Apple Inc. (Petitioner)
`v.
`RJ Technology LLC (Patent Owner)
`
`Petitioner’s Demonstratives
`
`Case No. IPR2023-01350
`U.S. Patent No. 7,749,641
`Before Jon B. Tornquist, Christopher M. Kaiser, and Brian D. Range
`Administrative Patent Judges
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`
`v.
`RJ Technology LLC (Patent Owner)
`
`Petitioner’s Demonstratives
`
`Case No. IPR2023-01350
`U.S. Patent No. 7,749,641
`Before Jon B. Tornquist, Christopher M. Kaiser, and Brian D. Range
`Administrative Patent Judges
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`
`
`Table of Contents
`
`• The ’641 Patent
`•
`
`Issue 1: Claims 5-8 are obvious over both Yamaki-Sakamoto and
`Yasunami-Koyama
`
`•
`
`Issue 2: Claims 11-14 are obvious over both Yamaki-Sakamoto
`and Yasunami-Koyama
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
`
`
`
`’641 Patent and Petition Overview
`
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`3
`
`
`
`The ’641 Patent
`
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`APPLE-1001, 17:5-11
`
`4
`
`
`
`Asserted Grounds
`
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`Petition, 5
`
`5
`
`
`
`Claims 5-8 Are Unpatentable over
`Yamaki-Sakamoto
`
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`6
`
`
`
`Yamaki-Sakamoto Combination
`
`• Overview of the Yamaki-Sakamoto combination
`•
`
`Issue 1.1: The Yamaki-Sakamoto combination satisfies the
`claimed charge cut-off voltage range
`
`•
`
`•
`
`Issue 1.2: A POSITA would have been motivated to combine
`Yamaki and Sakamoto
`
`Issue 1.3: A POSITA would have expected success in combining
`Yamaki and Sakamoto
`
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`7
`
`
`
`The Yamaki-Sakamoto Combination
`
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`8
`
`
`
`Yamaki’s battery has high CCV and good cycle life
`
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`APPLE-1004, [0012], [0014]; Petition, 6-7
`
`9
`
`
`
`Sakamoto describes a range of capacity balance values
`
`APPLE-1005, [0007]; Petition, 8-9
`
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`10
`
`
`
`The Yamaki-Sakamoto combination
`
`. . .
`
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`Petition, 9-10
`
`11
`
`
`
`The Yamaki-Sakamoto combination
`
`Petition
`
`Yamaki
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`APPLE-1004, [0014]-[0015]; Petition, 13
`
`12
`
`
`
`ISSUE 1.1
`
`The Yamaki-Sakamoto Battery Satisfies the
`Claimed Charge Cut-off Voltage Range
`
`[5a] the secondary lithium ion cell or battery has a charge cut-off voltage
`of greater than 4.2 V but less than 5.8 V
`
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`13
`
`
`
`Yamaki’s charge cut-off voltage falls within the claimed range
`
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`APPLE-1004, [0014]; Petition, 15
`
`14
`
`
`
`Expert testimony confirms that Yamaki describes viable batteries
`
`Patent Owner’s Sur-reply
`
`Second Hruska Declaration
`
`APPLE-1035, ¶7-8; Pet. Reply, 7-8; PO Sur-reply, 2-3
`
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`15
`
`
`
`Yamaki describes viable batteries
`
`Deposition of Patent Owner’s expert
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`APPLE-1004, 12; APPLE-1034, 38:14-39:9; Pet. Reply, 7
`
`16
`
`
`
`Yamaki is an enabling reference
`
`Pet Reply
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`Pet. Reply, 8-9
`
`17
`
`
`
`ISSUE 1.2
`
`A POSITA Would Have Been Motivated to
`Combine Yamaki and Sakamoto
`
`[5b] a ratio of positive electrode material to negative electrode material
`of the secondary lithium ion cell or battery is from 1:1.0 to 1:2.5
`
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`18
`
`
`
`The Yamaki-Sakamoto combination
`
`Petitioner’s Reply
`
`Patent Owner’s Response
`
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`POR, 28; Pet. Reply, 9-10
`
`19
`
`
`
`The Yamaki-Sakamoto combination
`
`Petition
`
`Patent Owner’s Response
`
`Petitioner’s Reply
`
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`Petition, 20-21; POR, 29; Pet. Reply, 11
`
`20
`
`
`
