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`571-272-7822
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`Paper No. 38
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`QUALCOMM INCORPORATED,
`Patent Owner.
`_____________
`
`Case IPR2018-01283 (Patent 7,834,591 B2)
`Case IPR2018-01452 (Patent 7,834,591 B2)
`_____________
`
`Record of Oral Hearing
`Held: December 13, 2019
`_____________
`
`
`
`
`Before TREVOR M. JEFFERSON, DANIEL J. GALLIGAN, and
`SCOTT B. HOWARD, Administrative Patent Judges.
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`571-272-7822
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`Paper No. 38
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`QUALCOMM INCORPORATED,
`Patent Owner.
`_____________
`
`Case IPR2018-01283 (Patent 7,834,591 B2)
`Case IPR2018-01452 (Patent 7,834,591 B2)
`_____________
`
`Record of Oral Hearing
`Held: December 13, 2019
`_____________
`
`
`
`
`Before TREVOR M. JEFFERSON, DANIEL J. GALLIGAN, and
`SCOTT B. HOWARD, Administrative Patent Judges.
`
`
`
`
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`
`
`
`
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`IPR2018-01283 (Patent 7,834,591 B2)
`IPR2018-01452 (Patent 7,834,591 B2)
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`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`EAGLE ROBINSON, ESQ.
`TALBOT HANSUM, ESQ.
`Norton Rose Fulbright US, LLP
`98 San Jacinto Boulevard
`Suite 1100
`Austin, Texas 78701
`(512) 474-5201
`eagle.robinson@nortonrosefulbright.com
`talbot.hansum@nortonrosefullbright.com
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`NICHOLAS A. JEPSEN, ESQ.
`W. KARL RENNER, ESQ.
`THOMAS ROZYLOWICZ, ESQ.
`Fish & Richardson, P.C.
`1000 Maine Avenue, SW
`Washington, D.C. 20024
`(202) 626-6447 (Renner)
`renner@fr.com
`
`
`
`
`The above-entitled matter came on for hearing on Friday, December
`
`13, 2019, commencing at 1:00 p.m. at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`P R O C E E D I N G S
`- - - - -
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`(1:00 p.m.)
`JUDGE JEFFERSON: You can be seated. before we go on the
`record, I'm just letting the parties know we have a training situation going on
`here shadowing us today. So there will be one more person in front of you
`than normal.
`So good afternoon. This is a trial in Hearing IPR 2018-01283 and
`2018-01452 concerning Patent No. 7834591. Apple Inc. is Petitioner in the
`case and Patent Owner is Qualcomm. I'm going to have the counsel
`introduce yourselves at the lectern and identify anyone in the room who is
`with you today. And we'll start with Petitioner.
`MR. RENNER: Good afternoon, Your Honors. Karl Renner for
`Apple, Petitioner. Joined by Nick Jepsen and Tom Rozylowicz. And may
`I approach with a copy of the demonstratives?
`JUDGE JEFFERSON: You certainly can.
`(off the record comments)
`MR. ROBINSON: Good afternoon, Your Honors. Eagle
`Robinson for Patent Owner. With me at counsel table is Mr. Talbot
`Hansum and Mr. Bert Patella (phonetic) representative for Qualcomm.
`JUDGE JEFFERSON: Welcome. Before we begin, obviously
`remind the parties that the hearing is open to the public and transcript will be
`made of record. As mentioned from my trial order that each party has 60
`minutes to present its argument in each case. After both cases, we will
`allow some time. Obviously there's a lot of material to cover. Petitioner
`has the burden to show patentability and Patent Owner can respond. Both
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`parties are allowed to have rebuttal time. So at this time -- I'll have you
`start at the beginning of your presentation and tell us how much you time
`want to reserve. And I'll do my best to keep track of the time here,
`although the clock was not behaving properly when I was working with it
`earlier. So we'll see if -- I'll let you know if I end up doing it manually.
`Obviously for clarity of the transcript and for my colleagues, Judges
`Galligan and Howard who have joined us remotely, please refer to exhibit
`number and slide number. It helps them follow along if they can't see the
`screen here in the room. We have very experienced counsel, so obviously
`demonstratives are not evidence. But you can address each others
`demonstrative as needed. We will continue straight through without a
`break. And I would remind you just let me know what time you're going to
`reserve.
