Académique Documents
Professionnel Documents
Culture Documents
vs.
APPLE INC.,
founding in 1993, Immersion has developed and licensed haptic products and intellectual
property across diverse industries and applications, including, for example, medical devices,
medical training simulations, game systems and controllers, automotive devices, touchscreen
controls for appliances and office equipment, and mobile electronic devices. In recent years, a
primary focus of Immersion's business has been developing products for the mobile electronic
device industry, including software products for implementing advanced haptic effects, including
pressure-enabled haptic effects, on mobile electronic devices.
2.
provides touch or tactile sensations to the users of electronic devices. Because of the importance
of the sense of touch to the way people perceive their surroundings and the things with which
they interact, haptics can greatly enhance the usability and functionality of consumer electronic
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devices. Haptic sensations in such devices are typically created by actuators, or motors, which
create a vibration.
3.
Immersion's TouchSense software), users can experience a vibrating force as they push a
virtual button, select a graphical object, scroll through a list, or receive a message. As another
example, when haptics is implemented in a laptop computer (for example, in the laptop's
touchpad), users can experience a vibrating force when they press down on the touchpad.
Haptics may, for example, confirm or provide cues that an action has been performed.
Predefined haptic effects may be incorporated in an electronic device to allow certain haptic
effects to be associated with certain actions and allow applications to access and use the
predefined haptic effects library. As another example, when implemented in a mobile game,
users can feel an engine reverberation, the crack of the bat meeting the ball, or the release of a
slingshot. The presence of haptics in electronic devices provides a new level of user interaction
through haptic cues, which provide users with a more rich and immersive user experience.
4.
embedded software, and integrated into device user interfaces and applications via embedded
control software APIs. Applications running on a mobile electronic device call these APIs to
implement the haptic effects. These APIs in turn cause specific haptic effect commands to be
sent to an actuator in the electronic device, resulting in the associated haptic feedback effect.
More sophisticated applications may provide a variety of tactile sensations. For example, user
actions may trigger different haptic effects and thus communicate different types of information.
This information may be conveyed by varying the type, duration, intensity, or frequency of the
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tactile sensations. This enables the creation of different haptic effects so that users can easily
distinguish, for example, a calendar alert from a text message alert or an incoming call.
5.
sensors may measure the pressure levels of contacts on the touchscreen. Separate haptic effects
may be configured for different interactions with graphical objects, for example, touching
graphical objects on the touchscreen and applying pressure at varying pressure levels. Different
haptic effects may be provided depending on the pressure level of the contact on the touchscreen
in relation to predefined pressure thresholds.
6.
For example, a
particular haptic effect may be used when the pressure level of the contact on the touchscreen is
less than a first pressure threshold, or a particular haptic effect may be used when the pressure
level of the contact on the touchscreen is between the first pressure threshold and a second
pressure threshold. As another example, haptic effects in a pressure-enabled mobile device may
be provided depending on whether certain conditions are met by the user's interaction with the
pressure-enabled touch sensor. For example, a user may interact with a displayed graphical
object on the touchscreen by applying pressure to the touchscreen. The pressure-enabled touch
sensor may receive contact data from the interaction and the mobile device may determine a
gesture based on the contact data. As an example, if the pressure is greater than a pressure
threshold and the change in pressure is greater than a change in pressure threshold and a time
interval has elapsed, a haptic effect may be provided. In this way, the user's intended interaction
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may be accurately determined based on contact data from the pressure-enabled touch sensor, and
the user experience enhanced.
7.
receipt of a command and indicate that a command is unrecognized. For example, a user may
issue a command by interacting with a graphical object on a touchscreen, e.g., by applying a
certain level of pressure to the touchscreen. If the user input is recognized and the command is
determined, the mobile electronic device may provide a haptic effect confirming receipt of the
command. Otherwise, the mobile electronic device may provide a second haptic effect. The
second haptic effect may indicate, for example, that the user input is unrecognized or that a
corresponding command was not found. Haptic feedback confirming receipt of a command
provides a more realistic and responsive user experience, informing the user via tactile sensation
whether the user's input was recognized and the command was determined.
8.
Immersion's hard work and ingenuity in the field of haptics has resulted in
extensive intellectual property protection for Immersion's innovations. This protection includes
more than 2,100 world-wide granted and pending patents, including the patents-in-suit.
9.
features of the current generation of Apple iPhones are promoted under the names "3D Touch"
and "Taptic Engine."
feedback, including feedback based on pressure-sensitive interactions with the touch screen.
Apple and AT&T tout this functionality on their websites.
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10.
Similarly, important haptic features of the Apple MacBook, Apple MacBook Pro
13-inch, and Apple MacBook Pro 15-inch are promoted under the names "Force Touch" and
"Taptic
Engine."
Apple
touts
this
http://www.apple.com/macbook/design/:
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functionality
on
its
website.
See
11.
mobile devices that infringe Immersion's patents. Defendants are utilizing Immersion's patented
inventions without license or authority from Immersion. Immersion has brought this action to
remedy Defendants' infringement.
PARTIES
12.
at 50 Rio Robles, San Jose, CA 95134. Immersion is the owner of the intellectual property rights
at issue in this action. As noted above, Immersion is a leading innovator and developer of haptic
feedback technologies. Since its founding in 1993, Immersion has developed and licensed haptic
feedback products and intellectual property across diverse industries and applications, including
mobile electronic devices.
13.
Defendant Apple Inc. ("Apple") is a California corporation with its principal place
Apple makes, uses, offers to sell, sells, and imports into the United States mobile
electronic devices, including the Apple MacBook, Apple MacBook Pro 13-inch, Apple
MacBook Pro 15-inch, Apple iPhone 6s, and Apple iPhone 6s Plus. Apple maintains one or
more retail stores and numerous employees in this judicial district. Apple's retail stores in this
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judicial district offer to sell and do sell infringing devices, including the Apple MacBook, Apple
MacBook Pro 13-inch, Apple MacBook Pro 15-inch, Apple iPhone 6s, and Apple iPhone 6s
Plus.
15.
business at 208 S. Akard Street, Dallas, TX 75202. Defendant AT&T Mobility LLC is a
Delaware limited liability company with its principal place of business at 1025 Lenox Park
Boulevard NE, Atlanta, GA 30319. AT&T Mobility LLC is a wholly-owned subsidiary of
AT&T Inc. Together, AT&T Inc. and AT&T Mobility LLC will be referred to as "AT&T."
16.
AT&T uses, offers to sell, sells, and imports into the United States mobile
electronic devices, including the Apple iPhone 6s and Apple iPhone 6s Plus. AT&T maintains
one or more retail stores and numerous employees in this judicial district. AT&T's retail stores
in this judicial district offer to sell and do sell infringing devices, including the Apple iPhone 6s
and Apple iPhone 6s Plus.
JURISDICTION AND VENUE
17.
This is an action for patent infringement arising under the patent laws of the
United States of America, 35 U.S.C. 1, et seq., including 35 U.S.C. 271. This Court has
subject matter jurisdiction over the matters pleaded herein under 28 U.S.C. 1331 and 1338(a).
18.
This Court has personal jurisdiction over Defendants because, among other
reasons, Defendants have done business in this District, have committed and continue to commit
acts of patent infringement in this District, and have harmed and continue to harm Immersion in
this District, by, among other things, using, selling, and offering for sale infringing products in
this District. Moreover, the Defendants have placed infringing products into the stream of
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commerce by shipping those products into this District or knowing that the products would be
shipped into this District.
19.
because, among other reasons, Defendants are subject to personal jurisdiction in this District and
have committed acts of infringement in this District, including selling and distributing infringing
products in this District.
