`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________
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`COOLER MASTER CO., LTD.
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`Petitioner,
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`v.
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`ASETEK DANMARK A/S,
`
`Patent Owner
`
`_________________
`
`U.S. Patent No. 8,245,764
`_________________
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`
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`DECLARATION OF GEORGIOS KARAMANIS, PH.D.
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`Dated: March 5, 2023
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`Respectfully submitted,
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`______________________
`Georgios Karamanis, Ph.D.
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`Cooler Master Co., Ltd. Ex. 1003, Page 1 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.
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`TABLE OF CONTENTS
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`I.
`INTRODUCTION AND QUALIFICATIONS .............................................. 1
`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 ............................................................................... 9
`IV. LEGAL STANDARDS .................................................................................. 9
`V. OVERVIEW OF THE ’764 PATENT ......................................................... 11
`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
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`2.
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`3.
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`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
`D. GROUND 6: Claim 8 is obvious over Batchelder in view of
`Duan and further in view of Laing. .................................................. 159
`IX. CONCLUDING STATEMENT ................................................................. 160
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`B.
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`C.
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`4.
`5.
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`6.
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`7.
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`2.
`3.
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`4.
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`5.
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`6.
`7.
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`Cooler Master Co., Ltd. Ex. 1003, Page 3 of 168
`Cooler Master Co., Ltd. v. Asetek Danmark A/S
`IPR2023-00668
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`I, Georgios Karamanis, Ph.D., declare as follows:
`INTRODUCTION AND QUALIFICATIONS
`I.
`Counsel for Cooler Master Co., Ltd.. (“CMC”) has retained me as an
`1.
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`expert to offer my opinion regarding the validity of U.S. Patent No. 8,245,764 (“’764
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`patent”). I submit this declaration based on my personal knowledge and in support
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`of CMC’s inter partes review Petition against the ’764 patent. I previously submitted
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`a substantively identical declaration in support of Shenzhen Apaltek Co. Ltd.’s inter
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`partes review Petition against the ’764 patent.
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`2.
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`In 2018, I received my Ph.D. from Tufts University in Mechanical
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`Engineering. My Ph.D. thesis was entitled “Nusselt Numbers for Superhydrophobic
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`Microchannels and Shrouded Longitudinal-Fin Heat Sinks.”
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`3.
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`In October 2018, I began working at Transport Phenomena
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`Technologies, LLC (TPT) in Medford, MA where I am co-founder and managing
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`member.
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`4.
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`I am currently a Chief Engineer at TPT and responsible for R&D in the
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`area of thermal management of electronics and heat/mass/momentum transfer
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`modeling.
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`5.
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`I am the PI on a National Science Foundation Phase I and its successor
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`Phase II SBIR award (#2025882) and before that on a Massachusetts Clean Energy
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`Center Catalyst award (Spring 2019) relevant to development of software and
`1
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`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`hardware for thermal management of electronics.
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`6.
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`I have 10 journal publications most of which are related to thermal
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`management of electronics and liquid cooling. A copy of my Curriculum Vitae
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`(“CV”) is submitted herewith as Appendix A, which describes my education,
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`training, and experience in greater detail.
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`7. My primary consulting client is Apaltek, acting as an expert on thermal
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`management in general, including liquid cooling to cool CPUs.
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`8.
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`I have not previously testified as an expert witness in any court or
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`administrative proceeding.
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`9.
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`I am billing my work in this matter at $200 per hour, with
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`reimbursement for actual expenses. My payment is not contingent upon my
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`testimony or the outcome of the case. I have no personal interest in the outcome of
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`the case.
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`II. MATERIALS CONSIDERED
`10. The analysis provided in this declaration is based on my education as
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`well as my experience in the field. In addition to relying upon my knowledge based
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`on written materials and other information that was known as of May 6, 2005, I have
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`considered the exhibits to the Petition (Exs. 1001-1015), shown below.
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`IPR2023-00668
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`
`Exhibit
`1001
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`1002
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`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`1011
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`1012
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`1013
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`Description
`U.S. Patent No. 8,245,764 (“’764 patent”)
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`Inter Partes Reexamination Certificate, Reexamination Request
`95/002,386, U.S. Patent No. 8,245,764
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`File history of U.S. Patent No. 8,245,764 (“’764-FH”)
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`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)
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`U.S. Patent Publication No. 2006/0185830 (“Duan”)
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`U.S. Patent Publication No. 2006/0185829 (“Duan-I”)
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`U.S. Patent No. 6,019,165 to Batchelder (“Batchelder”)
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`Patent Owner’s Response, Paper No. 21 in IPR2020-00523 (Nov.
