Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.507 Filed 06/27/22 Page 1 of 18
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`SCRAMOGE TECHNOLOGY LTD.,
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`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`Case No. 2:22-cv-10730-GAD-APP
`
`
`
`
`
`v.
`
`JURY TRIAL DEMANDED
`
`VOLKSWAGEN GROUP OF
`AMERICA, INC.,
`
`
`
`
`
`
`
`Defendant.
`
`
`
`
`
`
`AMENDED COMPLAINT FOR PATENT INFRINGEMENT AGAINST
`VOLKSWAGEN GROUP OF AMERICA, INC.
`This is an action for patent infringement arising under the Patent Laws of the
`
`United States of America, 35 U.S.C. § 1 et seq., in which Plaintiff Scramoge
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`Technology Limited (“Plaintiff” or “Scramoge”) makes the following allegations
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`against Defendant Volkswagen Group of America, Inc. (“Defendant” or
`
`“Volkswagen”):
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`INTRODUCTION
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`1.
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`This amended complaint arises from Volkswagen’s unlawful
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`infringement of the following United States patents owned by Plaintiff, which relate
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`to improvements in wireless charging of mobile devices: United States Patent Nos.
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`Page 1 of 47
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`Volkswagen Exhibit 1016
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.508 Filed 06/27/22 Page 2 of 18
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`
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`10,546,685 (“the ’685 Patent”), 10,193,392 (“the ’392 Patent”), 7,825,537 (“the ’537
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`Patent”), and 10,243,400 (“the ’400 Patent”) (collectively, the “Asserted Patents”).
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`PARTIES
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`2.
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`Plaintiff Scramoge Technology Ltd. is a limited liability company
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`organized and existing under the law of Ireland, with its principal place of business
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`at The Hyde Building, Suite 23, The Park, Carrickmines, Dublin 18, Ireland.
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`Scramoge is the sole owner by assignment of all right, title, and interest in the
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`Asserted Patents, including the right to recover damages for past, present, and future
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`infringement.
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`3.
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`On information and belief, Volkswagen is a corporation organized and
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`existing under the laws of New Jersey, with a corporate headquarters located in
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`Herndon, Virginia. Volkswagen also has a place of business at 3800 Hamlin Rd.,
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`Auburn Hills, MI 48326. On information and belief, Defendant Volkswagen of
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`America, Inc. is a wholly owned subsidiary of Volkswagen AG and is responsible
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`for importing, making, marketing, distributing, offering for sale, and selling
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`automotive vehicles and components from Volkswagen-managed brands in the
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`United States. Volkswagen is registered to do business in Michigan and may be
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`served through its resident agent for service of process CSC-Lawyers Incorporating
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`Service, 2900 West Road (Ste 500), East Lansing, MI 48823.
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`2
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`Page 2 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.509 Filed 06/27/22 Page 3 of 18
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`JURISDICTION AND VENUE
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`4.
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`This action arises under the patent laws of the United States, Title 35 of
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`the United States Code. This Court has original subject matter jurisdiction pursuant
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`to 28 U.S.C. §§ 1331 and 1338(a).
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`5.
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`This Court has personal jurisdiction over Volkswagen in this action
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`because Volkswagen has committed acts within this District giving rise to this action
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`and has established minimum contacts with this forum such that the exercise of
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`jurisdiction over Volkswagen would not offend traditional notions of fair play and
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`substantial justice. Volkswagen, directly and through subsidiaries or intermediaries,
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`has committed and continues to commit acts of infringement in this District by,
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`among other things, importing, offering to sell, and selling products that infringe the
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`Asserted Patents. Further, this Court has personal jurisdiction over Volkswagen
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`because it is registered to do business in Michigan and has a corporate location in
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`Auburn Hills, MI.
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`6.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b).
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`Upon information and belief, Volkswagen has transacted business in this District
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`and has committed acts of direct and indirect infringement in this District by, among
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`other things, making, using, offering to sell, selling, and importing products that
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`infringe the Asserted Patents. Volkswagen has a regular and established place of
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`business in this District at 3800 Hamlin Rd., Auburn Hills, MI 48326. Volkswagen.