`And I do want to -- at least I'll start off by saying if it doesn't come
`up in your presentation, I might have a few questions about our motions to
`exclude that we can wrap up at the end. Okay? And with that, Petitioner,
`you may begin when you're ready.
`MR. JEPSEN: Good afternoon. I would like to reserve 25
`minutes for rebuttal.
`JUDGE JEFFERSON: Okay.
`MR. JEPSEN: Slide 2 please. Today Petitioner is going to be
`discussing four major topics. The first is Item 1.0, the construction of as a
`voltage on the battery increases. Item 2.0, charging current greater than
`input current to switching regulator. Item 3.0, feature reducing battery
`charging current in a current control mode as the voltage on the battery
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`increases. And 4.0, an explanation of why Bell, Kester, and Gong are
`properly combined.
`Slide 7 please. I'll just note that only Ground 1A of the 1283
`proceeding is contested. And so that's the only one I'll discuss today.
`Slide 8 please. Similarly in the 1452 Petition, only Ground 2A is contested
`and so I'll be discussing that.
`Slide 9 please. So as an initial matter, the construction of the
`phrase "as the voltage on the battery increases" is disputed by the parties.
`Qualcomm in the preliminary Patent Owner response indicated that plain
`and binary meaning should be used. However, Qualcomm has advanced a
`different view later in the proceeding.
`Slide 11 please. To the left is the Claim 1 of the 591 Patent
`showing the highlighted portion at the bottom with the phrase in question,
`"as the voltage on the battery increases." And Qualcomm's position on the
`right is that phrase means in response to a sensed increase in battery voltage.
`However, looking back at the patent, there is no mention of sensing an
`increase. There's nothing in the claim that requires a response to a sensed
`increase. Qualcomm could have chosen to amend the claims. To require
`the features and the new construction, but they chose not to.
`Slide 12. This new construction by Qualcomm creates a number of
`problems here. And I'll just briefly note as in the slide, this construction
`does not meet BRS Standard. It violates the claim differentiation doctrine.
`It imports a single embodiment into the claims. That's the embodiment that
`directly senses battery voltage. And last of all, it reads the sensed input
`current embodiment out of the claims. So why would Qualcomm try so
`hard to exclude one of its own embodiments that senses input current? It's
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`because the Bell prior art that we'll discuss today is doing exactly that. It's
`sensing input current and reducing charging current in response.
`Qualcomm's construction is wrong. And the Board should reject it.
`Moving to Slide 15. Even if the Board were to accept Qualcomm's
`flawed construction, the Bell and Kester combination still satisfies the
`claims. And a key to this is in the upper right-hand corner showing a quote
`from the 591 Patent itself. And I'll read that. "The switching regulator may
`detect the rise in the battery voltage by sensing either the battery voltage
`directly, the input current, or other related matters." And it's worth noting
`that there are three ways here that you can detect or sense this rise in battery
`voltage. And only one of which involves directly sensing battery voltage.
`Nevertheless, Qualcomm's construction is that direct sensing is required.
`That's not supported by the 591 Patent.
`In the Bell system, input current is sensed. Qualcomm may argue
`whether the input current is the regulator for charging alone or combination
`with other current. But the language in the 591 Patent is clear. Other
`related parameters are sufficient.
`Referring to Slide 17 now. The Bell, Kester, Gong combination
`also satisfies Qualcomm's improper construction. As we noted, the
`combination senses battery voltage Vb and reduces charging current based
`on the sense battery voltage Vb. And as shown on the right in Gong's
`figure, the very first step in determining a charge current is to read battery
`voltage Vb. And then in Step 906, to determine an efficient charge current
`based on the battery voltage. Clearly Gong teaches this same technique
`and meets even Qualcomm's construction. Slide 19 please.
`JUDGE JEFFERSON: Before you move on.
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`MR. JEPSEN: Yes, sir?
`JUDGE JEFFERSON: Although the parties have sort of
`concentrated or shortened it to "as the voltage on the battery increases", the
`phrase is "It reduces in a current control mode as the voltage on the battery
`increases." Is current control mode a term of art or is it tied specifically to
`what is described in the specification as being the current control mode?