`The Petition motivated the Yamaki-Sakamoto combination
`
`Patent Owner’s Response
`
`Petitioner’s Reply
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`POR, 30-31; Pet. Reply, 12
`
`21
`
`
`
`The Petition presented five motivations for the combination
`
`Petition, 11-12
`
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`22
`
`
`
`The Petition motivated the Yamaki-Sakamoto combination
`
`Patent Owner’s Sur-reply
`
`PO Sur-reply, 7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`23
`
`
`
`ISSUE 1.3
`
`A POSITA Would Have Expected Success
`in Combining Yamaki and Sakamoto
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`24
`
`
`
`The Petition demonstrated that a POSITA would have expected success
`
`Petition
`
`Yamaki
`
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`APPLE-1004, [0014]-[0015]; Petition, 13
`
`25
`
`
`
`The Petition demonstrated that a POSITA would have expected success
`
`Patent Owner’s Response
`
`Petition
`
`POR, 33; Pet. Reply, 11-12, 14
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
`
`
`
`The Petition demonstrated that a POSITA would have expected success
`
`Sakamoto
`
`Petition
`
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`APPLE-1005, [0008]; Pet. Reply, 11-12
`
`27
`
`
`
`Claims 5-8 Are Unpatentable over
`Yasunami-Koyama
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`
`
`Yasunami-Koyama Combination
`
`• Overview of the Yasunami-Koyama combination
`•
`
`Issue 1.4: “Charge cut-off voltage”
`
`•
`
`•
`
`Issue 1.5: The combination satisfies the claimed charge cut-off
`voltage range
`
`Issue 1.6: A POSITA would have been motivated to combine
`Yasunami and Koyama
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`29
`
`
`
`The Yasunami-Koyama Combination
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`
`
`Yasunami’s battery has a high end-of-charge voltage
`
`Yasunami
`
`APPLE-1006, [0006], [0034]; Petition, 39
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`
`
`Koyama describes a range of capacity balance values
`
`Koyama
`
`APPLE-1007, [0005]-[0006]; Petition, 40
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`32
`
`
`
`The Yasunami-Koyama combination
`
`Petition
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, 41-42
`
`33
`
`
`
`ISSUE 1.4
`
`“Charge Cut-off Voltage”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`34
`
`
`
`Battery charging
`
`Patent Owner’s Response
`
`Second Hruska Declaration
`
`POR, 53; APPLE-1035, 13; Pet. Sur-Reply, 15-16
`
`35
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`
`
`PO’s construction of “charge cut-off voltage”
`
`Patent Owner’s Response
`
`Petitioner’s Reply
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`POR, 24-25; Pet. Reply, 1
`
`36
`
`
`
`The ’641 Patent contradicts PO’s construction
`
`’641 Patent
`
`Petitioner’s Reply
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1001, 9:49-55; Pet. Reply, 2
`
`37
`
`
`
`CCV – Statements by PO’s expert
`
`Petitioner’s Reply
`
`Pet. Reply, 4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`38
`
`
`
`ISSUE 1.5
`
`The Yasunami-Koyama Battery Satisfies
`the Claimed Charge Cut-off Voltage Range
`
`[5a] the secondary lithium ion cell or battery has a charge cut-off voltage
`of greater than 4.2 V but less than 5.8 V
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Yasunami’s end-of-charge voltage is a charge cut-off voltage
`
`Petition
`
`POR
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, 48; POR, 50
`
`40
`
`
`
`Yasunami’s end-of-charge voltages fall within / overlap with the claimed range
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1006, [0034], [0067]; Petition, 49-50
`
`41
`
`
`
`The Yasunami’s end-of-charge voltage is substantially equivalent
`to the battery voltage
`
`Petition
`
`Second Hruska Declaration
`
`Pet. Reply
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1035, ¶14; Pet. Reply, 15-16, 19
`
`42
`
`
`
`The CCV range is obvious even under PO’s construction
`
`Second Hruska Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1035, ¶18-19; Pet. Reply, 19-20
`
`43
`
`
`
`Overlapping ranges
`
`Petition