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`3
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`Page 3 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.510 Filed 06/27/22 Page 4 of 18
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`has also previously agreed that this District is a proper venue. See StratisAudio, Inc.
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`v. Volkswagen Grp. Of Am., Inc., No. 6:20-cv-1131-ADA, Dkt. No. 16 at 5 (W.D.
`
`Tex. Feb. 19, 2021).
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`COUNT I
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`INFRINGEMENT OF U.S. PATENT NO. 10,546,685
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`7.
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`Plaintiff realleges and incorporates by reference the foregoing
`
`paragraphs as if fully set forth herein.
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`8.
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`Plaintiff owns by assignment all rights, title, and interest, including the
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`right to recover damages for past, present, and future infringement, in U.S. Patent
`
`No. 10,546,685, titled “Wireless power transmitting apparatus.” The ’685 Patent
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`was duly and legally issued by the United States Patent and Trademark Office on
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`January 28, 2020. A true and correct copy of the ’685 Patent is attached as Exhibit
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`A.
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`9.
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`On information and belief, Volkswagen makes, uses, offers for sale,
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`sells, and/or imports certain automobiles with a wireless charger, including without
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`limitation the Volkswagen Antenna Booster (5NA980611) included in the
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`Volkswagen Golf R, Volkswagen Golf GTI, Volkswagen ID.4, Volkswagen Atlas,
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`Volkswagen Atlas Cross Sport, Volkswagen Tiguan, Volkswagen Jetta,
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`Volkswagen Arteon, and Volkswagen Taos (“Accused Products”), that directly
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`infringe, literally and/or under the doctrine of equivalents, one or more claims of
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`
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`4
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`Page 4 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.511 Filed 06/27/22 Page 5 of 18
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`
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`the ’685 Patent. Identification of the accused products will be provided in Plaintiff’s
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`infringement contentions pursuant to the Court’s scheduling order.
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`10. The Accused Products satisfy all claim limitations of one or more
`
`claims of the ’685 Patent. A claim chart comparing exemplary independent claim 1
`
`of the ’685 Patent to representative Accused Products is attached as Exhibit B.
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`11. By making, using, offering for sale, selling and/or importing into the
`
`United States the Accused Products, Volkswagen has injured Plaintiff and is liable
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`for infringement of the ’685 Patent pursuant to 35 U.S.C. § 271(a).
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`12. As a result of Volkswagen’s infringement of the ’685 Patent, Plaintiff
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`is entitled to monetary damages (past, present, and future) in an amount adequate to
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`compensate for Volkswagen’s infringement, but in no event less than a reasonable
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`royalty for the use made of the invention by Volkswagen, together with interest and
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`costs as fixed by the Court.
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`COUNT II
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`INFRINGEMENT OF U.S. PATENT NO. 10,193,392
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`13. Plaintiff realleges and incorporates by reference the foregoing
`
`paragraphs as if fully set forth herein.
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`14. Plaintiff owns by assignment all rights, title, and interest, including the
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`right to recover damages for past, present, and future infringement, in U.S. Patent
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`No. 10,193,392, titled “Wireless power transfer device and wireless power transfer
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`
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`5
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`Page 5 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.512 Filed 06/27/22 Page 6 of 18
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`
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`system.” The ’392 Patent was duly and legally issued by the United States Patent
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`and Trademark Office on January 29, 2019. A true and correct copy of the ’392
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`Patent is attached as Exhibit C.
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`15. On information and belief, Volkswagen makes, uses, offers for sale,
`
`sells, and/or imports certain automobiles with a wireless charger, including without
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`limitation the Volkswagen Antenna Booster (5NA980611) included in the
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`Volkswagen Golf R, Volkswagen Golf GTI, Volkswagen ID.4, Volkswagen Atlas,
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`Volkswagen Atlas Cross Sport, Volkswagen Tiguan, Volkswagen Jetta,
`
`Volkswagen Arteon, and Volkswagen Taos (“Accused Products”), that directly
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`infringe, literally and/or under the doctrine of equivalents, one or more claims of
`
`the ’392 Patent. Identification of the accused products will be provided in Plaintiff’s
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`infringement contentions pursuant to the Court’s scheduling order.
