Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 1 of 18
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`EXHIBIT A: INFRINGEMENT CLAIM CHART FOR
`APPLE ACCUSED PRODUCTS – U.S. PATENT NO. 7,151,430
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`No part of this exemplary chart construes, or is intended to construe, the specification, file history, or claims of the ’430 patent.
`Moreover, this exemplary chart does not limit, and is not intended to limit, Ericsson’s infringement positions or contentions.
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`Infringing Products: Apple iPhone 13
`The Apple iPhone 13 has an inductor layout, the layout having reduced mutual electromagnetic
`coupling.
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`The Apple iPhone 13 utilizes the Broadcom BCM4387 semiconductor chip, which includes an
`inductor with loops that tend to reduce and cancel out their respective magnetic field components.
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`The below picture shows the box of the Apple product.
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`U.S. Patent No. 7,151,430
`Claim 1
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`[1pre] An inductor layout having
`reduced mutual electromagnetic
`coupling, comprising:
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`EXHIBIT A: INFRINGEMENT CLAIM CHART FOR
`APPLE ACCUSED PRODUCTS – U.S. PATENT NO. 7,151,430
`
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`No part of this exemplary chart construes, or is intended to construe, the specification, file history, or claims of the ’430 patent.
`Moreover, this exemplary chart does not limit, and is not intended to limit, Ericsson’s infringement positions or contentions.
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`Infringing Products: Apple iPhone 13
`The Apple iPhone 13 has an inductor layout, the layout having reduced mutual electromagnetic
`coupling.
`
`The Apple iPhone 13 utilizes the Broadcom BCM4387 semiconductor chip, which includes an
`inductor with loops that tend to reduce and cancel out their respective magnetic field components.
`
`The below picture shows the box of the Apple product.
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`U.S. Patent No. 7,151,430
`Claim 1
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`[1pre] An inductor layout having
`reduced mutual electromagnetic
`coupling, comprising:
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 2 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Ericsson lab photo of an iPhone 13 model A2484).
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 3 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Ericsson lab photo showing bar code data).
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`The above picture shows information available on the box of the Apple product.
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 4 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photo of an iPhone 13 model A2484 with front cover removed).
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`The above photo shows the iPhone 13 with the front cover removed.
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 5 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photos showing two sides of a printed circuit board (PCB) in the iPhone 13
`model A2484).
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 6 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
`The above photos show two sides of a printed circuit board (PCB) in the iPhone 13. An integrated
`circuit module marked USI 339S00761 (below referred to as “the USI module”) is highlighted with a
`red rectangle in the lower photo. The USI module comprises the BCM4387 circuit.
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`(Sigma Connectivity photo shows a close-up photo of the cover of the USI module in the iPhone 13).
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 7 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photo showing the semiconductor die of the Broadcom BCM4387 circuit with
`several inductors annotated in red).
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`The above picture shows the semiconductor die in the Broadcom BCM4387 Dual-Band 802.11ax Wi-
`Fi/Bluetooth 5 Combo Chip in the Apple Product. There are many inductors on the die, including a
`number of Digure-8-shaped inductors (which are highlighted above). In the pictures below, an
`exemplary inductor layout is highlighted having a reduced far field.
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 8 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 9 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photo showing a zoomed-in view of the inductor layout annotated in red in the
`previous photo).
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 10 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photo showing enlargement of the die marking indicating it is the BCM4387
`chipset).
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`The BCM4387 chipset includes an inductor layout having a reduced far field. As seen in the photos
`above, the BCM4387 has an inductor layout having reduced mutual electromagnetic coupling, which
`is highlighted with a red rectangle in the top photo and zoomed in on the second photo.
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`Thus, to the extent the preamble is limiting, the iPhone 13 has an inductor layout having reduced
`mutual electromagnetic coupling.
`The Apple iPhone 13 includes at least the below exemplary first inductor having a reduced far field.
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`As discussed, the BCM4387 chipset includes an inductor layout having a reduced far field. As seen
`in the photos above, the BCM4387 has an inductor layout having reduced mutual electromagnetic
`coupling. This includes a first inductor having a reduced far field as shown below.
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`[1a] a first inductor having a reduced
`far field, said first inductor comprising:
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 11 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photo showing a zoomed-in view of the inductor layout in the BCM4387
`chipset, with an exemplary first inductor annotated in red).
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`The above picture shows an enlargement of an exemplary first inductor on the semiconductor die in
`the domestic industry product.
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 12 of 18
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`U.S. Patent No. 7,151,430
`[1b] a first loop having a shape that is
`substantially symmetrical about a first
`predefined axis;
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`Infringing Products: Apple iPhone 13
`The Apple iPhone 13 has an inductor having a reduced far field, said first inductor comprising a first
`loop having a shape that is substantially symmetrical about a first predefined axis.