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, 2
`
`44
`
`
`
`The 4.2 V lower limit of the claimed range
`
`Petition
`
`Second Hruska Declaration
`
`Petition, 50; APPLE-1035, ¶21-22; Pet. Reply, 19
`
`45
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`
`
`It was obvious for Yasunami to implement CC-CV charging
`
`Yasunami
`
`Hruska Declaration
`
`APPLE-1003, ¶190; APPLE-1006, [0006]; Petition, 49
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`46
`
`
`
`ISSUE 1.6
`
`A POSITA Would Have Been Motivated
`to Combine Yasunami and Koyama
`
`[5a] the secondary lithium ion cell or battery has a charge cut-off voltage
`of greater than 4.2 V but less than 5.8 V
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`47
`
`
`
`The Petition presented four motivations for the combination
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, 43-45
`
`48
`
`
`
`Koyama’s capacity ratio is compatible with Yasunami’s battery
`
`Patent Owner’s Response
`
`Petitioner’s Reply
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Pet. Reply, 22; POR, 60
`
`49
`
`
`
`Koyama’s capacity ratio is compatible with Yasunami’s battery
`
`Patent Owner’s Response
`
`Petitioner’s Reply
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet. Reply, 21; POR, 59-60
`
`50
`
`
`
`Koyama’s capacity ratio is compatible with Yasunami’s battery
`
`Yasunami
`
`Pet. 46; POR, 59; APPLE-1006, [0002], [0007]
`
`51
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Koyama’s capacity ratio is compatible with Yasunami’s battery
`
`Koyama
`
`Second Hruska Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet. Reply, 21; APPLE-1007, [0009]; APPLE-1035, ¶¶28-29
`
`52
`
`
`
`ISSUE 2
`
`Claims 11-14 Are Obvious over
`Yamaki-Sakamoto or Yasunami-Koyama
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`
`
`Claims 11-14 recite percent capacity retention values
`
`Apple-1001, Claims 11-14; Petition, 23
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`54
`
`
`
`The ’641 Patent does not describe how to achieve the capacity
`retention features
`
`Petition, 24-25; Pet. Reply, 28
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`55
`
`
`
`The ’641 Patent does not describe how to achieve the capacity
`retention features
`
`Deposition of Patent Owner’s expert
`
`Pet. Reply, 27; APPLE-1034, 32:2-14
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`56
`
`
`
`The ’641 Patent does not describe how to achieve the capacity
`retention features
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet. Reply, 26-27
`
`57
`
`
`
`The recited capacity retention capabilities were achievable by
`routine experimentation
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Petition, 28-29
`
`58
`
`
`
`Routine experimentation
`
`Petitioner’s Reply
`
`EX2021 (Broussely)
`
`Pet. Reply, 29; EX2021, 7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`59
`
`
`
`Yamaki-Sakamoto – Cycle life
`
`Hruska Declaration
`
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`APPLE-1003, ¶98; Petition, 25
`
`60
`
`
`
`Yamaki – Cycle life
`
`Yamaki
`
`Patent Owner’s expert
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet. Reply, 7-8; Petition, 25; APPLE-1004, [0012], [0057]
`
`61
`
`
`
`Sakamoto – Cycle life
`
`Sakamoto
`
`Petition, 25; APPLE-1005, [0007]
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`62
`
`
`
`Yasunami-Koyama – Cycle life
`
`Hruska Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1003, ¶223; Petition, 59
`
`63
`
`
`
`Yasunami – Cycle life
`
`Yasunami
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1006, [0006], [0066]; Petition, 60
`
`64
`
`
`
`Koyama – Cycle life
`
`Koyama
`
`Petition
`
`APPLE-1019
`
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`Petition, 44; APPLE-1019, 3:24-28; APPLE-1007, [0006]
`
`65
`
`
`
`Cycle life testing
`
`Hruska Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPLE-1003, ¶101; Petition, 26
`
`66
`
`
`
`Claims 11-14 do not recite structural features
`
`Petition
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Petition, 23
`
`67
`
`
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