20.
among other reasons, Immersion asserts a right to relief against Defendants with respect to or
arising out of the same transaction, occurrence, or series of transactions or occurrences relating
to the making, using, importing into the United States, offering for sale, or selling of common
accused products, including the Apple iPhone 6s and Apple iPhone 6s Plus, and questions of fact
common to all Defendants will arise in this action.
FIRST CLAIM FOR RELIEF FOR PATENT INFRINGEMENT
(U.S. Patent No. 8,749,507)
21.
22.
Immersion is the owner of the entire right, title, and interest in and to U.S. Patent
in full.
No. 8,749,507 (the "'507 patent"), entitled "Systems and Methods for Adaptive Interpretation of
Input from a Touch-Sensitive Input Device," which was duly issued on June 10, 2014. A copy
of the '507 patent is attached as Exhibit A.
23.
certain mobile electronic devices such as mobile phones that receive contact data from
interactions with a touchscreen. The '507 patent teaches, among other things, systems and
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methods in which the mobile electronic device determines a pressure and a change in pressure
based on contact data. The mobile electronic device outputs a haptic effect if the pressure is
greater than a pressure threshold, the change in pressure is greater than a change in pressure
threshold, and an interval has elapsed. Further details of the invention are described in the
specification and the claims.
24.
Defendants have infringed and are currently infringing the '507 patent, in
violation of 35 U.S.C. 271, by, among other things, making, using, offering for sale, selling,
and/or importing within this judicial district and elsewhere in the United States, without license
or authority, products and/or processes falling within the scope of one or more claims of the '507
patent, including without limitation the Apple iPhone 6s and Apple iPhone 6s Plus.
25.
Based on the information presently available to it, Immersion alleges that at least
the following apparatuses, products, devices, processes, methods, acts, or other instrumentalities
infringe or are covered by claims of the '507 patent: the Apple iPhone 6s and Apple iPhone 6s
Plus.
devices, processes, methods, acts, or other instrumentalities without the benefit of discovery or
claim construction in this action, and expressly reserves the right to augment, supplement, and
revise its identifications based on additional information obtained through discovery or
otherwise.
26.
Apple, AT&T, and their customers directly infringe the '507 patent using the
Apple iPhone 6s and Apple iPhone 6s Plus. The accused devices receive contact data from a
user's finger contacting the touch screen of the devices.
interactions with displayed graphical objects. Then, the accused devices determine a "Peek" or
"Pop" press using pressure, change in pressure, and timing interval information. Additional
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details relating to the accused devices and their infringement are in the possession of
Defendants.
27.
Defendants also indirectly infringe the '507 patent. Defendants are aware of the
'507 patent at least from the date of this Complaint. Additionally, on information and belief,
Defendants were aware of the '507 patent before the date of this Complaint, including without
limitation through Defendants' knowledge of Immersion and Immersion's disclosure of its
patents
on
its
website
(formerly
located
at
http://www.immersion.com/haptics-
to
Defendants.
See,
e.g.,
http://www.benzinga.com/analyst-ratings/analyst-
color/13/08/3816746/immersion-others-could-get-a-boost-when-haptics-market-r
("When
it
comes to haptics, Immersion is usually the first company that comes to mind."). Defendants
knew that the Apple iPhone 6s and Apple iPhone 6s Plus infringed the '507 patent, or at a
minimum believed there was a high probability that the Apple iPhone 6s and Apple iPhone 6s
Plus were covered by the '507 patent, but willfully blinded themselves to Immersion's patent and
the infringing nature of the Apple iPhone 6s and Apple iPhone 6s Plus.
28.
Defendants induced and are actively inducing infringement of the '507 patent, in
violation of 35 U.S.C. 271(b), by, among other things, actively and knowingly aiding and
abetting others to directly make, use, offer for sale, sell, and/or import within this judicial district
and elsewhere in the United States, without license or authority, products and/or processes
falling within the scope of one or more claims of the '507 patent, including without limitation the
Apple iPhone 6s and Apple iPhone 6s Plus. For example, Defendant Apple provides directions,
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instruction manuals, guides, and/or other materials that encourage and facilitate infringing use by
others.
See,
e.g.,
http://www.att.com/wireless/iphone/;
https://www.att.com/cellphones/
infringing the '507 patent, in violation of 35 U.S.C. 271(c), by, among other things, selling,
offering for sale, and/or importing within this judicial district and elsewhere in the United States,
without license or authority, products or components of products which constitute a material part
of the '507 patent, knowing that such products and/or components are especially made or
especially adapted for use in the infringement of the '507 patent, and not staple articles or
commodities of commerce suitable for substantial noninfringing use.
30.
Defendants' infringement of the '507 patent has been and continues to be willful
and deliberate. Despite knowledge of the '507 patent, Defendants have acted and are acting
despite an objectively high likelihood that their actions constitute patent infringement. This
objective risk was and is known to the Defendants, and is also so obvious that it should have
been known to the Defendants.
31.
Immersion has suffered and will continue to suffer irreparable injury for which there is no
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adequate remedy at law. Immersion has also been damaged and, until an injunction issues, will
continue to be damaged in an amount yet to be determined.
SECOND CLAIM FOR RELIEF FOR PATENT INFRINGEMENT
(U.S. Patent No. 7,808,488)
32.
33.
Immersion is the owner of the entire right, title, and interest in and to U.S. Patent
in full.
No. 7,808,488 (the "'488 patent"), entitled "Method and Apparatus for Providing Tactile
Sensations," which was duly issued on Oct. 5, 2010. A copy of the '488 patent is attached as
Exhibit B.
34.
certain mobile electronic devices such as mobile phones that have, among other things, a
touchscreen and an actuator. The '488 patent teaches, among other things, systems and methods
in which the mobile electronic device displays on the touchscreen a graphical object. When the
user touches the graphical object on the touchscreen using his or her finger, a signal is generated
indicating an object contacting the touchscreen and a pressure of the contact. The mobile
electronic device generates an actuator signal to the actuator to output a haptic effect based on
the user's interaction with the graphical object on the touchscreen. Haptic effects are output
based on, among other things, the pressure of the contact in relation to pressure thresholds.
Further details of the invention are described in the specification and the claims.
35.
Defendants have infringed and are currently infringing the '488 patent, in
violation of 35 U.S.C. 271, by, among other things, making, using, offering for sale, selling,
and/or importing within this judicial district and elsewhere in the United States, without license
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or authority, products and/or processes falling within the scope of one or more claims of the '488
patent, including without limitation the Apple iPhone 6s and Apple iPhone 6s Plus.
36.
Based on the information presently available to it, Immersion alleges that at least
the following apparatuses, products, devices, processes, methods, acts, or other instrumentalities
infringe or are covered by claims of the '488 patent: the Apple iPhone 6s and Apple iPhone 6s
Plus.
devices, processes, methods, acts, or other instrumentalities without the benefit of discovery or
claim construction in this action, and expressly reserves the right to augment, supplement, and
revise its identifications based on additional information obtained through discovery or
otherwise.
37.
Apple, AT&T, and their customers directly infringe the '488 patent using the
Apple iPhone 6s and Apple iPhone 6s Plus. When a user presses at a pressure level to trigger a
"Peek" interaction on a software-generated object on the touch screen of the accused devices, the
processor receives a signal indicating the application of pressure from a user's finger contacting
the touch screen, and transmits an actuator signal to the actuator in the accused devices (e.g., the
"Taptic Engine"), causing the actuator to output a first tactile sensation. Similarly, when the user
then presses at a greater pressure level to trigger a "Pop" interaction, a different, second tactile
sensation is produced. Additional details relating to the accused devices and their infringement
are in the possession of Defendants.