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`16. The Accused Products satisfy all claim limitations of one or more
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`claims of the ’392 Patent. A claim chart comparing exemplary independent claim 1
`
`of the ’392 Patent to representative Accused Products is attached as Exhibit D.
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`17. By making, using, offering for sale, selling and/or importing into the
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`United States the Accused Products, Volkswagen has injured Plaintiff and is liable
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`for infringement of the ’392 Patent pursuant to 35 U.S.C. § 271(a).
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`18. As a result of Volkswagen’s infringement of the ’392 Patent, Plaintiff
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`is entitled to monetary damages (past, present, and future) in an amount adequate to
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`6
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`Page 6 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.513 Filed 06/27/22 Page 7 of 18
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`compensate for Volkswagen’s infringement, but in no event less than a reasonable
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`royalty for the use made of the invention by Volkswagen, together with interest and
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`costs as fixed by the Court.
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`COUNT III
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`INFRINGEMENT OF U.S. PATENT NO. 7,825,537
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`19. Plaintiff realleges and incorporates by reference the foregoing
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`paragraphs as if fully set forth herein.
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`20. Plaintiff owns by assignment all rights, title, and interest, including the
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`right to recover damages for past, present, and future infringement, in U.S. Patent
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`No. 7,825,537, entitled “Inductive power transfer system and method.” The ’537
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`Patent was duly and legally issued by the United States Patent and Trademark Office
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`on November 2, 2010. A true and correct copy of the ’537 Patent is attached as
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`Exhibit E.
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`21. On information and belief, Volkswagen makes, uses, offers for sale,
`
`sells, and/or imports certain automobiles with a wireless charger, including without
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`limitation the Volkswagen Antenna Booster (5NA980611) included in the
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`Volkswagen Golf R, Volkswagen Golf GTI, Volkswagen ID.4, Volkswagen Atlas,
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`Volkswagen Atlas Cross Sport, Volkswagen Tiguan, Volkswagen Jetta,
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`Volkswagen Arteon, and Volkswagen Taos (“Accused Products”), that directly
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`infringe, literally and/or under the doctrine of equivalents, one or more claims of
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`7
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`Page 7 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.514 Filed 06/27/22 Page 8 of 18
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`the ’537 Patent, including through Volkswagen’s own use and/or testing of the
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`Accused Products. Identification of the accused products will be provided in
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`Plaintiff’s infringement contentions pursuant to the Court’s scheduling order.
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`22. The Accused Products satisfy all claim limitations of one or more
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`claims of the ’537 Patent. A claim chart comparing exemplary independent claim 1
`
`of the ’537 Patent to representative Accused Products is attached as Exhibit F.
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`23. Volkswagen also knowingly and intentionally induces infringement of
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`one or more claims of the ’537 Patent in violation of 35 U.S.C. § 271(b). At least as
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`of April 8, 2022 (when Volkswagen was served with the original complaint),
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`Volkswagen has knowledge of the ’537 Patent and the infringing nature of the
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`Accused Products through, for example, the ’537 Patent claim chart served therewith.
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`Dkt. No. 6. Despite this knowledge of the ’537 Patent, Volkswagen continues to
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`actively encourage and instruct its customers and end users (for example, through
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`user manuals and online instruction materials on its website) to use the Accused
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`Products in ways that directly infringe the ’537 Patent. For example, Volkswagen
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`advertises that the Accused Products contain a “[w]ireless smartphone charger” to
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`transfer
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`power
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`to
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`compatible
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`devices.
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`
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`See,
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`e.g.,
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`Ex.
