Filed on behalf of: Eve Energy Co., Ltd..
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`INTER PARTES REVIEW
`
`U.S. Patent Nos.
`9,153,835
`9,496,581
`9,799,913
`
`Eve Energy Co., Ltd.
`Petitioner
`
`v.
`
`VARTA MICROBATTERY GMBH
`Patent Owner
`_____________
`
`Case Nos.
`IPR2022- 01484
`IPR2022- 01486
`IPR2022- 01487
`
`DECLARATION OF MARC JUZKOW
`
`VARTA Ex. 2013 Page 1 of 5
`EVE Energy v. VARTA
`IPR2022-01484
`
`Eve Energy Co., Ltd v. Varta Microbattery Gmbh
`
`Eve Ex. 1002, p. 1
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`INTER PARTES REVIEW
`
`U.S. Patent Nos.
`9,153,835
`9,496,581
`9,799,913
`
`Eve Energy Co., Ltd.
`Petitioner
`
`v.
`
`VARTA MICROBATTERY GMBH
`Patent Owner
`_____________
`
`Case Nos.
`IPR2022- 01484
`IPR2022- 01486
`IPR2022- 01487
`
`DECLARATION OF MARC JUZKOW
`
`VARTA Ex. 2013 Page 1 of 5
`EVE Energy v. VARTA
`IPR2022-01484
`
`Eve Energy Co., Ltd v. Varta Microbattery Gmbh
`
`Eve Ex. 1002, p. 1
`
`
`
`144. Kobayashi further discloses various compositions for the insulating members,
`
`such as “polyethylene or polypropylene resin, a film made of PET or polyimide, or the
`
`like.” Id. A POSITA would further understand that, beyond the specific materials disclosed
`
`by Kobayashi, a variety of materials can be used as this insulating member, including
`
`plastic polymers, such as polyolefin (such as polypropylene or polyethylene), polyester,
`
`polyimide (such as Kapton), and fluoropolymers, as discussed in §IX.A.1.d.
`
`145.
`
`I further note that this claim is directed to an insulating means arranged
`
`“between the end faces of the spiral winding and the housing cup and the housing top.”
`
`(Emphasis added). This suggests that the insulating means according to the ‘835 patent is
`
`the same on the top end face of the spiral winding and the bottom face of the spiral winding.
`
`Kobayashi still discloses this configuration, as the insulating plates disclosed are made of
`
`the same material, are in the same shape, and are arranged between both the housing cup
`
`and the housing top.
`
`k.
`
`Combining Kobayashi, Kaun, and Brenner would have been obvious to
`the POSITA
`146. A POSITA would have been motivated to combine the teachings of
`
`Kobayashi and Kaun. Kobayashi and Kaun both share the common objective of improving
`
`button cells and related types of batteries without sacrificing longevity or efficiency. For
`
`example, Kaun provides:
`
`a button-type cell enclosure. Consisting of two opposing shallow cups,
`
`which are electrically isolated from each other with a polymeric “U”
`
`- 70 -
`
`VARTA Ex. 2013 Page 2 of 5
`
`Eve Energy Co., Ltd v. Varta Microbattery Gmbh
`
`Eve Ex. 1002, p. 71
`
`
`
`shaped gasket at the outer edge. The gasket further forms a gas-tight
`
`seal for the interior contents of the cell. These cup members interface
`
`with the perpendicular electrode member of another electrochemical
`
`cell to serve as both an output conductor and a cell terminal. The
`
`positive electrode substrate is essentially of the same material as the
`
`positive terminal surface and the negative electrode substrate is
`
`essentially of the same material as the negative terminal surface. The
`
`positive is generally aluminum and the negative is generally copper.
`
`The Rolled-Ribbon cell assembly is a disc that is slightly wider that the
`
`distance between the parallel surfaces of the assembled current-
`
`collector cups to assure contact with the electrode foil substrates.
`
`Ex. 1023 (Kaun) at [0072]. Similarly, Kobayashi is directed
`
`to provid[ing] a small battery capable of improving a heavy load
`
`characteristic without impairing productivity. . . . The present inventors
`
`have found a method of safely and highly productively storing a wound
`
`electrode group in a case of a small battery such as a button shape or a
`
`coin shape.
`
`[A] container having a sealing structure is used in which a metallic
`
`negative electrode case serving as a negative electrode terminal and a
`
`- 71 -
`
`VARTA Ex. 2013 Page 3 of 5
`
`Eve Energy Co., Ltd v. Varta Microbattery Gmbh
`
`Eve Ex. 1002, p. 72
`
`
`
`metallic positive electrode case serving as a positive electrode terminal
`
`are fitted via an insulating gasket.
`
`Ex. 1004 (Kobayashi) at [0012]-[0013].
`
`147. Based on my review of these references, Kobayashi is directed to the same
`
`subject matter disclosed in Kaun – Button-cell batteries with spiral wound electrode
`
`assemblies enclosed within a cell housing. Compare Ex. 1004 (Kobayashi) at [0013] (“It
`
`has been found that a small battery excellent in heavy load characteristics can be provided
`
`by housing an electrode group in which a laminate including a positive electrode and a
`
`negative electrode is wound spirally in the container.”) with Ex. 1023 (Kaun) at [0048]
`
`(“This basic laminate cell preassembly is layered on itself, such as by winding or coiling it
`
`in a spiral to form an electrode assembly in the general shape of a flat disc (wherein the
`
`diameter is preferably greater than twice the thickness of the disk). The cell membrane is
`
`sandwiched between plate-like current collectors with the electrode interfaces primarily
`
`perpendicular to the current collectors to make up an electrochemical cell.”).
`
`148.
`
`Instead of beading, Kaun uses an insert molded gasket placed between
`
`housing top 28p and cup 28n to provide a gas-tight seal. Ex. 1023, [0116]. As discussed
`
`above, Kaun provides a sealing mechanism that closes the button cell without being beaded
`
`over. Supra §IX.A.1.f. Using insulator/gasket 32 allows for sealing of the button cell using
`
`a housing cup whose edge remains essentially perpendicular to its flat bottom area. Ex.
`
`1023, FIG. 7.
`
`- 72 -
`
`VARTA Ex. 2013 Page 4 of 5
`
`Eve Energy Co., Ltd v. Varta Microbattery Gmbh
`
`Eve Ex. 1002, p. 73
`
`
`
`149. As can be seen clearly in FIG. 1 of Kobayashi (annotated below), a significant
`
`portion of the available space within the cell is reduced by the process of crimping the cell
`
`closed. The process of crimping the cell closed can require significant extra space for the
`
`cell housing, but such space cannot be used for active materials, thus reducing the overall
`
`volumetric energy density of the cell.
`
`150. A POSITA would have been motivated to alter the housing of Kobayashi so
`
`as to incorporate the non-beaded over sealing features of the Kaun cell housing. A benefit
`
`is that the button cell of Kaun, which is sealed without being beaded over, allows for greater
`
`internal space to contain the electrode assembly, meaning that more electrode layers can
`
`be included in a button cell of a given diameter that is closed without being beaded over
`
`(i.e., according to Kaun) than one that is closed by being beaded over (i.e. according to
`
`Kobayashi).
`
`151. A POSITA would have also understood that it would be preferred to have the
`
`inner lateral side of the housing flat from top to bottom to absorb uniform radial forces
`
`from the expansion of the electrodes in the spiral winding, as provided by Kaun.
`
`- 73 -
`
`VARTA Ex. 2013 Page 5 of 5
`
`Eve Energy Co., Ltd v. Varta Microbattery Gmbh
`
`Eve Ex. 1002, p. 74
`
`
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