38.
Defendants also indirectly infringe the '488 patent. Defendants are aware of the
'488 patent at least from the date of this Complaint. Additionally, on information and belief,
Defendants were aware of the '488 patent before the date of this Complaint, including without
limitation through Defendants' knowledge of Immersion and Immersion's disclosure of its
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patents
on
its
website
(formerly
located
at
http://www.immersion.com/haptics-
to
Defendants.
See,
e.g.,
http://www.benzinga.com/analyst-ratings/analyst-
color/13/08/3816746/immersion-others-could-get-a-boost-when-haptics-market-r
("When
it
comes to haptics, Immersion is usually the first company that comes to mind."). Defendants
knew that the Apple iPhone 6s and Apple iPhone 6s Plus infringed the '488 patent, or at a
minimum believed there was a high probability that the Apple iPhone 6s and Apple iPhone 6s
Plus were covered by the '488 patent, but willfully blinded themselves to Immersion's patent and
the infringing nature of the Apple iPhone 6s and Apple iPhone 6s Plus.
39.
Defendants induced and are actively inducing infringement of the '488 patent, in
violation of 35 U.S.C. 271(b), by, among other things, actively and knowingly aiding and
abetting others to directly make, use, offer for sale, sell, and/or import within this judicial district
and elsewhere in the United States, without license or authority, products and/or processes
falling within the scope of one or more claims of the '488 patent, including without limitation the
Apple iPhone 6s and Apple iPhone 6s Plus. For example, Defendant Apple provides directions,
instruction manuals, guides, and/or other materials that encourage and facilitate infringing use by
others.
See,
e.g.,
http://www.att.com/wireless/iphone/;
https://www.att.com/cellphones/
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and are selling these products with the knowledge and intent that customers who buy the
products will use the products for their infringing use and therefore that customers have been and
are directly infringing the '488 patent.
40.
infringing the '488 patent, in violation of 35 U.S.C. 271(c), by, among other things, selling,
offering for sale, and/or importing within this judicial district and elsewhere in the United States,
without license or authority, products or components of products which constitute a material part
of the '488 patent, knowing that such products and/or components are especially made or
especially adapted for use in the infringement of the '488 patent, and not staple articles or
commodities of commerce suitable for substantial noninfringing use.
41.
Defendants' infringement of the '488 patent has been and continues to be willful
and deliberate. Despite knowledge of the '488 patent, Defendants have acted and are acting
despite an objectively high likelihood that their actions constitute patent infringement. This
objective risk was and is known to the Defendants, and is also so obvious that it should have
been known to the Defendants.
42.
Immersion has suffered and will continue to suffer irreparable injury for which there is no
adequate remedy at law. Immersion has also been damaged and, until an injunction issues, will
continue to be damaged in an amount yet to be determined.
THIRD CLAIM FOR RELIEF FOR PATENT INFRINGEMENT
(U.S. Patent No. 8,581,710)
43.
in full.
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44.
Immersion is the owner of the entire right, title, and interest in and to U.S. Patent
No. 8,581,710 (the "'710 patent"), entitled "Systems and Methods for Haptic Confirmation of
Commands," which was duly issued on Nov. 12, 2013. A copy of the '710 patent is attached as
Exhibit C.
45.
certain mobile electronic devices such as mobile phones that have, among other things, a
touchscreen and an actuator. The '710 patent teaches, among other things, systems and methods
in which the mobile electronic device receives user input via the touchscreen. The mobile
electronic device generates an actuator signal to the actuator to output a first haptic effect if the
user input is recognized and a command is determined, confirming receipt of the command.
Otherwise, the mobile electronic device generates an actuator signal to the actuator to output a
second haptic effect. The second haptic effect may indicate that the user input is unrecognized
or that a corresponding command was not found. Further details of the invention are described
in the specification and the claims.
46.
Defendants have infringed and are currently infringing the '710 patent, in
violation of 35 U.S.C. 271, by, among other things, making, using, offering for sale, selling,
and/or importing within this judicial district and elsewhere in the United States, without license
or authority, products and/or processes falling within the scope of one or more claims of the '710
patent, including without limitation the Apple iPhone 6s and Apple iPhone 6s Plus.
47.
Based on the information presently available to it, Immersion alleges that at least
the following apparatuses, products, devices, processes, methods, acts, or other instrumentalities
infringe or are covered by claims of the '710 patent: the Apple iPhone 6s and Apple iPhone 6s
Plus.
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devices, processes, methods, acts, or other instrumentalities without the benefit of discovery or
claim construction in this action, and expressly reserves the right to augment, supplement, and
revise its identifications based on additional information obtained through discovery or
otherwise.
48.
Apple, AT&T, and their customers directly infringe the '710 patent using the
Apple iPhone 6s and Apple iPhone 6s Plus. For example, when a user of the accused devices
attempts to access the "Quick Actions" associated with an application by applying pressure on
the touchscreen, a first haptic effect will be output if the application supports "Quick Actions."
Otherwise, a second haptic effect will be output to the housing of the device, indicating that the
application does not support "Quick Actions." Additional details relating to the accused devices
and their infringement are in the possession of Defendants.
49.
Defendants also indirectly infringe the '710 patent. Defendants are aware of the
'710 patent at least from the date of this Complaint. Additionally, on information and belief,
Defendants were aware of the '710 patent before the date of this Complaint, including without
limitation through Defendants' knowledge of Immersion and Immersion's disclosure of its
patents
on
its
website
(formerly
located
at
http://www.immersion.com/haptics-
to
Defendants.
See,
e.g.,
http://www.benzinga.com/analyst-ratings/analyst-
color/13/08/3816746/immersion-others-could-get-a-boost-when-haptics-market-r
("When
it
comes to haptics, Immersion is usually the first company that comes to mind."). Defendants
knew that the Apple iPhone 6s and Apple iPhone 6s Plus infringed the '710 patent, or at a
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minimum believed there was a high probability that the Apple iPhone 6s and Apple iPhone 6s
Plus were covered by the '710 patent, but willfully blinded themselves to Immersion's patent and
the infringing nature of the Apple iPhone 6s and Apple iPhone 6s Plus.
50.
Defendants induced and are actively inducing infringement of the '710 patent, in
violation of 35 U.S.C. 271(b), by, among other things, actively and knowingly aiding and
abetting others to directly make, use, offer for sale, sell, and/or import within this judicial district
and elsewhere in the United States, without license or authority, products and/or processes
falling within the scope of one or more claims of the '710 patent, including without limitation the
Apple iPhone 6s and Apple iPhone 6s Plus. For example, Defendant Apple provides directions,
instruction manuals, guides, and/or other materials that encourage and facilitate infringing use by
others.
See,
e.g.,
http://www.att.com/wireless/iphone/;
https://www.att.com/cellphones/
infringing the '710 patent, in violation of 35 U.S.C. 271(c), by, among other things, selling,
offering for sale, and/or importing within this judicial district and elsewhere in the United States,
without license or authority, products or components of products which constitute a material part
of the '710 patent, knowing that such products and/or components are especially made or
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especially adapted for use in the infringement of the '710 patent, and not staple articles or
commodities of commerce suitable for substantial noninfringing use.
52.
Defendants' infringement of the '710 patent has been and continues to be willful
and deliberate. Despite knowledge of the '710 patent, Defendants have acted and are acting
despite an objectively high likelihood that their actions constitute patent infringement. This
objective risk was and is known to the Defendants, and is also so obvious that it should have
been known to the Defendants.