`30 2020) (“’354-POR”)
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`U.S. Patent No. 10,078,354 (the “’354 patent”)
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`Final Written Decision in IPR2020-00523, Paper No. 36 (Aug. 19,
`2021) (“’354-FWD”)
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`File history of Reexamination Request 95/002,386, U.S. Patent
`No. 8,245,764 (“’764-Rexam-FH”)
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`Institution Decision, Paper No. 10, IPR2021-01196 (Dec. 28,
`2021) (“’196-Institution”)
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`Exhibit
`1014
`
`Description
`Certified Translation of Japanese Unexamined Patent App. Pub.
`No. 2002-151638 to Takayuki Shin (“Shin”)
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`1015
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`U.S. Patent Publication No. 2004/0052663 (“Laing”)
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`
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`III. OVERVIEW AND LEGAL STANDARDS
`Priority Date
`A.
`11. Counsel has explained to me that I should assume the effective filing
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`date of the ’764 patent is May 6, 2005. I have, therefore, applied this date in
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`considering the prior art and the viewpoint of a person of ordinary skill in the art
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`(“POSITA”).
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`12.
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`I understand Petitioner may argue that the ’764 patent is not entitled to
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`a 2005 effective filing date. Even if this were true, my opinions would not change.
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`B.
`13.
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`Person Having Ordinary Skill in the Art
`I understand that my assessment of the claims of the ’764 patent must
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`be undertaken from the perspective of what would have been known or understood
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`by a person having ordinary skill in the art, reading the ’764 patent on its relevant
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`filing date and in light of the specification and file history of the ’764 patent. I will
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`refer to such a person as a “POSITA.”
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`14.
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`I understand that my analysis and opinions expressed in this declaration
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`must be rendered based on the perspective of a POSITA as of the priority date of the
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`Challenged Claims. I also understand that a POSITA is a hypothetical person who
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`is presumed to have known the relevant art at the time of the alleged invention
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`claimed in the ’764 patent.
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`15.
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`I further understand that in determining the level of ordinary skill in the
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`art, I am to consider factors including:
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`a) the type of problems encountered in the art or field of invention,
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`b) prior art solutions to those problems,
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`c) the rapidity with which innovations are made,
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`d) sophistication of the technology, and
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`e) the educational level of active workers in the field.
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`16.
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`I understand that a POSITA is a person of ordinary creativity, but not
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`an automaton, and that a POSITA can often fit multiple patents or prior art references
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`together like pieces of a puzzle as a result of this ordinary creativity. I also
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`understand that I may consider the inferences and creative steps that a POSITA
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`would employ. In addition, I understand that a POSITA would necessarily have been
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`capable of understanding the scientific and engineering principles applicable to the
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`pertinent art. I also understand that when I consider what would have been obvious
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`to a POSITA, I am not considering what would have been obvious to me at the time,
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`nor to the inventors, judges, laymen, those skilled in other arts, or to geniuses in
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`the art.
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`17. Based on my review and analysis of the Challenged Patent, the prior art
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`cited herein, and the ordinary skill factors described in this section, in my opinion,
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`POSITA working in the field of liquid cooling systems for computer systems as of
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`the claimed priority date (May 6, 2005) would have been knowledgeable regarding
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`liquid cooling systems for computer systems, would have had a Bachelor of Science
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`(B.S.) in electrical or mechanical engineering, or similar advanced post-graduate
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`education in this area, or would have possessed at least 2-3 years of experience in
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`liquid cooling systems for computer systems or similar systems. (See, e.g., Ex-1001
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`at 1:11-47 (describing the “Background of the Invention” of the ’764 patent).) A
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`POSITA would be knowledgeable of the concepts, components, and their functions
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`described as “prior art” in the ’764 patent such as, for example, liquid pumps, heat
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`radiators, air fans, reservoirs, and other techniques of heat dissipation and liquid
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`cooling. (Id.) In addition, a POSITA would be knowledgeable about electric motors
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`and their components such as, for example, electromagnetic coils, rotors, stators, AC
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`motors, DC motors, etc.
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`18. A person with less education but more relevant practical experience,
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`depending on the nature of that experience and degree of exposure to liquid cooling
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`systems for computer systems could also qualify as a POSITA in the field of the
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`’764 patent.
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`C. CLAIM CONSTRUCTION
`“reservoir”
`1.
`I understand that the parties have stipulated, in the pending district court
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`19.
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`action, to construe the term “reservoir,” as that term is used in the ’764 patent claims,
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`to mean “single receptacle defining a fluid flow path.” (Ex-1005 at 2.)
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`“chamber”
`2.
`I further understand that the parties have also stipulated to construe the
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`20.
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`term “chamber,” as that term is used in the ’764 patent claims, to mean
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`“compartment within the reservoir. (Ex-1005 at 2.)
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`“underside” and “upper side” of the “chassis”
`3.