`And I'm going to preview what one of my issues is, is that I'm now curious
`as to how that matters when I look at the, vis-a-vis the prior art that was
`overcome in the prosecution with this constant current/constant voltage
`mode, how then that differs from what we are looking at today. I'm sort of
`curious as to, you know, is this current control mode common across the art
`or common across the industry and should we give some life to it in these
`claims?
`MR. JEPSEN: Good question. I'm not aware of any evidence in
`the record saying that this is a term of art that would be instantly
`recognizable. That said, the parties do not disagree on the key points here.
`Qualcomm has not required a specific construction, neither has petitioner.
`One of the key elements is control as mentioned in the phrase itself. And
`Apple's position from the beginning has been that control requires an act.
`It requires for example, an active step or a command to cause this to occur.
`Current is not like floating, it is controlled or limited and actively set at some
`point.
`
`Turning to Slide 19. I'll now turn to the first of two disputed
`features in the claims. And in this section, the discussion of Bell and
`Kester as it applies to switching regulators, applies to both proceedings since
`both use Bell's switching regulator. Slide 20 please. Bell makes very
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`clear that he's using a switching buck regulator. This is an extremely well
`known type of power converter. So well known that a person of ordinary
`skill would not need Bell to explain these basic properties including step-
`down and voltage and corresponding step-up of current. Now Bell doesn't
`explain this, but it doesn't need to explain how this decades-old power
`converter works.
`Slide 21 please. Qualcomm's going to argue that buck regulators
`don't perform this kind of step-up. Or at least they may argue that it's
`uncertain. For that very purpose, Apple included in its original petitions,
`very clear evidence from Kester, which is a basic design guide covering
`topics such as thermal management and power management. And on the
`third page of the section on switching regulators, Kester makes this explicit
`statement. The quote here -- in particular, the highlighted portion from
`Kester says that "In step-down buck designs, the input current is lower than
`the output current." There are no qualifications here. There are no
`reservations. Kester's not ambiguous on this point as Qualcomm would
`like Your Honors to believe. Importantly, Kester explains the reason for
`this in the sentence just above the highlighted portion. Kester states, "The
`conservation of energy applies so the input power equals the output power."
`And note even before that, it mentions the efficiencies can be quite high,
`generally greater than 80 to 90 percent. As a result of the voltage step-
`down with high efficiency in these regulators, a current increase occurs from
`input to output.
`Slide 22 please. As noted in the original petitions on the left of the
`slide, in the combination Bell's switching regulator would provide filtered
`output current that is greater than the input current. Dr. Phinney notes in
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`the upper right-hand corner, it is obvious from Bell's switching regulator to
`provide such an output current that is greater than the input current. But
`this is common, well known behavior of the buck regulator. In the note
`below, the relationship between the input current and output current is a
`fundamental property of buck regulators that would be known to a person of
`ordinary skill. In fact, Qualcomm does not dispute that in a continuous
`mode of operation, buck regulators do have this property.
`Slide 23 please.
`JUDGE JEFFERSON: As I understand Qualcomm's argument and
`I'm sure they will give me the details of it, it's not that it's just -- that the
`petitioner assumes without actually explaining which mode it's operating in,
`that this buck step-down converter would operate in the mode that always or
`brings in. I'm not sure if we're talking about inherency or something that's
`so well known that it's common knowledge. But the argument is that in a
`discontinuous mode, there may be chances when the current is not stepped
`down.
`MR. JEPSEN: Thank you, Your Honor. Let me address that
`point. Go back to Slide 22 please. I'll note that Dr. Phinney explains it is
`obvious for regulators to operate in this way. This is not an inherency
`standard. This is an obviousness standard. It is possible to design a very
`poor buck regulator that doesn't do what it is designed to do. But as Kester
`noted, efficiencies are generally very high, 80 to 90 percent or higher.
`Notably Qualcomm gives no reason why a buck regulator, at least in
`continuous mode, would not provide this. And moving to Slide 23, it's
`telling that in the 591 Patent, it uses a buck regulator just like Bell does.
`Under the obviousness standard here, it is sufficient for the common and
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`obvious and typical design of a buck regulator to provide this property. It's
`obvious for that normally designed, well understood component to act as it's
`designed.