53.
Immersion has suffered and will continue to suffer irreparable injury for which there is no
adequate remedy at law. Immersion has also been damaged and, until an injunction issues, will
continue to be damaged in an amount yet to be determined.
FOURTH CLAIM FOR RELIEF FOR PATENT INFRINGEMENT
(AGAINST DEFENDANT APPLE)
(U.S. Patent No. 7,336,260)
54.
55.
Immersion is the owner of the entire right, title, and interest in and to U.S. Patent
in full.
No. 7,336,260 (the "'260 patent"), entitled "Method and Apparatus for Providing Tactile
Sensations," which was duly issued on Feb. 26, 2008. A copy of the '260 patent is attached as
Exhibit D.
56.
variety of electronic devices such as mobile phones and laptop computers that, among other
things, detect pressures and provide tactile sensations. The '260 patent teaches, among other
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things, systems in which the electronic device detects different levels of pressure on the device
and provide tactile sensations in response. Further details of the invention are described in the
specification and the claims.
57.
Apple has infringed and is currently infringing the '260 patent, in violation of 35
U.S.C. 271, by, among other things, making, using, offering for sale, selling, and/or importing
within this judicial district and elsewhere in the United States, without license or authority,
products and/or processes falling within the scope of one or more claims of the '260 patent,
including without limitation the Apple MacBook, Apple MacBook Pro 13-inch, and Apple
MacBook Pro 15-inch.
58.
Based on the information presently available to it, Immersion alleges that at least
the following apparatuses, products, devices, processes, methods, acts, or other instrumentalities
infringe or are covered by claims of the '260 patent: the Apple MacBook, Apple MacBook Pro
13-inch, and Apple MacBook Pro 15-inch. Immersion makes this preliminary identification of
infringing apparatuses, products, devices, processes, methods, acts, or other instrumentalities
without the benefit of discovery or claim construction in this action, and expressly reserves the
right to augment, supplement, and revise its identifications based on additional information
obtained through discovery or otherwise.
59.
Apple and its customers directly infringe the '260 patent using the Apple
MacBook, Apple MacBook Pro 13-inch, and Apple MacBook Pro 15-inch. The accused devices
include a Force Touch trackpad. The Force Touch trackpad is capable of detecting three or more
different pressure levels associated with a finger touching the trackpad, and the actuator
connected to the Force Touch trackpad can provide tactile sensations based on the three or more
different measured pressure levels.
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60.
Apple also indirectly infringes claims of the '260 patent. Apple is aware of the
'260 patent at least from the date of this Complaint. Additionally, on information and belief,
Apple was aware of the '260 patent before the date of this Complaint, including without
limitation through Apple's knowledge of Immersion, and Immersion's disclosure of its patents on
its
website
(formerly
located
at
http://www.immersion.com/haptics-
to
Apple.
See,
e.g.,
http://www.benzinga.com/analyst-ratings/analyst-
color/13/08/3816746/immersion-others-could-get-a-boost-when-haptics-market-r
("When
it
comes to haptics, Immersion is usually the first company that comes to mind."). Apple knew
that the Apple MacBook, Apple MacBook Pro 13-inch, and Apple MacBook Pro 15-inch
infringed the '260 patent, or at a minimum believed there was a high probability that the Apple
MacBook, Apple MacBook Pro 13-inch, and Apple MacBook Pro 15-inch were covered by the
'260 patent, but willfully blinded itself to Immersion's patent and the infringing nature of the
Apple MacBook, Apple MacBook Pro 13-inch, and Apple MacBook Pro 15-inch.
61.
Apple has induced and is currently actively inducing infringement of the '260
patent, in violation of 35 U.S.C. 271(b), by, among other things, actively and knowingly aiding
and abetting others to directly make, use, offer for sale, sell, and/or import within this judicial
district and elsewhere in the United States, without license or authority, products and/or
processes falling within the scope of one or more claims of the '260 patent, including without
limitation the Apple MacBook, Apple MacBook Pro 13-inch, and Apple MacBook Pro 15-inch.
For example, Apple provides directions, instruction manuals, guides, and/or other materials that
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'260 patent, in violation of 35 U.S.C. 271(c), by, among other things, selling, offering for sale,
and/or importing within this judicial district and elsewhere in the United States, without license
or authority, products or components of products which constitute a material part of the '260
patent, knowing that such products and/or components are especially made or especially adapted
for use in the infringement of the '260 patent, and not staple articles or commodities of
commerce suitable for substantial noninfringing use.
63.
Apple's infringement of the '260 patent has been and continues to be willful and
deliberate. Despite knowledge of the '260 patent, Apple has acted and is acting despite an
objectively high likelihood that its actions constitute patent infringement. This objective risk
was and is known to Apple, and is also so obvious that it should have been known to Apple.
64.
Immersion has suffered and will continue to suffer irreparable injury for which there is no
adequate remedy at law. Immersion has also been damaged and, until an injunction issues, will
continue to be damaged in an amount yet to be determined.
PRAYER FOR RELIEF
WHEREFORE, Immersion prays for judgment as follows:
A.
6251724
- 23 -
B.
C.
That AT&T has directly infringed U.S. Patent Nos. 8,749,507; 7,808,488; and
8,581,710;
D.
E.
That AT&T has induced the infringement of U.S. Patent Nos. 8,749,507;
G.
That AT&T has contributorily infringed U.S. Patent Nos. 8,749,507; 7,808,488;
and 8,581,710;
H.
That Apple and its subsidiaries, parents, officers, directors, agents, servants,
employees, affiliates, attorneys, and all others in active concert or participation with any of the
foregoing be preliminarily and permanently enjoined from further acts of infringement of the
Patents-In-Suit;
I.
That AT&T and its subsidiaries, parents, officers, directors, agents, servants,
employees, affiliates, attorneys, and all others in active concert or participation with any of the
foregoing be preliminarily and permanently enjoined from further acts of infringement of U.S.
Patent Nos. 8,749,507; 7,808,488; and 8,581,710;
J.
L.
That Defendants be ordered to pay supplemental damages to Plaintiff, and pre and
6251724
- 24 -
N.
O.
That the damages be enhanced under 35 U.S.C. 284 to three times the amount
found or measured;
P.
That this be adjudged an exceptional case and that Plaintiff be awarded their
That Plaintiff be awarded such other and further relief as the Court may deem
appropriate.
DEMAND FOR JURY TRIAL
Immersion hereby demands trial by jury on all issues.
Respectfully submitted,
Of Counsel:
FARNAN LLP
Morgan Chu
Richard M. Birnholz
Jason G. Sheasby
IRELL & MANELLA LLP
1800 Avenue of the Stars, Suite 900
Los Angeles, CA 90067
Phone: (310) 277-1010
Fax: (310) 203-7199
mchu@irell.com
rbirnholz@irell.com
jsheasby@irell.com
Lisa Glasser
Babak Redjaian
IRELL & MANELLA LLP
840 Newport Center Drive, Suite 400
Newport Beach, CA 92660
Phone: (949) 760-0991
Fax: (949) 760-5200
lglasser@irell.com
bredjaian@irell.com
Attorneys for Plaintiff Immersion Corporation
6251724
- 25 -
EXHIBIT A
DaCosta et a].
(54)
(56)
References Cited
2,972,140
3,157,853
3,220,121
3,497,668
3,517,446
3,903,614 A
3,911,416 A
4,127,752 A
11/1978 Lowthorp
(Continued)
FOREIGN PATENT DOCUMENTS
EP
EP
0349086
0536715 A2
Aug. 2, 2012
(63)
(51)
Int. Cl.
