprising the heat exchange interface,
`
`the reservoir of cooling liquid, and the pump for pumping the cooling liquid. (Id. at
`
`1:51-2:31; claims 1-18.)
`
`
`
`
`
`
`-11-
`
`
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 14 of 168
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`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`33. The following figures capture the main characteristics of the purported
`
`invention claimed in the Challenged Claims.
`
`34. FIG. 7 is a perspective view of the
`
`cooling system showing the reservoir housing 14
`
`with the heat exchanging surface (not shown) and
`
`the pump (not shown) inside the reservoir. The
`
`tube
`
`inlet connection and
`
`the
`
`tube outlet
`
`connection are connected to a heat radiator by
`
`means of connecting tubes 24 and 25 through
`
`which the cooling liquid flows into and out of the
`
`reservoir and the heat radiator, respectively. Within the heat radiator 11, the cooling
`
`liquid passes a number of channels for conducting/convecting the heat, which has
`
`been dissipated into the cooling liquid inside the reservoir, and to the surroundings
`
`of the heat exchanger. The air fan 10 blows air past the channels of the heat radiator
`
`in order to cool the radiator and thereby cooling the cooling liquid flowing inside the
`
`channels through the heat radiator and back into the reservoir.” (Ex. 1001 at 15:61-
`
`16:7.)
`
`The internal structures of the claimed reservoir 14 are depicted in FIGS. 17 and 20
`
`reproduced below.
`
`
`
`
`
`
`-12-
`
`
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 15 of 168
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`
`
`
`
`35.
`
` The use of liquid cooling with what is sometimes referred to in the
`
`industry as an “all-in-one” cooler to cool semiconductor chips in computer systems
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`
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`
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`-13-
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`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 16 of 168
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`IPR2022-01317
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`was generally known to a person of ordinary skill in the art (“POSITA”) long before
`
`the claimed May 6, 2005 priority date of the ’764 patent, as evidence by Batchelder
`
`(filed May 18, 1998).
`
`36. The images below compare FIG. 20 of the ’764 patent with FIG. 2 of
`
`Batchelder:
`
`Reservoir
`
`’764 Patent
`
`
`
`Batchelder
`
`
`
`37. The use of a closed liquid cooling loop connecting an all-in-one cooler
`
`and a radiator with tubes was also generally known to a POSITA before the claimed
`
`priority date of the ’764 patent, as evidenced by Duan (Ex-1006) and Duan-I (Ex-
`
`1007). The images below compare FIG. 7 of the ’764 patent with FIG. 6 of Duan:
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`-14-
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`
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`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 17 of 168
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`Radiator
`
`Reservoir
`
`’764 Patent
`
`Duan
`
`
`
`38. The ’764 patent only discloses an embodiment of the known “all-in-
`
`one” coolers used in closed liquid cooling loops.
`
`
`
`VI. OVERVIEW OF PRIOR ART
`A. Duan (Ex-1006)
`39. Duan published as U.S. Patent Publication No. 2006/0185830 on
`
`August 24, 2006, from Application No. 11/060,442, which was filed on February
`
`
`
`
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`
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`-15-
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`
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`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 18 of 168
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`IPR2022-01317
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`18, 2005. My understanding is that Duan qualifies as prior art to the ’764 patent for
`
`all Challenged Claims.
`
`B. Duan I (Ex-1007)
`40. Duan I published as U.S. Patent Publication No. 2006/0185829 on
`
`August 24, 2006, from Application No. 11/060,419, which was filed on February
`
`18, 2005. My understanding is that Duan I qualifies as prior art to the ’764 patent
`
`for all Challenged Claims.
`
`C. Batchelder (Ex-1008)
`41. Batchelder issued as U.S. Patent No. 6,019,165 on February 1, 2000.
`
`(Ex-1006 at [11], [45].) My understanding is that Batchelder qualifies as prior art to
`
`the ’764 patent for all Challenged Claims.
`
`D. Laing (Ex-1015)
`42. Laing published as U.S. Patent Publication No. 2004/0052663 on
`
`March 18, 2004, from Application No. 10/434,307, which was filed on May 7, 2003.
`
`My understanding is that Laing qualifies as prior art to the ’764 patent for all
`
`Challenged Claim.
`
`
`
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`
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`-16-
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`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 19 of 168
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`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`VII. CLAIM ELEMENT NUMBERING KEY
`43. Because the Challenged Claims have similar claim elements, they are
`
`numbered as follows for the element-by-element invalidity analyses of the
`
`Challenged Claims that follows below.