`And you're right, Your Honor, Qualcomm does take issue with the
`discontinuous mode. And I will address that now with reference to Slide
`25. First of all, Qualcomm has not provided any evidence to support their
`conjecture that discontinuous mode would not provide this kind of step-
`down. And further, that conjecture is wrong as we indicated in our reply in
`Phinney's declaration. This is a slide showing a figure from Kester. And
`on the left, there are two current sources annotated. The blue is switch
`current that is input current from a source. The red arrow shows current
`from a diode that is coming from a different portion. It's actually being
`pulled up from ground through diode. And it's not from input.
`On the right, Kester shows these different wave forms, individually
`and in combination as they form the outcome. The bottom in Inset D,
`shows the blue contribution of the switch input diode. Above that in Inset
`C, shows the red contribution of the diode current. And in Inset B, it shows
`that the output is the combination of the red and the blue. And so, the
`combination of input current, plus additional diode current must be greater
`than the input current alone. It's very easy to see that visually. It's also
`clear to see that in Inset B, I-Out, which is the average output current line is
`much higher than the input current line shown in Inset D. Notably after
`seeing these figures in Petitioner's documents, Qualcomm has backed away
`from this argument. And they did not emphasize it in their surreply.
`I'm going to move to Slide 27, which addresses the second dispute in
`claim feature, reducing battery charging current in a current control mode
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`as a voltage on the battery increases. Slide 29 please. It's important to
`understand how Bell operates to see how these limitations are met. I want
`to emphasize that in this figure showing Bell's 4B, on the right-hand side,
`there are three elements noted, which are pieces of different feedback
`controllers. From top to bottom, there is a charging current, feedback
`control loop that regulates output current to the battery. A charging voltage
`feedback control loop, which limits the maximum voltage to the battery.
`And an input current feedback control loop, which will regulate the input
`current so it does not exceed a maximum level.
`Note that Bell's system is designed for all of these three controllers
`to be operating concurrently. That doesn't mean that they are all regulating
`the output instantly. It means they are all watching for the respective
`conditions to occur. The charging current feedback control loop sets a
`target output level -- Let's say 1 amp. And the other two control loops can
`override that control if needed. So if the battery voltage reaches the limit,
`the voltage control feedback loop will override that current setting and
`decrease output. Similarly the input current feedback control loop, if it
`detects the current being drawn as too high, it will also override the output
`current feedback loop.
`Slide 30 please. As we noted in the petition, the input current
`feedback loop operates to keep input current within the limits of the power
`source. Bell was very explicit on this part. I'll refer you to the
`highlighted portion on the right. This input current feedback loop will
`operate to reduce the battery charging current. Thereby reducing the power
`drain of DC/DC Converter 32. And bringing current supply to Converter
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`The quote below is also important too. Note from the beginning, it
`says "Thus when the current, through a Resistor 50 is too high, the output of
`current sense Amplifier 54 will be high." Resulting in the highlighted
`portion to generate a control signal causing DC/DC converter to lower the
`charging current. That's important because the Resistor 50 is sensing not
`just system power demand as Qualcomm would like Your Honors to believe,
`but it's sensing the combination of charging power and system power. If
`either or both of those quantities would exceed the limit, the result is the
`same. Bell lowers the charging component. As Your Honors can see, this
`is also clearly a current control mode because lowering the charging current
`is an intentional active step taken by Bell 's circuitry.
`Slide 32 please.
`JUDGE JEFFERSON: Before you go on. Counsel, that's a -- are
`you characterizing that as a change in the current drawn from the power
`converter based on the overall power of the -- which is both the
`measurement of some battery voltage and current? Or is it one --
`disentangle that for me. Can it just be one? I mean because in terms of
`the claim, it's clearly -- I mean, the strongest form of the argument is that it
`has to be a direct measurement of the battery voltage. But let's say I buy
`that, why does that qualify for that ground, okay?
`MR. JEPSEN: And so I'd refer Your Honors back to the slide
`discussing how the 591 Patent describes the sensing.
`JUDGE JEFFERSON: I understand if you're getting ready to say it
`can be both direct and indirect.
`MR. JEPSEN: Correct.
`JUDGE JEFFERSON: I understand that quote.
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`MR. JEPSEN: Yes.
`JUDGE JEFFERSON: But let's say for the moment I buy that it
`has to be a direct measurement of the battery voltage, at least as you
`described Bell here, it's clearly a power -- it's clearly a concern with overall
`power that then modifies the current. Power can be a measurement of both,
`voltage and current. So I'm trying to disentangle exactly what it's
`measuring or sensing, even if it's indirectly related. What is the
`measurement on it?