`
`I
`
`(https://www.vw.com/en/models/golf-
`
`r.html?modelId=CD1RMT&modelYear=2022&modelVersion=4&exteriorId=F14
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`+2T2T&interiorId=F56+++++OB&---=%7B%22models_golf-
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`8
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`Page 8 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.515 Filed 06/27/22 Page 9 of 18
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`
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`r sectiongroup 9747253 featureappsection 1921718042%22%3A%22%2F%3Fzi
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`p%3D%22%7D). Volkswagen also teaches its customers and end users how to use
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`the wireless phone charger in the exemplary 2021 Tiguan SEL model to inductively
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`charge a target unit, i.e., smartphone, in a manner that infringes one or more claims
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`of the ’537 Patent:
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`9
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`Page 9 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.516 Filed 06/27/22 Page 10 of 18
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`See Ex. J (https://knowyourvw.com/model/143/asset=7107). Specifically, through
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`its “Wireless Phone Charging” tutorial video, Volkswagen provides detailed
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`instructions its customers and end users of, inter alia, (1) the location of the accused
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`wireless charger in the exemplary 2021 Tiguan SEL (or other models), (2) how to
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`prepare a smartphone for charging (for example, by removing objects that may
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`“interfere with the device’s placement on the charging surface”), (3) that a “phone
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`symbol” on the charger represents the “center position” for the wireless charging
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`function, (4) that to charge a smartphone, a user should place a compatible handset
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`“flat in the center of the charging shelf facing up,” and (5) other recommendations
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`for customers and end users for optimal use of the accused wireless charging
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`functionality. See Ex. J (https://knowyourvw.com/model/143/asset=7107). Despite
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`Page 10 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.517 Filed 06/27/22 Page 11 of 18
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`Scramoge’s prior allegations in its original complaint that Volkswagen’s
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`instructional “Wireless Phone Charging” tutorial provides customers and end users
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`with detailed instructions on how to use the accused wireless charging functionality
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`in an infringing manner, Volkswagen continues to make this video widely accessible
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`on its website and elsewhere on the Internet. See Dkt. No. 1 at ¶ 24. Volkswagen
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`provides these instructions, user manuals, and other materials knowing and intending
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`(or with willful blindness to the fact) that its customers and end users will commit
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`these infringing acts. Volkswagen also continues to make, use, offer for sale, sell,
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`and/or import the Accused Products, despite its knowledge of the ’537 Patent,
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`thereby specifically intending for and inducing its customers to infringe the ’537
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`Patent through the customers’ normal and customary use of the Accused Products.
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`24. Volkswagen has also infringed, and continues to infringe, one or more
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`claims of the ’537 Patent by selling, offering for sale, or importing into the United
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`States, the Accused Products, knowing that the Accused Products constitute a
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`material part of the inventions claimed in the ’537 Patent, are especially made or
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`adapted to infringe the ’537 Patent, and are not staple articles or commodities of
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`commerce suitable for non-infringing use. At least as of April 8, 2022 (when
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`Volkswagen was served with the original complaint), Volkswagen has knowledge
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`of the ’537 Patent and the infringing nature of the Accused Products through, for
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`example, the ’537 Patent claim chart served therewith. Dkt. No. 6. Volkswagen has
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`Page 11 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.518 Filed 06/27/22 Page 12 of 18
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`been, and currently is, contributorily infringing the ’537 Patent in violation of 35
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`U.S.C. §§ 271(c) and/or (f). For example, Volkswagen advertises that the Accused
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`Products contain a “[w]ireless smartphone charger” to transfer power to compatible
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`devices.
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`
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`See,
`
`e.g.,
`
`Ex.
`
`I
`
`(https://www.vw.com/en/models/golf-
`
`r.html?modelId=CD1RMT&modelYear=2022&modelVersion=4&exteriorId=F14
`
`+2T2T&interiorId=F56+++++OB&---=%7B%22models golf-
`
`r sectiongroup 9747253 featureappsection 1921718042%22%3A%22%2F%3Fzi
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`p%3D%22%7D). Volkswagen also provides its customers and end users with a
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`detailed instructional video that provides step-by-step instructions on how to use the
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`accused wireless charging functionality in an infringing manner. See Ex. J
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`(https://knowyourvw.com/model/143/asset=7107). Volkswagen’s wireless chargers
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`are base units that constitute a material part of the inventions claimed in the ’537
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`Patent, are especially made or adapted to infringe the ’537 Patent, and are not staple
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`articles or commodities of commerce suitable for non-infringing use. For example,
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`there are no non-infringing uses for the wireless charging functionality in the
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`Accused Products other than to inductively transfer power to a target unit in an
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`infringing manner.