G09G 5/00
US. Cl.
USPC
(58)
1/1990
4/1993
(Continued)
Adel stein, A Virtual Environment System For The Study of Human
Arm Tremor, Ph.D. Dissertation, Dept. of Mechanical Engineering,
MIT, Jun. 1989.
(Continued)
(52)
Hirsch
Hirsch
Cutler
Hirsch
Carlyon et a1.
OTHER PUBLICATIONS
US 2012/0194472 A1
2/1961
11/1964
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2/1970
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Apr. 6, 2012
(65)
A
A
A
A
A
3,623,064 A
3,902,687 A
(*)
US 8,749,507 B2
(2006.01)
715/701, 702
See application ?le for complete search history.
(57)
ABSTRACT
Processor
>
Various
Interfaces
US 8,749,507 B2
Page 2
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A
A
A
A
A
A
A
A
A
A
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5,889,511
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6,081,536
6,111,577
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A
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A
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3/1999
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US 8,749,507 B2
Page 3
(56)
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OTHER PUBLICATIONS
gies.
Baigrie, Electric Control Loading:A Low Cost. High Performance
Alternative, Proceedings, pp. 247-254, Nov. 6-8, 1990.
Bejczy et al. A Laboratory Breadboard System For Dual-Arm
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US 8,749,507 B2
Page 4
(56)
References Cited
OTHER PUBLICATIONS
* cited by examiner
US. Patent
Sheet 1 0f 4
US 8,749,507 B2
$253, $0thc
on
Hemwo i
.05H
US. Patent
Sheet 3 0f 4
US 8,749,507 B2
m.05
gm
US. Patent
Sheet 4 0f4
US 8,749,507 B2
US 8,749,507 B2
1
CROSS-REFERENCE TO RELATED
APPLICATIONS
SUMMARY
25
BACKGROUND
30
DETAILED DESCRIPTION
35
40
system.
50
55
60
between different users and between the same user; the move
lized.
Capacitance-based touchpads are well known to those
65
US 8,749,507 B2
3
the touchpad 102 may utilize the PS/ 2, Serial, Apple Desktop
25
a ?nger.
35
greater for the ?rst person than for the second person for the
40
55
60
synchronized display.
touchpad 102 may cover a smaller surface area than one held
US 8,749,507 B2
5
processor (106) starts a ?rst tick count 208. The ?rst tick
25
30
(102). The processor (106) may also vary the thresholds based
on the speci?c user who is touching the touchpad (102). The
35
processor (106) may also vary the threshold when the user
40
50
55
60
65
US 8,749,507 B2
7
rithm.
FIG. 3 is a ?ow chart illustrating another process according
to the present invention for detecting a ?nger press on a
touchpad (102).
However, the process shown in FIG. 3 differs from the
process shown in FIG. 2 in several ways. In the embodiment
20
25
30
40
from passing.
A recursive or non-recursive ?lter may be utilized in an
embodiment of the present invention. A non-recursive or
50
55
recognized.
pseudo pressure is compared to a threshold value 322. If the
change in pseudo pressure is less than or equal to the thresh
old, the processor (106) returns to step 302 in the process. If
60
following formula:
ym)
ing the speed to the speed threshold, the processor (106) may
determine that although the user is exerting enough pressure
the data received, and provide the ?ltered data as output. The
digital ?lter is programmable, allowing some signals to pass
cludes that the user is touching 318. If the user was not
?rst tick counter 316 and concludes that the user is touching
step 302.
At step 302, if the processor (106) determines that the
pseudo pressure exceeds the upper threshold, the processor
(106) determines whether the user was previously touching
314. If so, the processor (106) bypasses step 316 and con
[Equation 1]
65
US 8,749,507 B2
10
9
speed and pseudo pressure, and N is set to 5 in ?ltering the
change in pseudo-pressure. These values are related to the
? = N i- 12 Am)
[Equation 2]
W") = 4(n) ?
[Equation 3]
[Equation 4]
PM) _ {0,
p = 2 pm)
[Equation 5]
PM)
[Equation 6]
TABLE 1
Variable
Threshold
32
lower = 16
where:
B is the bias among Mn),
N(n) are the unbiased coe?icients,
upper = 32
AZ
v(n) s O
20
25
Waveform
402
Step
TABLE 2
Reference
1. A method comprising:
receiving contact data from an input device;
Formula
n<N/2
Mn)={0, n=N/2
45
l, n > N / 2
404
Pulw
l,
406
Ramp
408
Triangle
-1, n<N/4,n>3N/4
tic effect.
2. The method of claim 1, wherein the contact data com
prises an actual pressure and a pseudo pressure.
50
device.
5. The method of claim 4, wherein the contact information
Mn) = l 2n/N
410
412
414
416
418
Quarter Cosine
Quarter Sine
Half Cosine
Half Sine
Full Cosine
Mn)
Mn)
Mn)
Mn)
Mn)
=
=
=
=
=
34n/N, n>N/2
sin(nn/2N)
cos(nn/2N)
cos(nn/N)
sin(mn/N)
cos(2nn/N)
further comprises:
60
data.
6. The method of claim 1, wherein the determining a ges
65
US 8,749,507 B2
11
12
device;
comprising:
program code for determining a pres sure and a change in
pressure based on the contact data, and
program code for determining a press if:
the pressure is greater than a pressure threshold,
effect.
15. The system of claim 14, Wherein the contact data com
prises an actual pressure and a pseudo pressure.
25
input device.
18. The system of claim 14, Wherein the processor is con
EXHIBIT B
Martin et al.
(54)
(75)
(56)
References Cited
2,972,140 A
(Continued)
0349086
1/1990
(Continued)
OTHER PUBLICATIONS
Adel stein, A Virtual Environment System For The Study of Human
Arm Tremor, Ph.D. Dissertation, Dept. of Mechanical Engineering,
MIT, Jun. 1989.
2/1961 Hirsch
Milpitas, CA (US)
(22)
*Oct. 5, 2010
Notice:
US 7,808,488 B2
(Continued)
Primary ExamineriRicardo L Osorio
(74) Attorney, Agent, or FirmiKilpatrick Stockton LLP
(57)
ABSTRACT
Oct. 4, 2007
(65)
US 2007/0229455 A1
(63)
(60)
(51)
(52)
(58)
Int. Cl.
G09G 5/00
(2006.01)
345/169; 345/156
345/156,
345/161,163,173,167*169
See application ?le for complete search history.
US 7,808,488 B2
Page 2
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3,157,853
3,220,121
3,497,668
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3,903,614
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4,127,752
4,160,508
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A
A
A
A
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A
A
A
A
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A
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A
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A
A
A
A
A
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4,885,565
4,891,764
4930770
4,934,694
4982918
4,983,786
51019761
5,022,384
5,022,407
5,035,242
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A
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A
A
A
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A
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5,466,213
5,489,812
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5,514,150
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5,575,761
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5,691,747
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5,767,457
5,785,630
5,791,992
5,844,392
5,857,986
5,887,995
5,889,670
5,889,672
5,917,906
5,943,044
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6,078,126
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Peder
Lowthorp
Salisbury, Jr. et 31.
Hall et a1.
Schwellenbach
Prudenziati
Barnes
Cordes et a1.
Forest
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Acklametal.
Boothroyd
Hoshino
Hladky eta1~
Clark
DeVries etal.
Alban
Wihlborg
Adler
Selinko
Jau
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Batsonetal.
Lovell
6,097,964 A
6,111,577 A
6/1989 Mulleretal.