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`(Ericsson Lab photo showing a zoomed-in view of the first inductor in the BCM4387 chipset)
`(highlights added).
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`The above picture shows an enlargement of the first inductor on the semiconductor die in the Apple
`iPhone 13, highlighting that there is at least one first loop symmetrical about a first axis.
`The exemplary inductor has a second loop(s) connected to each first loop(s), and the size and shape of
`the second loop is substantially identical to the size and shape of the first loop. The second loop is
`arranged such that the current flow through the second loop is opposite in direction to the current flow
`in the first loop, so that a magnetic field emanating from the second loop tends to cancel a magnetic
`field emanating from the first loop.
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`[1c] a second loop connected to the
`first loop, said second loop having a
`size and shape substantially identical to
`the first loop, said second loop
`arranged such that a magnetic field
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 13 of 18
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`U.S. Patent No. 7,151,430
`emanating therefrom tends to cancel a
`magnetic field emanating from the first
`loop; and
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`Infringing Products: Apple iPhone 13
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` (Ericsson Lab photo showing a zoomed-in view of the exemplary first inductor in the BCM4387
`chipset) (highlights added).
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`The above picture shows an enlargement of the first inductor on a semiconductor die in the iPhone 13
`product, highlighting a second loop(s) connected to the first loop(s).
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 14 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Ericsson Lab photo showing a zoomed-in view of the first inductor in the BCM4387 chipset)
`(highlights added).
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`The above picture shows an enlargement of the first inductor on the semiconductor die in the iPhone
`13 product, highlighting the direction and orientation of electrical current and magnetic fields.
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`In the figure above, the current flow through the conductive traces forming the two loops of the first
`inductor are shown in red, the relative direction of current around each of the two loops is shown in
`blue, and the relative direction (coming out of the page or going into the page) of the magnetic field
`emanating from each of the two loops is shown in yellow. The symmetry of the two loops in size and
`shape causes the magnetic fields emanating from the two loops to be substantially equal in strength,
`and these two substantially equal magnetic fields tend to cancel each other because they are oriented
`in opposite directions.
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 15 of 18
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`U.S. Patent No. 7,151,430
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`[1d] two closely spaced terminals
`connected to the first loop for
`supplying electrical current to the first
`and second loops while minimizing
`magnetic field contributions from the
`terminals; and
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`Infringing Products: Apple iPhone 13
`The direction of a magnetic field produced by a current flowing through a conductive loop is
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`illustrated above with the symbols ⊗ and ⊙, where ⊗ denotes a magnetic field having a direction
`into the page, and ⊙ denotes a magnetic field having a direction out of the page.
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`The inductor has two closely spaced terminals connected to the first loop that supply the current that
`flows through the first and second loops in the inductor. The close spacing between these two
`terminals minimizes the far field magnetic field contributions from the terminals.
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`(Ericsson Lab photo showing a zoomed-in view of the exemplary first inductor in the BCM4387
`chipset with two closely spaced terminals) (highlights added).
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`The above picture shows an enlargement of the exemplary first inductor on a semiconductor die in the
`domestic industry product, highlighting two terminals that are connected to the first loop and that
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 16 of 18
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`U.S. Patent No. 7,151,430
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`[1e] a second inductor positioned at a
`predetermined distance from the first
`inductor, wherein a mutual
`electromagnetic coupling between the
`first inductor and the second inductor
`is reduced as a result of the first
`inductor having a reduced
`electromagnetic field.
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`Infringing Products: Apple iPhone 13
`supply the current that flows through the first and second loops of the inductor. Current flows in
`opposite directions through these two terminals, which are closely spaced, thereby minimizing any far
`field contributions from the two terminals.
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`The Apple iPhone 13 utilizing the Broadcom BCM4387 semiconductor chip, includes at least one
`second inductor positioned at a predetermined distance from the first inductor, wherein a mutual
`electromagnetic coupling between the first inductor and the second inductor is reduced as a result of
`the first inductor having a reduced electromagnetic field.
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 17 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
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`(Sigma Connectivity photo showing a zoomed-in view of the inductor layout showing an exemplary
`first inductor and a second inductor) (annotations added in red).
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`The above picture shows an enlargement of the layout of an exemplary first inductor and one of the
`second inductors on the semiconductor die in the accused product. These two inductors are
`positioned on the same die at a predefined distance from each other. The symmetry of the two loops
`in size and shape causes the magnetic fields emanating from the two loops of the exemplary first
`inductor to be substantially equal in strength, and these two substantially equal magnetic fields tend to
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`Case 6:22-cv-00061-ADA Document 1-2 Filed 01/17/22 Page 18 of 18
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`U.S. Patent No. 7,151,430
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`Infringing Products: Apple iPhone 13
`cancel each other because they are oriented in opposite directions. As a result, there is reduced
`mutual electromagnetic coupling between the first inductor and the second inductors.
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