`MR. JEPSEN: All right, so the measurement is input current to
`Bell system --
`JUDGE JEFFERSON: Okay.
`MR. JEPSEN: -- the overall current in Bell system.
`JUDGE JEFFERSON: Total input current?
`MR. JEPSEN: Yes. And a component of that is naturally the
`input current used by the regulator to charge the battery. And that is the
`link as you'll see in the following slides, how the system responds to
`battery charging -- the battery voltage during charging. There are just a
`few steps that show why this happens. So in Slide 32, Bell makes clear that
`it intends to maximize the amount of power used for charging. And so
`referring to just the highlighted portions of these Bell quotes, Bell's object is
`to maximize utilization of the power and the capacity. Also to best utilize a
`power converter's capacity. Many other quotes from Bell explain how it's
`intending to use as much power as possible and not leave power capacity
`unused and waste it.
`So in Slide 33, Bell illustrates this principle. The area in green,
`Box 15, is power used by the device circuitry. And you'll note that there's a
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`power limit at 30 watts in this example of Bell. And all of that area is filled
`in. There's no gap. The area under or not included in 15 is in yellow,
`Region 17. And that is power that can be used for charging. In a quote
`from Bell below describing this principle, Bell states "that Battery Charger
`20 may use any or all of the excess power." Now Qualcomm takes issue
`with this. Dr. Lall in particular says that all does not mean all. And yet
`fails to give any reasonable justification for that position. But Bell was
`explicit. Any or all excess power can be used for charging.
`Combine that with Bell's stated motivation to maximize usage of
`power. To not let power capacity be wasted. And we have a clear
`motivation in Bell -- an explanation why Bell's system itself should use all
`power capacity. Now is that a necessary condition? It may not happen
`at every instance in time. Batteries do have limited amounts of current that
`they can accept. But given Bell's teachings, a person of ordinary skill
`would give a battery as much as it can handle to maximize usage of the
`power source. And Bell says it explicitly there, all of the excess power
`source.
`Referring now to Slide 35. I simply want to show you that cell
`voltage -- battery voltage increases your end charge. This is showing a
`lithium ion battery, the same kind used in the combination here. Now
`referring to Slide 36, increasing battery voltage increases power demand,
`which causes the input current feedback loop to decrease charging current.
`In a quote here, the center quote, it notes, "The electrical power P, electrical
`power demand is a function of current I and Voltage V, particular P=IV" --
`Power equals current times voltage. Now we established that Bell intends
`to maximize use of his power source. So P is operating at its maximum
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`value. It can't increase any further. Yet as noted before, battery voltage,
`B, is increasing. And so for power to remain the same and voltage to
`increase, there's only one choice. The current to the battery, I , must
`decrease. And that's exactly what Bell does. It just said in several
`instances that the input current feedback loop, to maintain power at the
`desired maximum level, will decrease charging current.
`Your Honors, I'll refer you now to Slide 38. It summarizes these
`features here. One, combination maximizes charging power within a
`power constraint. Two, voltage on the battery increases during charging.
`Three, the electrical power demand is a function of current and voltage.
`And four, increasing battery voltage increases power demand, which causes
`the input current feedback loop to decrease the charging current.
`Now referring to Slide 39. We discussed the relationship between
`voltage and current. There's a question regarding sense parameters -- Let
`me make it clear that input current limiting is not a different approach than is
`used by the 591 Patent. In fact, input current limiting is the reason the 591
`Patent reduces charge. And it's also the mechanism that the patent uses for
`the doing so. At least in some embodiments. Keep in mind that we're
`dealing with USB power sources, which are very limited sources.
`Sometimes as low as 100 milliamps. Bell's teaching to use as much power
`as possible for charging. It's perfectly suited to that scenario when you're
`going to run into your limit very quickly.
`Slide 42 please. You'll hear today from Qualcomm that somehow
`Bell's current reductions are incidental. That's not the case. Bell
`explicitly states that it is actively limiting the power demand of the battery
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`charger. To reach Qualcomm's conclusion, you have to disregard the plain
`language of Bell, not once but time and again.
`Slide 43 please. In case there is any question about whether current
`is controlled, Dr. Phinney noted that current is controlled. And it's for the
`same reasons that I noted before. There's both an input current, feedback
`loop, and an output current feedback loop.