12/1989
V1990
6/1990
6/1990
l/199l
1/1991
5/1991
6/1991
6/1991
7/1991
8/1991
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
Embach
McIntosh
Baker
McIntosh
Kaye
Stevens
Kraft
Freels
Horch er 91Franklin etal.
Szakaly
6,118,435
6,131,097
6,160,439
6,195,592
A
A
A
B1
6,198,206
6,218,966
6,219,034
6,225,976
6,292,173
B1
B1
B1
B1
B1
6,307,465 B1
6,344,791 B1
6,369,803 B2
6,373,463 B1
6,374,255 B1
10/1995
11/1995
2/1996
3/1996
5/1996
5/1996
8/1996
11/1996
5/1997
11/1997
11/1997
V1998
3/1998
6/199g
6/1998
7/1998
g/199g
12/1998
1/1999
3/1999
3/1999
3/1999
6/1999
8/1999
8/1999
11/1999
11/1999
5/2()()()
6/2000
Wang et a1.
Hogan etal.
Furuhata et a1.
Gamer
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Bnohanan etal.
Yamasaki et a1.
Hajianponr
Kramer
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Anlan0
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Sinclair etal
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Crump et a1
Peurach etal.
Moriyasu
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5,053,585 A
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6,388,655 B1
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5,078,152 A
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7/2002 Thorneretal.
5,116,051 A
5,165,897
5,175,459
5,182,557
5,186,695
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5/1992 Moncriefetal-
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6,429,846 B2*
Johnson
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6,543,487
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5,240,417 A
5241308 A
5246316 A
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2002/0128048 A1
2002/0149561 A1
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5,355,148
5,390,128
5,390,296
5,402,499
5,402,680
5,436,622
5,437,607
5,451,924
A
A
A
A
A
A
A
A
A
A
A
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2/1995
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3/1995
4/1995
7/1995
8/1995
9/1995
Pierce et a1.
Everett
Wherlock
Anderson
Ryan et a1.
crandall et a1.
Robison etal.
Korenaga
Gutman et a1.
Taylor
Massimino etal.
0817110
2180342
01003664
H2-185278
02-109714
H4-8381
04007371
H5-192449
1/1998
3/1987
7/1990
7/1990
1/1992
1/1992
8/1993
8/1993
US 7,808,488 B2
Page 3
JP
JP
JP
JP
JP
JP
JP
JP
JP
JP
JP
JP
JP
KR
W0
W0
W0
W0
WO
W0
W0
05-193862
H7-24147
8221173
10171586
1124834
11-085400
2001-222379
2001-265485
2001-290572
2001-296950
2001-350592
2002-259059
2002-528831
2001-0028369
W0 9520787
WO 97/18546
WO 99/49443
WO 01/54109
WO01/91100
WO 02/27645
W0 0231807
A
A
A1
A1
A1
1/1995
1/1995
8/1996
6/1998
1/1999
3/1999
8/2001
9/2001
10/2001
10/2001
12/2001
9/2002
9/2002
4/2001
8/1995
5/1997
9/ 1999
7/2001
11/2001
4/2002
4/2002
OTHER PUBLICATIONS
1970.
1981.
ASME 1992.
US 7,808,488 B2
Page 4
Snow et al., Model-X Force-Re?ecting-Hand-Controller, NT Con
trol No. MPO-17851; JPL Case No. 5348, pp. 1-4, Jun. 15, 1989.
Sep. 5, 2007.
Japanese Patent Of?ce, Response to Notice of Reasons for Rejection
for Jan. 29, 2008, Japanese Patent Application No. 2003-540973,
mailed Feb. 20, 2008.
Of?ce Action dated Jun. 19, 2009 for corresponding Chinese Appli
cation No. 200810008845.X.
* cited by examiner
US. Patent
0a. 5, 2010
Sheet 3 0f 11
FIG.3
US 7,808,488 B2
US. Patent
0a. 5, 2010
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US 7,808,488 B2
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Sheet 7 of 11
Input
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Oct. 5, 2010
US 7,808,488 B2
Sheet 8 0f 11
Access
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Output
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72
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70
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1
CROSS-REFERENCES TO RELATED
APPLICATION
small fonts and graphics that are dif?cult to read and select.
to the user of the touchpad. US. Pat. No. 5,977,867 is one
SUMMARY
20
30
35
40
speci?cation.
50
present invention;
FIG. 9 is a table illustrating a ?rst set of data to be used in
65
US 7,808,488 B2
3
DETAILED DESCRIPTION
tion With input devices are suitable for use in the present
20
35
45
55
60
65
US 7,808,488 B2
5
20
25
30
35
input device 2.
FIG. 2 shoWs another embodiment of the present invention.
An apparatus 60 shoWn in FIG. 2 includes multiple input
devices. These multiple input devices include tWelve ?xed or
40
50
55
60
65
US 7,808,488 B2
7
phone, such buttons 12a, 12b, 120 may be used to navigate the
functions.
In addition, the assignable-function buttons 12a-c are con
that the buttons 12a, 12b are con?gured such that the ?rst
magnitude of pressure is an amount of pressure that signi?es
that a user s ?nger is hovering over, or touching With more
than passing force, the button, and such that the second mag
nitude of pressure is an amount of pressure that signi?es that
a users ?nger applies When the user Wishes to activate the
button. Preferably, the buttons 11a, 11b, 110, 12a, 12b, 120
are con?gured such that they receive and analyZe other data in
determining Whether the user is merely hovering or, instead,
Wishes to activate the button (such as type of, and duration of,
contact With the button). Any suitable input-device may be
used an assignable-function input device. Examples of such
input-devices include rocker-sWitches and scroll Wheels.
In an alternative embodiment (not shoWn), the middle
assignable-function button 120, includes the input device of
FIG. 1. It is in communication With the actuator 6 (not shoWn)
shoWn in FIG. 1 as Well, and operates in the manner described
With reference to FIG. 1. In such an embodiment, the PCB 62
20
frequency.
25
signals at, for example, only tWo of the states. In this Way,
such keys 10 may be con?gured to provide hover/activation
signals similar to that Which is provided in the pre-assigned
50
and understood in the art is used to hold the keys in the rest
US 7,808,488 B2
10
greater pressure is applied to the button 10. The distance of
travel between each position does not have to be equal, and
the amount of pressure required to move betWeen each posi
tion can vary. In addition, for a given key, the number of
positions can vary from tWo (no pressure and activated) up to
to cause the button to move to its second level 25, the ?rst
the fact that the user dWelled at that level for the pre
user has selected the function associated With the second level
of button 101', in this case the selection of the letter W. In
20
25
61 upon receipt of this ?rst signal from the sWitch 19a. The
controller transmits the ?rst controller output signal to the
40
45
55
communicated to the sWitch 1911, at each level 25, 26, 27, 28,
60
PCB 62.
In the embodiment shoWn, a distinct tactile sensation is
65
EXHIBIT C
Heubel et a].
(54)
(75)
2011/0061017 A1
2011/0102160 A1
(*)
Notice:
2002/0098874 A1
2002/0107695 A1
US 8,581,710 B2
W0
W0 99/045531
9/1999
W0
WO 2004/053830
6/2004
W0
WO 2004/102527
11/2004
OTHER PUBLICATIONS
Claimem
I I
* Cited by examiner
(22)
Flled:
sepl 5 2012
(65)
US 2013/0088340 A1
(57)
_
ABSTRACT
_
_
Systems and methods for haptic con?rmation of commands
(63)
(51)
Int Cl
G08B 6/00
(200601)
(52)
U-s- Cl-
(58)
(56)
References Clted
5/1973 Hirsch
6/1998 Van Roekel et a1.