`21. Claim 1 recites “a double-sided chassis adapted to mount a pump
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`configured to circulate a cooling liquid, the pump comprising a stator and an
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`impeller, the impeller being positioned on the underside of the chassis and the stator
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`being positioned on the upper side of the chassis and isolated from the cooling
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`liquid” (emphasis added). Thus, a POSITA would have understood the “upper side
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`of the chassis” to mean the side isolated from the cooling liquid and the “underside
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`of the chassis” to mean the other side contacting the cooling liquid.
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`“below”
`4.
`22. The term “below” by itself appears in the following phrase in claim 1:
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`“a pump chamber including the impeller and formed below the chassis[.]” Because
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`the “impeller” is positioned on the underside of the chassis (i.e., the side contacting
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`the cooling liquid) and included in the “pump chamber,” a POSITA would have
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`understood the “pump chamber” to be “formed below the chassis” on the “underside
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`of the chassis” contacting the cooling liquid.
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`“below … vertically”
`5.
`23. The term “below … vertically” appears in the following phrase in claim
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`1: “a thermal exchange chamber formed below the pump chamber and vertically
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`spaced apart from the pump chamber[.]” Petitioner and Patent Owner have
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`stipulated that “vertically spaced apart” means “vertically arranged (with reference
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`to each other and the heat exchanging interface) chambers” (with “chamber”
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`construed as above).” (Ex-1005 at 2.) Thus, a POSITA would have understood
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`“below … vertically” to mean that the “thermal exchange chamber” is “formed
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`below the pump chamber … vertically” with reference to each other and the heat
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`exchanging interface.
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`IPR2023-00668
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`6. Other Terms
`24. As to other terms, a POSITA would have understood the plain and
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`ordinary meaning of the term “double-sided chassis” to be “two-sided frame or
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`base.” To the extent applicable, I have rendered my opinions using these
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`constructions. Although it is my understanding that district court claim construction
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`proceedings are ongoing, for purposes of these IPRs, I believe no additional specific
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`constructions are required; I understand that the other claim terms in these IPRs will
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`be construed according to their ordinary and customary meaning. I further
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`understand that the claims are read in light of the patent’s specification and that
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`claims themselves often provide significant guidance as to the meaning of a
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`particular term.
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`IV. LEGAL STANDARDS
`I have been asked to opine on whether certain claims are either
`25.
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`anticipated or rendered obvious by the prior art.
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`26.
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`I have been instructed that anticipation means that a single prior art
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`reference discloses each claim element and discloses the arrangement of each claim
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`element. To disclose a claim element, the prior art does not have to expressly spell
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`out the claim element as along as a POSITA, reading the reference, would at once
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`envisage the claimed arrangement or combination.
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`27.
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`I have been instructed that obviousness means that one or more prior
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`art references disclose each claim element of a claim and that there must be an
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`apparent reason to combine the known elements to arrive at the claims. The analysis
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`is a flexible one, accounting for the inferences and creative steps that a person of
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`ordinary skill in the art would employ. The claims must be read as a whole when
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`evaluating whether it is obvious.
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`28.
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`It is my understanding that a claimed invention is unpatentable under
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`35 U.S.C. § 103 if the differences between the invention and the prior art are such
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`that the subject matter as a whole would have been obvious at the time the alleged
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`invention was made to a person of ordinary skill in the art to which the subject matter
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`pertains. This is sometimes described as “obviousness.” I understand that an
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`obviousness analysis considers the level of ordinary skill in the art, the scope and
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`content of the prior art, and the differences between the prior art and the claimed
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`subject matter. The analysis may also consider secondary considerations, such as
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`commercial success, unmet but long felt need and failure of others.
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`29.
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`It is my understanding that court cases have recognized several
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`rationales for combining references or modifying a reference to show obviousness
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`of the claimed subject matter. Some of these rationales include the following:
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`combining prior art elements according to known methods to yield predictable
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`results; simple substitution of one known element for another to obtain predictable
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`results; a predictable use of prior art elements according to their established
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`functions; applying a known technique to a known device to yield predictable
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`results; choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and some teaching, suggestion, or motivation in
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`the prior art that would have led a POSITA to modify the prior art or combine prior
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`art teachings to arrive at the claimed invention.
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`V. OVERVIEW OF THE ’764 PATENT
`30. The ’764 patent characterizes its field of invention as follows:
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`“The present invention relates to a cooling system for a central processing
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`unit (CPU) or other processing unit of a computer system. More
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`specifically, the invention relates to a liquid-cooling system for a
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`mainstream computer system such as a PC.” (Ex-1001 at 1:11-15.)
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`31. The ’764 patent relates to a liquid-cooling system for a computer
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`system. The specification purports to disclose embodiments of a liquid-cooling
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`system that is more efficient, easier to use, and more compact with integrated
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`components than prior art cooling systems. (Ex-1001 at 1:11-2:19.)