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`25. By making, using, offering for sale, selling and/or importing into the
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`United States the Accused Products, Volkswagen has injured Plaintiff and is liable
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`12
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`Page 12 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.519 Filed 06/27/22 Page 13 of 18
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`for infringement of the ’537 Patent pursuant to 35 U.S.C. § 271(a), (b), (c), and/or
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`(f).
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`26. As a result of Volkswagen’s direct infringement of the ’537 Patent,
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`Plaintiff is entitled to monetary damages (past, present, and future) in an amount
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`adequate to compensate for Volkswagen’s infringement, but in no event less than a
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`reasonable royalty for the use made of the invention by Volkswagen, together with
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`interest and costs as fixed by the Court.
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`27. As a result of Volkswagen’s indirect infringement of the ’537 Patent,
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`Plaintiff is entitled to monetary damages (present and future) in an amount adequate
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`to compensate for Volkswagen’s infringement, but in no event less than a reasonable
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`royalty for the use made of the invention by Volkswagen, together with interest and
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`costs as fixed by the Court, accruing as of the time Volkswagen obtained knowledge
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`of the ’537 Patent on or before April 8, 2022.
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`COUNT IV
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`INFRINGEMENT OF U.S. PATENT NO. 10,243,400
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`28.
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`Plaintiff realleges and incorporates by reference the foregoing
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`paragraphs as if fully set forth herein.
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`29.
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`Plaintiff owns by assignment all rights, title, and interest, including the
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`right to recover damages for past, present, and future infringement, in U.S. Patent
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`No. 10,243,400, titled “Wireless power transmitter.” The ’400 Patent was duly and
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`13
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`Page 13 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.520 Filed 06/27/22 Page 14 of 18
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`legally issued by the United States Patent and Trademark Office on March 26, 2019.
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`A true and correct copy of the ’400 Patent is attached as Exhibit G.
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`30. On information and belief, Volkswagen makes, uses, offers for sale,
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`sells, and/or imports certain automobiles with a wireless charger, including without
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`limitation the Volkswagen Antenna Booster (5NA980611) included in the
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`Volkswagen Golf R, Volkswagen Golf GTI, Volkswagen ID.4, Volkswagen Atlas,
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`Volkswagen Atlas Cross Sport, Volkswagen Tiguan, Volkswagen Jetta,
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`Volkswagen Arteon, and Volkswagen Taos (“Accused Products”), that directly
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`infringe, literally and/or under the doctrine of equivalents, one or more claims of
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`the ’400 Patent. Identification of the accused products will be provided in Plaintiff’s
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`infringement contentions pursuant to the Court’s scheduling order.
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`31. The Accused Products satisfy all claim limitations of one or more
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`claims of the ’400 Patent. A claim chart comparing exemplary independent claim 1
`
`of the ’400 Patent to representative Accused Products is attached as Exhibit H.
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`32. By making, using, offering for sale, selling and/or importing into the
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`United States the Accused Products, Volkswagen has injured Plaintiff and is liable
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`for infringement of the ’400 Patent pursuant to 35 U.S.C. § 271(a).
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`33. As a result of Volkswagen’s infringement of the ’400 Patent, Plaintiff
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`is entitled to monetary damages (past, present, and future) in an amount adequate to
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`compensate for Volkswagen’s infringement, but in no event less than a reasonable
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.521 Filed 06/27/22 Page 15 of 18
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`royalty for the use made of the invention by Volkswagen, together with interest and
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`costs as fixed by the Court.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff respectfully requests that this Court enter:
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`a. A judgment in favor of Plaintiff that Volkswagen has infringed, either
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`literally and/or under the doctrine of equivalents, the ’685, ’392, ’537, and ’400
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`Patents;
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`b.
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`A judgment and order requiring Volkswagen to pay Plaintiff its
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`damages (past, present, and future), costs, expenses, and pre-judgment and post-
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`judgment interest for Volkswagen’s infringement of the ’685, ’392, ’537, and ’400
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`Patents;
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`c.
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`A judgment and order requiring Volkswagen to pay Plaintiff
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`compulsory ongoing licensing fees, as determined by the Court in equity.