10/2012
It
Memory
115
105
Processor
F
Actuator
13
l1_0
L Microphone
1 5
US. Patent
Sheet 1 0f 7
2
2
8.5
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1
present invention;
CROSS-REFERENCE TO RELATED
APPLICATIONS
DETAILED DESCRIPTION
BACKGROUND
niZed and that the phone Will perform the requested function.
The phone may then attempt to make a phone call to a tele
25
user may hear a beep or see a light ?ash to indicate that the
30
35
the second user over the radio. The second user may be unable
SUMMARY
the ?rst user. The ?rst users radio may receive the haptic
message, and transmit a signal to the actuator in the ?rst user s
headset to cause the actuator to output a haptic effect to the
45 ?rst user.
Commands
50
55
60
65
US 8,581,710 B2
3
may indicate not only that the command Was partially recog
nized, but Which part of the command Was not recognized. For
example, if the date Was not recognized, the device may
output a fourth haptic effect, While if the time Was not recog
nized, the device may output a ?fth haptic effect. Using haptic
signaling, a user may be apprised of di?iculties understand
the actuator 130, Which outputs the ?rst haptic effect based on
the ?rst actuator signal.
HoWever, if the speech information is not recognized, or if
a command corresponding to the speech information is not
found, the processor 110 generates a second actuator signal
con?gured to cause the actuator 130 to output a second haptic
effect. The processor 110 then transmits the second actuator
20
?rst haptic effect is then output very shortly after the user has
said add appointment to calendar to indicate to the user that
25
30
40
45
effects.
For example, in one embodiment, the device 100 com
50
another appointment.
As described above, some embodiments of the present
invention may attempt to recognize speech information as it is
60
example, if the user says call home, the device 100 may
recognize the Word call and determine that it corresponds to
65
US 8,581,710 B2
5
the entire command. For example, the device 100 may Warm
100 may select one or more potential haptic effects that may
niZed.
In addition to handheld embodiments, other devices may
20
25
30
35
40
45
reference.
Referring again to FIG. 2, one embodiment of the present
invention may provide haptic effects that emulate the com
mand determined by the processor 110, 160 or the function
Work. The user may then put the cell phone back in his pocket,
initiate a phone call, or perform some other task. HoWever, the
cell phone may still be able to provide haptic status of the
50
60
65
number dialed and each ring of the phone being called. Actua
tor signals corresponding to the haptic effects are transmitted
US 8,581,710 B2
7
to the processor 110 in the ?rst device 100, Which outputs the
haptic effects, such as at a time corresponding to each button
device 412 can hear the voice command, such as via a speaker
(not shoWn). The user may con?rm that the command Was
recogniZed by pressing a button on device 425 to send a signal
indicating an acknoWledgment that the voice command Was
Wrist. The medical alert device 100 can be used by the user to
indicate a medical emergency, such as a fall or heart attack.
20
25
35
Was received and that help is on the Way. The processor 160
may then transmit a high-level actuator signal to the processor
110 in the medical alert device to cause a haptic effect to be
output. The processor 110 in the medical alert device may
then generate a loW-level actuator signal based on the
received signal from the processor 1 60 and transmit the actua
tor signal to the actuator to cause a haptic effect to be output.
40
45
60
Will comply. The device 412 may then transmit the tactile
response to another device, such as device 410, Which then
converts the tactile response into an audible signal, such as a
ted across the netWork 380 to the processor 160 in the com
been initiated. After the call has been ansWered, the commu
nication device 150 may cause a second haptic effect to be
output to indicate that the call Was ansWered. Alternatively, or
in addition, the dispatcher may cause a signal to be transmit
65
US 8,581,710 B2
10
information. HoWever, if no additional speech information is
received, the method 500 proceeds to step 536.
20
30
35
40
45
50
55
to block 534.
60
cate to the user that the speech information Was not recog
each time the haptic effect is output. Thus, a user Would feel
the same haptic effect about every 30 seconds. HoWever, in
some embodiments, different haptic effects may be output
depending on the status of the function. For example, in one
embodiment, the processor 110 may generate different actua
tor signals each time the method returns to block 542. In such
an embodiment, the processor 110 may generate actuator
65
US 8,581,710 B2
11
12
Which, the method returns to block 510 and the processor 110
attempts to receive more speech information.
Referring noW to FIG. 6, FIG. 6 shoWs a block diagram of
20
ceive the vibration moving to the right across their back and
therefore receive feedback indicating that the command Was
recogniZed.
25
30
40
50
55
60
With the squad but separated due to the nature of the opera
tion. In addition, other locations may monitor the squads
US 8,581,710 B2
14
13
con?gured hardware, such a ?eld-programmable gate array
(FPGA) speci?cally to execute the various methods. For
example, referring again to FIGS. 1-4 and 6, embodiments
ing; and
a processor in communication With the sensor and the
a user input;
20
25
30
35
40
50
55
of the operation.
13. A computer-implemented method comprising the steps
of:
60
user input;
recogniZing the user input and determining a command
a sensor;
65
US 8,581,710 B2
15
16
function.
ther comprising:
generating an audio signal con?gured to cause a speaker to
output a sound; and
EXHIBIT D
(12)
(54)
Martin et al.
3,220,121 A
3,497,688 A
US 7,336,260 B2
Feb. 26, 2008
11/1965 Cutler
2/1970 Hirsch
(Continued)
City, CA
Steven
(US);P-Alex
Vassallo,
S. Goldenberg,
Redwood
Portola Valley, CA (US); Alexander
Jasso, Los Altos, CA (US); Kollin
EP
0349086
(Con?rmed)
OTHER PUBLICATIONS
(US)
(*)
Notice:
I/ 1990
_
(Continued)
(22) Filed:
(57)
(65)
Nov. 1, 2002
ABSTRACT
(51)
52
J 1 151 2002
On u '
'
1e
'
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0
(56)
""
assl ca Ion
P
device or electronic device may be provided in response to
(2006 01)
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Int Cl
GobG /00
(58) F: l'd
(
'
345/169 3 4 5 /1 5 6
345/156
"""
earc
""""""" "
2/1961 Hirsch
3,157,853 A
11/1964 Hirsch
l8
18
35
W Z)
s
34
\_
W A
\
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30
j '4
\_ 34
33\
21
21
20
/
64
13
/
22
US 7,336,260 B2
Page 2
US. PATENT DOCUMENTS
3,517,446 A
3,623,064 A
3902687 A
5,496,174
5,514,150
5521336
5,547,382
3/1996
5/1996
5/1996
8/1996
Garner
Rostoker
Buchanan
Yamasaki et a1.
5,575,761 A
11/1996 Hajianponr
3,903,614 A
3,911,416 A
5,631,861 A
5,684,722 A
4,127,752
4,160,508
4,236,325
4,262,549
4,311,980
4,333,070
11/1978
7/1979
12/1980
4/1981
1/1982
6/1982
5,691,747 A
5,709,219 A
571997
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l1/1997
1/1998
3/1998
6/1998
6/199g
7/1998
A
A
A
A
A
A
9/1975 Hightower
A
A
A
A
Lowthorp
Salsbury
Hall et 31.