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`32. The ’764 patent further states that these purported improvements may
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`be achieved by having an integrated element comprising the heat exchange interface,
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`the reservoir of cooling liquid, and the pump for pumping the cooling liquid. (Id. at
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`1:51-2:31; claims 1-18.)
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`33. The following figures capture the main characteristics of the purported
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`invention claimed in the Challenged Claims.
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`34. FIG. 7 is a perspective view of the
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`cooling system showing the reservoir housing 14
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`with the heat exchanging surface (not shown) and
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`the pump (not shown) inside the reservoir. The
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`tube
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`inlet connection and
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`the
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`tube outlet
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`connection are connected to a heat radiator by
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`means of connecting tubes 24 and 25 through
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`which the cooling liquid flows into and out of the
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`reservoir and the heat radiator, respectively. Within the heat radiator 11, the cooling
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`liquid passes a number of channels for conducting/convecting the heat, which has
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`been dissipated into the cooling liquid inside the reservoir, and to the surroundings
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`of the heat exchanger. The air fan 10 blows air past the channels of the heat radiator
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`in order to cool the radiator and thereby cooling the cooling liquid flowing inside the
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`channels through the heat radiator and back into the reservoir.” (Ex. 1001 at 15:61-
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`16:7.)
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`The internal structures of the claimed reservoir 14 are depicted in FIGS. 17 and 20
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`reproduced below.
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`35.
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` The use of liquid cooling with what is sometimes referred to in the
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`industry as an “all-in-one” cooler to cool semiconductor chips in computer systems
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`was generally known to a person of ordinary skill in the art (“POSITA”) long before
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`the claimed May 6, 2005 priority date of the ’764 patent, as evidence by Batchelder
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`(filed May 18, 1998).
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`36. The images below compare FIG. 20 of the ’764 patent with FIG. 2 of
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`Batchelder:
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`Reservoir
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`’764 Patent
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`Batchelder
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`
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`37. The use of a closed liquid cooling loop connecting an all-in-one cooler
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`and a radiator with tubes was also generally known to a POSITA before the claimed
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`priority date of the ’764 patent, as evidenced by Duan (Ex-1006) and Duan-I (Ex-
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`1007). The images below compare FIG. 7 of the ’764 patent with FIG. 6 of Duan:
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`Radiator
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`Reservoir
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`’764 Patent
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`Duan
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`38. The ’764 patent only discloses an embodiment of the known “all-in-
`
`one” coolers used in closed liquid cooling loops.
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`
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`VI. OVERVIEW OF PRIOR ART
`A. Duan (Ex-1006)
`39. Duan published as U.S. Patent Publication No. 2006/0185830 on
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`August 24, 2006, from Application No. 11/060,442, which was filed on February
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`18, 2005. My understanding is that Duan qualifies as prior art to the ’764 patent for
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`all Challenged Claims.
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`B. Duan I (Ex-1007)
`40. Duan I published as U.S. Patent Publication No. 2006/0185829 on
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`August 24, 2006, from Application No. 11/060,419, which was filed on February
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`18, 2005. My understanding is that Duan I qualifies as prior art to the ’764 patent
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`for all Challenged Claims.
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`C. Batchelder (Ex-1008)
`41. Batchelder issued as U.S. Patent No. 6,019,165 on February 1, 2000.
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`(Ex-1006 at [11], [45].) My understanding is that Batchelder qualifies as prior art to
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`the ’764 patent for all Challenged Claims.
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`D. Laing (Ex-1015)
`42. Laing published as U.S. Patent Publication No. 2004/0052663 on
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`March 18, 2004, from Application No. 10/434,307, which was filed on May 7, 2003.
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`My understanding is that Laing qualifies as prior art to the ’764 patent for all
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`Challenged Claim.
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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
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`VII. CLAIM ELEMENT NUMBERING KEY
`43. Because the Challenged Claims have similar claim elements, they are
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`numbered as follows for the element-by-element invalidity analyses of the
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`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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`Petition for Inter Partes Review Of
`U.S. Patent No. 8,245,764
`Decl. of Georgios Karamanis, Ph.D.
`
`
`’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)
`
`
`[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)
`
`
`
`[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)
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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
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`
`
`[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
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`Cooler Master Co., Ltd. Ex. 1003, Page 22 of 168
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`IPR2023-00668
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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)
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`
`
`[10-e]
`wherein at least one of the one or
`more passages is offset from a
`center of the impeller.
`(Claim 10)
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`11. The cooling system of claim
`10, wherein a top wall of the
`reservoir physically separates the
`impeller from the stator.
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`Cooler Master Co., Ltd. Ex. 1003, Page 23 of 168
`Cooler Master Co., Ltd. v. Asetek Danmark A/S
`IPR2023-00668
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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
`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.
`
`[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)
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`
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`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.
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`See Claim 9 below
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`[15-d]
`wherein a first side of the
`heat-exchanging interface
`is in contact with