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`d.
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`A judgment and order requiring Volkswagen to provide an accounting
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`and to pay supplemental damages to Plaintiff, including without limitation, pre-
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`judgment and post-judgment interest and compensation for infringing products
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`released after the filing of this case that are not colorably different from the accused
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`products;
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`e.
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`A judgment and order finding that this is an exceptional case within the
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`meaning of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.522 Filed 06/27/22 Page 16 of 18
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`against Volkswagen; and
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`f.
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`Any and all other relief as the Court may deem appropriate and just
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`under the circumstances.
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`DEMAND FOR JURY TRIAL
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`Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a
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`trial by jury of any issues so triable by right.
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`Dated: June 27, 2022
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`Respectfully submitted,
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`
`
`/s/ Brett Cooper
`Brett E. Cooper (NY SBN 4011011)
`bcooper@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`Seth Hasenour (TX SBN 24059910)
`shasenour@raklaw.com
`Drew B. Hollander (NY SBN 5378096)
`dhollander@raklaw.com
`Reza Mirzaie (CA SBN 246953)
`rmirzaie@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Catherine T. Dobrowitksy
`RIVENOAK LAW GROUP, P.C.
`3331 W. Big Beaver Rd., Suite 109
`Troy, MI 48084
`(248) 677-1045
`ecf@rivenoaklaw.com
`P63245
`
`
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`Attorneys for Plaintiff Scramoge
`Technology Limited
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`Case 2:22-cv-10730-GAD-APP ECF No. 26, PageID.524 Filed 06/27/22 Page 18 of 18
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`CERTIFICATE OF SERVICE
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`I hereby certify that on June 27, 2022, I electronically filed using the
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`CM/ECF system, which will send notification of such filing to all parties of record
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`via the ECF system.
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`
`/s/ Brett Cooper
`Brett E. Cooper (NY SBN 4011011)
`bcooper@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff Scramoge
`Technology Limited
`
`
`
`18
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`Page 18 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PageID.613 Filed 06/27/22 Page 1 of 29
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`EXHIBIT F
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`Page 19 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.614 Filed 06/27/22 Page 2 of 29
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`U.S. Patent No. 7,825,537 (“’537 Patent’’)
`
`Accused Products
`Volkswagen products, including without limitation the Volkswagen Antenna Booster (SNA980611) included in the Volkswagen
`Golf R, Volkswagen Golf GTI, Volkswagen ID.4, Volkswagen Atlas, Volkswagen Atlas Cross Sport, Volkswagen Tiguan, Volkswagen
`Jetta, Volkswagen Arteon, and Volkswagen Taos(“Accused Products”), infringe at least Claim | of the ’537 Patent.
`
`Claim 1
`
`To the extent the preamble is limiting, each Accused Productincludes a method for inductively
`[lpre] A method for
`inductively transferring power|transferring power from a base unit providing input power,to a target unit providing output
`from a base unit providing
`power, wherethe base unit and the target unitare electrically isolated.
`input power, to a target unit
`providing output power, where
`the base unit and the target
`unit are electrically isolated,
`comprising:
`
`See, é.g.:
`
`Target unit
`
`Base unit
`
`target unit within a
`
`Photograph of the Volkswagen Antenna Booster showing the base unit for inductively transferring
`powerto an electrically isolated target unit.
`
`[la] positioning a second
`inductive elementof said
`
`Each Accused Product comprises positioning a second inductive elementof said target unit within
`a predetermineddistance ofa first inductive element of said base unit.
`
`Page 20 of 47
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`

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`For example, the exemplary Volkswagen Antenna Boosterincludes a coil, which comprises the
`predetermineddistance of a
`first inductive element of said|first inductive element of the base unit. A covering positions the second inductive elementof the
`base unit:
`target unit within a predetermined distance of the first inductive element of the base unit.
`
`See, e.g.:
`
`Antenna Booster.
`
`Photograph of the covering for positioning a second inductive element of the target unit within a
`predetermineddistance ofa first inductive element of the base unit for the exemplary Volkswagen
`
`Page 21 of 47
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.616 Filed 06/27/22 Page 4 of 29
`
`Accused Products
`
`Volkswagen Antenna Booster.