Schwellenbach
Prudenziati
Barnes
5,729,249 A
5,766,016 A
5,767,457 A
5,785,630 A
4,362,408 A
5,791,992 A
4,464,117
4,484,191
4,513,235
4,581,491
4,581,972
4,599,070
4692756
4,708,656
4,713,007
4,725,817
4,791,416
4,794,392
4,795,296
4,798,919
4,821,030
4,823,106
4,840,634
4,885,565
4,891,764
4,930,770
4,934,694
4982916
8/1984
11/1984
4/1985
4/1986
4/1986
7/1986
9/1987
11/1987
12/1987
2/1988
12/1988
12/1988
V1989
V1989
4/1989
4/1989
6/1989
12/1989
1/1990
6/1990
6/1990
l/199l
5,844,392
5,857,986
5,887,995
5,889,670
5,889,672
5,917,906
5,943,044
5,945,772
5,977,867
5,988,902
6,059,506
6,078,126
6,097,964
6,111,577
6,118,435
6,131,097
6,160,489
6,195,592
6,198,206
6,218,966
6,219,034
6,225,976
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
Foerst
Vavra
Acklam et 31.
Boothroyd
Hoshino
Hladky er 91
Clark
De Vries et 31.
Alba
Wihlborg
Adler
Selinko
Jau
Suita
Batson
Pope
Muller
Embach
McIntosh
Baker
McIntosh
DuPOIlt
4,983,786 A
1/1991
5,019,761 A
5/1991 Kraft
6,307,465 B1
5,022,384 A
5,022,407 A
6/1991 Freels
6/ 1991 Horch er 91-
6,344,791 B1*
6,369,803 B2*
5,035,242 A
5,038,089
5,053,585
5,078,152
5,116,051
5,165,897
A
A
A
A
A
5,175,459 A
8/1991
10/1991
1/1992
5/1992
11/1992
Stevens
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
B1
B1
B1
B1
B1
6,292,173 B1*
Szakaly
Yaniger
Bond
Moncrief
Johnson
Kramer
Thorner
Anlan0
Chen
Yasutake
Sinclair et 31
Gerpheide
Bobick eta1.
8/1998 clump
12/1998
1/1999
3/1999
3/1999
3/1999
6/1999
8/1999
g/1999
11/1999
11/1999
5/2000
6/2000
8/2000
8/2000
9/2000
10/2000
12/2000
2/2001
3/2001
4/2001
4/2001
5/2001
9/2001
Peurach
Moriyasn
Holehan
Schuler
Schuler
Thornton
Martine11i
Macnak
Bouin
Holehan
Kramer
Rollins
Nuovo
Zilles eta1.
Fujita et a1.
Peurach
Perry eta1.
Schuler
Saarmaa
Goodwin
Elbing et a1.
Yates
Rarnhaldi eta1. ......... .. 345/157
6,373,463 B1
4/2002 Beeks
6,374,255
6,388,655
6,422,941
6,429,846
6,543,487
4/2002
5/2002
7/2002
8/2002
5/2003
B1
B1
B1
B2
B2
6,597,347 B1*
Peurach
Leung
Thornereta1.
Rosenberg
Bazinet
5,182,557 A
V1993 Lang
345/173
5,186,685 A
5212473 A
345/157
345/179
5223658 A
6/1993
5,237,327 A
8/1993 Saitoh
2002/0177471 A1
5,240,417 A
5,241,308 A
5,246,316 A
2002/0033795 A1
2002/0128048 A1
2002/0149561 A1
3/2002 shahoian
9/2002 Aa1tonen
10/2002 Fukumoto eta1.
2002/0171621 A1*
2005/0099393 A1*
Suzuki
5,271,290 A
5,275,174 A
12/1993 Fischer
V1994 (399k
5,283,970 A
5,289,273 A
2/1994 Aigner
2/ 1994 Lang
5,299,810
5,309,140
5,334,027
5,355,148
5,390,128
5,390,296
5,402,499
5,402,680
5,436,622
5,437,607
5,451,924
5,461,711
5,466,213
5,489,812
A
A
A
A
A
A
A
A
A
A
A
A
A
A
4/1994
5/1994
8/1994
10/1994
2/1995
2/1995
3/1995
4/1995
7/1995
8/1995
9/1995
10/1995
11/1995
2/1996
Pierce et a1.
Everett
Wherlock
Anderson
Ryan
Crandall
Robinson
Korenaga
Gntrnan eta1.
Taylor
Massimino
Wang
Hogan eta1.
Furuhata
6,976,562 B1*
12/2005
1/2002 Kaaresoja
01003664
H2-185278
02109714
H4-8381
04007371
H5-192449
05193862
H7-24147
2001350592 A
2002259059 A
W09520787
W0 09718546 A1
W0 02/27645
7/1990
7/1990
1/1992
1/1992
8/1993
8/1993
1/1995
1/1995
12/2001
9/2002
8/1995
5/1997
4/2002
US 7,336,260 B2
Page 3
W0
W0
W0 0231807 A1
W0 019110A1 A1
4/2002
11/2002
OTHER PUBLICATIONS
1993.
nologies.
* cited by examiner
U.S. Patent
Sheet 1 6f 11
US 7,336,260 B2
U.S. Patent
Sheet 2 6f 11
US 7,336,260 B2
U.S. Patent
Sheet 3 6f 11
US 7,336,260 B2
U.S. Patent
Sheet 5 6f 11
FIG.5
US 7,336,260 B2
U.S. Patent
Sheet 6 6f 11
US 7,336,260 B2
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U.S. Patent
Feb. 26,2008
US 7,336,260 B2
Sheet 8 0f 11
Access
Memory
72
Obtain
Ambiguous
Feedback
Info.
Pressure
Data?
Obtain
Pressure
Data
Produce
Tactile
Sensation
FIG.8
U.S. Patent
Sheet 11 6f 11
US 7,336,260 B2
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US 7,336,260 B2
1
RELATED APPLICATIONS
small fonts and graphics that are dif?cult to read and select.
by reference.
20
30
45
FIG. 3;
FIG. 5 is a plan vieW of another electronic device includ
50
FIG. 5;
55
present invention.
60
DETAILED DESCRIPTION
65
US 7,336,260 B2
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phone.
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US 7,336,260 B2
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US 7,336,260 B2
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provided beloW.
the second level from button 101' (the 9 key), the controller
9 sends a ?rst control output signal to the actuator, and When
20
ably, the buttons 11a, 11b, 110, 12a, 12b, 120 are con?gured
such that they receive and analyZe other data in determining
Whether the user is merely hovering or, instead, Wishes to
activate the button (such as type of, and duration of, contact
With the button). Any suitable input-device may be used an
25
frequency.
FIG. 3 shoWs another embodiment of the present inven
tion, in the form of a mobile telephone 14 having the
apparatus of FIG. 2. The controller 9, actuator 61, and the
35
tion), and the pre-assigned buttons 11a, 11b, 11c, and the
1211-120.
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rest position 23. An object 24, for example the users ?nger
or a stylus, is used to select one or more of the keys 10 by
US 7,336,260 B2
10
controller 9. Thus, in the embodiment shoWn, different
signals are transmitted by the sWitch 19a for each pressure
associated With the second level 25 by the fact that the user
dWelled at that level for the pre-determined time. Upon so
determining, the controller 9 transmits a signal to a proces
sor (not shoWn) indicating that the user has selected the
function associated With the second level of button 101', in
this case the selection of the letter W. In embodiments, the
controller 9, upon so determining, also transmits a signal to
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frequency.
When the user applies further pressure to the button 101'
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communicated to the sWitch 19a, at each level 25, 26, 27, 28,
a distinct signal is transmitted by the sWitch 19a to the
US 7,336,260 B2
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Infringement of U.S. Patents US 8,749,507 B2; US 7,808,488 B2; US 8,581,710 B2; and US 7,336,260 B2
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VII. REQUESTED IN
81'(558/()5&Y3
COMPLAINT:
VIII. RELATED CASE(S)
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The Honorable Richard G. Andrews
IF ANY
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