`
`[1-PRE]
`1. A cooling system for a
`heat-generating component,
`comprising:
`
`[15-PRE]
`15. A cooling system for a
`heat-generating
`component, comprising:
`
`’764 Claim Limitations
`[10-PRE]
`10. A cooling system for a
`computer system, comprising:
`
`
`
`
`
`
`
`
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`
`
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`
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`-17-
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`
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`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 20 of 168
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`[1-a]
`a double-sided chassis
`adapted to mount a pump
`configured to circulate a
`cooling liquid, the pump
`comprising a stator and an
`impeller, the impeller being
`positioned on the underside of
`the chassis and the stator
`being positioned on the upper
`side of the chassis and
`isolated from the cooling
`liquid;
`(Claim 1)
`[1-b]
`a reservoir adapted to pass the
`cooling liquid therethrough,
`the reservoir including:
`(Claim 1)
`
`
`
`
`
`
`
`
`
`’764 Claim Limitations
`[10-a]
`a centrifugal pump adapted to
`circulate a cooling liquid, the
`pump including: an impeller
`exposed to the cooling liquid;
`and a stator isolated from the
`cooling liquid; (Claim 10)
`
`[15-a]
`a pump adapted to circulate
`a cooling liquid, the pump
`including: an impeller
`exposed to the cooling
`liquid; and a stator isolated
`from the cooling liquid;
`(Claim 15)
`
`
`[10-b]
`a reservoir configured to be
`thermally coupled to a heat-
`generating component of the
`computer system, the reservoir
`including:
`(Claim 10)
`
`
`[15-b]
`a reservoir including
`(Claim 15)
`
`[15-c]
`an impeller cover, an
`intermediate member and
`(Claim 15)
`
`-18-
`
`
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 21 of 168
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`IPR2022-01317
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`See [1-d] and [1-e] below
`
`[1-c]
`a pump chamber including the
`impeller and formed below
`the chassis, the pump
`chamber being defined by at
`least an impeller cover having
`one or more passages for the
`cooling liquid to pass
`through;
`(Claim 1)
`
`’764 Claim Limitations
`[10-c]
`a thermal exchange chamber
`adapted to be positioned in
`thermal contact with the heat-
`generating component;
`(Claim 10)
`[10-d]
`a separate pump chamber
`vertically spaced part from the
`thermal exchange chamber and
`coupled with the thermal
`exchange chamber through one
`or more passages configured for
`fluid communication between
`the pump chamber and the
`thermal exchange chamber, and
`
`
`
`[15-e]
`wherein a top wall of the
`reservoir and the impeller
`cover define a pump
`chamber for housing the
`impeller, and the
`intermediate member and
`the heat exchange interface
`define a thermal exchange
`chamber, the pump
`
`
`
`
`
`
`
`-19-
`
`
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 22 of 168
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`IPR2022-01317
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`’764 Claim Limitations
`(Claim 10)
`
`
`[1-d]
`a thermal exchange chamber
`formed below the pump
`chamber and vertically spaced
`apart from the pump chamber,
`the pump chamber and the
`thermal exchange chamber
`being separate chambers that
`are fluidly coupled together
`by the one or more passages;
`and
`(Claim 1)
`See Claim 6 below
`
`See [1-a] above
`
`chamber and the thermal
`exchange chamber being
`spaced apart from each
`other in a vertical direction
`and fluidly coupled
`together; and
`(Claim 15)
`
`
`
`
`
`[10-e]
`wherein at least one of the one or
`more passages is offset from a
`center of the impeller.
`(Claim 10)
`
`11. The cooling system of claim
`10, wherein a top wall of the
`reservoir physically separates the
`impeller from the stator.
`
`
`
`
`
`
`
`
`-20-
`
`
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`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 23 of 168
`Shenzhen Apaltek Co., Ltd. v. Asetek Danmark A/S
`IPR2022-01317
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`

`

`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`[1-e]
`a heat-exchanging interface,
`the heat-exchanging interface
`forming a boundary wall of
`the thermal exchange
`chamber, and configured to be
`placed in thermal contact with
`a surface of the heat-
`generating component; and
`(Claim 1)
`
`[1-f]
`a heat radiator fluidly coupled
`to the reservoir and
`configured to dissipate heat
`from the cooling liquid.
`(Claim 1)
`
`
`
`
`
`
`
`
`
`’764 Claim Limitations
`12. The cooling system of claim
`10, wherein the thermal
`exchange chamber includes a
`heat-exchange interface
`configured to be placed in
`thermal contact with the heat-
`generating component.
`
`13. The cooling system of claim
`10, further including a heat
`radiator fluidly coupled to the
`reservoir using flexible conduits,
`wherein the heat radiator is
`configured to be positioned
`remote from the reservoir.
`
`See Claim 9 below
`
`
`-21-
`
`
`
`[15-d]
`wherein a first side of the
`heat-exchanging interface
`is in contact with a cooling
`liquid in the thermal
`exchange chamber and a
`second side of the heat-
`exchanging interface
`opposite the first side is
`configured to be placed in
`thermal contact with a
`surface of the heat-
`generating component; and
`(Claim 15)
`[15-f]
`a liquid-to-air heat
`exchanger fluidly coupled
`to the reservoir using
`flexible conduits, the heat
`exchanger being
`configured to be positioned
`remote from the reservoir.
`(Claim 15)
`
`
`Shenzhen Apaltek Co., Ltd. Ex. 1003, Page 24 of 168
`Shenzhen Apaltek Co., Ltd. v. Asetek Danmark