`
`X-ray of the coils comprising the first inductive element inside the base unit from the exemplary
`
`First inductive element
`
`Page 22 of 47
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.617 Filed 06/27/22 Page 5 of 29
`
`See, é.g.:
`
`Photograph of the exemplary Volkswagen Antenna Booster showing howthe covering positions
`the second inductive elementof the target unit within a predetermineddistance ofthe first
`inductive element of the base unit.
`Each Accused Product comprises applying a time varying electric currentto said first inductive
`[1b] applying a time varying
`element to produce a time varying magnetic field, said time varying magnetic field induces an
`electric current to said first
`inductive element to produce a|electric current in said second inductive element.
`time varying magneticfield,
`said time varying magnetic
`field inducesanelectric
`current in said second
`inductive element;
`
`Target unit
`
`Base unit
`
`Page 23 of 47
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.618 Filed 06/27/22 Page 6 of 29
`
`SIGLENT
`
`M 2.00us/ Delay:0.00s
`
`Accused Products
`
`See, e.g.:
`
`Oscilloscope measurementofthe time varyingelectric current inthe first inductive element from
`the exemplary Volkswagen Antenna Booster. The current produces a time varying magneticfield,
`whichinducesanelectric current in the second inductive elementofthe target unit.
`
`eh
`
`Di g-1eice) ay
`
`Event Num
`
`[1c] monitoring at least one
`parameterindicative of an
`efficiency of powertransfer
`fromsaid base unitto said
`target unit;
`
`Each Accused Product comprises monitoring at least one parameterindicative of anefficiency of
`powertransfer fromsaid base unit to said target unit.
`
`For example, the exemplary Volkswagen Antenna Booster includes a NXP WCT1001 Wireless
`PowerTransmitter IC, which monitors at least a voltage and current associated withthefirst
`inductive elementin the base unit.
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`Page 24 of 47
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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.619 Filed 06/27/22 Page 7 of 29
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`=©,omralieaol-
`
`Volkswagen Antenna Booster.
`
`ed
`wu
`
`Ty
`oe
`
`aeitabi2 TS
`O {tm
`Photograph ofthe NXP WCT1001 Wireless Power Transmitter IC on the PCB of the exemplary
`
`1
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`Page 25 of 47
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.620 Filed 06/27/22 Page 8 of 29
`
`4.1 Functional Block Diagram
`
`This functional block diagram just shows the commonpin assignmentinformation by all members ofthe
`family. For the detailed pin multiplexing information, refer to Section 4.4 “Pin Function Description”.
`
`2) RAIL_vOX
`(29) IN_VOL
`= RAIL_CURR
`Up) TEMP_Main
`ir
`12) TEMP_COILL
`[13] TEMP_COn2
`x
`[14] Temp_cons
`-—~
`scik
`=p canon
`SPI & CAN
`mMosi
`CAN_TX
`CAN_RX
`L601
`(50) PMA_ADM
`Le02
`| .