`Slide 44 please. You'll also hear Qualcomm argue that Bell only
`contemplated constant current charging. Bell does not agree. Bell notes
`here in quote, "It is an additional object of the invention to vary the charging
`rate of a battery." I want to be very clear on this point, Bell is not teaching
`pure constant current charging. Bell intends to lower the charging current.
`That is the whole reason that the input current control loop is there.
`I'll now move to Slide 49 discussing the combination with Gong.
`JUDGE JEFFERSON: Before you move on, one of the arguments
`that's made is that Bell does not explicitly state that the filtered current to the
`battery is reduced as the voltage increases. Clearly you're talking about
`input. In the Bell system, you were referring specifically to input current.
`What's your response to that? That it doesn't explicitly state it. That it's
`a natural occurrence and, in their terms, incidental occurrence as part of this
`power management system?
`MR. JEPSEN: Well Your Honors are very familiar with the law of
`obviousness. And we have established how this circuit operates and what a
`person of ordinary skill would understand from it. In obviousness, a person
`of ordinary skill is not limited to the explicit text of the reference. They
`can understand how the reference operates. And as I noted before, the way
`it operates, although Bell gives the example of system power fluctuating and
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`not triggering the input current control loop, we can plainly see that the
`contribution of current there is also from current flowing to the battery
`charger. And so regardless of the reason that the input current limiter is
`triggered for battery charging demand or for system power demand or some
`combination of both, the result is absolutely the same.
`Slide 49 please. So I want to emphasize the striking similarity
`between the teachings of the 591 Patent and Gong here. On the left, we
`have the 591 Patent and the red highlighted portion notes filtered current is
`reduced in a current control mode. On the right, explicitly in Gong, the
`amount of power supply to the battery is controlled by controlling the charge
`current. This is clearly a current control mode. And in the lower red
`section in Gong, the charge current, I-charge is reduced. Gong leaves no
`question on this point. And second, referring to the green sections in the
`591, this occurs as the voltage on the battery increases. In Gong, also as
`the voltage in the battery increases.
`Qualcomm never addresses this point. Qualcomm would rather
`discuss the vagaries and inferences about a specific peripheral figure. And
`I'll show that figure right now, Slide 50. In case there are any doubt,
`comparing Gong's approach in Figure 4 to the 591 approach on the left, they
`both are showing the same technique. On the left -- in both figures
`actually, the horizontal axis shows voltage increasing from left to right.
`And directly as a result of that, we see the stair step in red in both of these
`that is reducing current in discrete steps. Now Qualcomm makes various
`points about this figure. Argues that perhaps it's not a progression over
`time, but perhaps it's a snapshot in time. Perhaps the power current may
`vary. These conjectures really make no difference because you have to
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`take the figure in isolation. You have to take it out of context from Gong's
`disclosure to reach that conclusion.
`Slide 51 please. Gong unequivocally states that the charge current
`is reduced as in the top quote as the voltage of the battery increases. In the
`lower quotes, also adjusting a charge current as the battery voltage changes.
`And the final quote, the efficient charge current changes as the battery
`voltage changes. Read in context with Gong's full disclosure, there's no
`question that Gong teaches the same feature every time.
`Slide 52 please. Qualcomm can't deal with the point of disclosure
`of the references here. And so any peripheral issues about the combination,
`none of those arguments apply. Slide 54 please. Initially to discuss
`motivation, it's worth noting that Gong teaches battery charging managed by
`a power manager microprocessor, No. 6.
`Slide 55 please. A primary motivation here is to use
`microprocessor control to gain the flexibility to easily change current and
`voltage. Petitioner actually didn't come up with this argument. It was
`directly from Bell. Bell states as one of its sanctioned modifications to its
`own circuit, a host microprocessor can program the current and voltage
`characteristics, depending upon the design of the battery. Gong provides
`the technique to do exactly that.
`Slide 56 please. Further bolstering this combination, it is an object
`to -- or it would be obvious to achieve Bell's objective to provide battery
`charging circuitry, which is not specific to any one battery construction or
`sub- chemistry. Again, that's the original petition quoting Bell directly.
`And what does Gong teach? And another advantage of Gong's invention is
`that battery type specific processing can be readily provided for different
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`battery types. Ag
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