`st,
`EXTAL
`(3)
`PORT
`"4 XTAL
`PORT2
`r
`PORTS
`PORTS
`4) Pw
`PORTS
`LED Indicators
`isa) Pwe2
`PORTE
`py
`&
`"17, COM_OIS
`PORT?|312)
`r
`Free Ports
`DC/OC &
`"43, COMO_EN
`PORTS
`Inverter
`"48 COM1_EN
`i
`PORTS
`PORTIO
`PORTIA
`PORTI2
`PORTI3
`
`sheet/WCT100XADSpdf
`
`r
`
`HC Interface
`and Low
`Power Control
`
`Interfaces
`
`(23)
`
`
`
`
`
`WCT1001/3A
`
`Faults
`Protection
`
`Analog
`Si
`ensing
`
`Demodulation
`
`|
`
`WPCDigital
`
`POA
`Decoding
`On-chip
`Oscillator
`
`52
`
`3)
`
`[as ]ex}—{04] 2] 3 [es] 2 Hs Ho Har Haz
`PRPS EERE
`
`Control
`
`"47, COM2_EN
`*U28) RAIL_CTRL
`*U2) DCDC_eN
`"20 DCDC_PG
`
`Figure 3. WCT1001/3AVLH Function Block Diagram
`
`Functional block diagram from the NXP WCT1001 Wireless Power Transmitter IC datasheet
`showingthatit includes an “analog sensing” unit that monitors a voltage and current associated
`with the first inductive elementin the base unit. Source: https://www-.nxp.com/docs/en/data-
`
`Page 26 of 47
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.621 Filed 06/27/22 Page 9 of 29
`
`NXP Semiconductors
`Data Sheet
`
`Document Number: WCT100XADS
`Rev. 1.2, 01/2021
`
`https://www.nxp.com/docs/en/data-sheet/WCT100XADSpdf
`
`Conforms to the latest version WPC “Qi” specification
`Supports wide DC inputvoltage range of6 V (limited
`duration at Start/Stop operation)to 16 V for automotive
`battery input
`Supports Foreign Object Detection (FOD)
`Low-power system standby available using Freescale
`Touch technology
`Provides free positioning solutions by using WPC A or
`B type multi-coil technology
`Uses rail voltage control or phase shift control with
`fixed operating frequency to control power transfer to
`helpalleviate automotive system interference
`Supports the key FOB avoidance function
`Supports the operation frequency dithering technology
`to eliminate the AM band interference
`Improved EMC performance for automotive
`certification
`Supports CAN/LIN/TIC/SCI/SPIinterfaces
`LEDfor system status indication
`
`Automotive Wireless Transmitter
`Controller
`Features
`
`Overview Description
`The WCT100xA is a wireless power transmitter controller
`that integrates all required functions for WPC “Qi”
`compliant wireless power transmitter design. The
`WCT100xA transmitter IC manages the power transfer by
`receiving commands from the receiver. Receivers are
`detected by using cither standard protocol methods or
`Freescale touch sensor technology. Once the mobile device
`is detected, the WCT100xA controls the power transfer by
`adjusting rail voltage or phase shift ofpowerstage according
`to message packets sent by mobile device.
`
`To maximize the design freedom and product differentiation,
`the WCT100xA supports any 5W coil topology capable of
`supporting WPC Qi-based implementation. In addition, the
`system supports both WPC and PMAprotocols.
`The WCT100xA also includes CAN/LIN/TIC/SCI/SPI
`interfaces, over-voltage/current/temperature protection and
`FOD method to protect from overheating by misplaced
`metallic foreign objects. It also handles any system fault and
`operation status, and provides comprehensive indicator
`outputs for robust system design.
`
`Software based solution to provide maximum design
`freedom and product differentiation
`Qualified to AEC100 Test Group A&B
`Dual-mode capable
`
`Applications
`e Automotive Wireless Power Transmitter
`o WPC compliant
`
`Excerpt from the NXP WCT1001 Wireless Power Transmitter IC datasheet showingthat it has the
`capability for over-current and over-voltage protection, which suggests it monitors the voltage and
`current associated with the first inductive elementin the base unit. Source:
`
`Page 27 of 47
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`

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`Case 2:22-cv-10730-GAD-APP ECF No. 26-7, PagelD.622 Filed 06/27/22 Page 10 of 29
`
`Accused Products
`
`For example, the exemplary Volkswagen Antenna Booster includes a NXP WCT1001 Wireless
`Power Transmitter IC, which adjusts the voltage of the time varying electric current to improve
`powertransfer efficiency.
`
`[1d] automatically adjusting at|Each Accused Product comprises automatically adjusting at least one characteristic of said time
`least one characteristic of said|varying electric current responsive to said parameter to maximize an efficiency of powertransfer
`time varyingelectric current
`from said base unit to said target unit.
`responsive to said parameter to
`maxumizean efficiency of
`powertransfer from said base
`unit to said target unit.
`
`transfer efficiency.
`
`For example, using an oscilloscope, the voltage of the time varying electric currentin thefirst
`inductive element of the base unit from the exemplary Volkswagen Antenna Booster was
`measured. As a small 5 mm gap was introduced between the target unit and base unit, the voltage
`wasobservedto change,