APPLE INC.
`EXHIBIT 1011 - PAGE 0001
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`EXHIBIT 5
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`EXHIBIT 5
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0001
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`EXHIBIT 1011 - PAGE 0001
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`EXHIBIT 5
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`EXHIBIT 5
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0001
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`
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`U.S. Patent No. 8,659,571
`
`This claim chart applies to all Respondents Apple Inc. ("Apple”) and AT&T Mobility LLC ("AT&T"). The
`*
`activities of Respondents all involve the same Apple products detailed in this chart.
`
`
`Claim Language Apple iPhones
`Apple and AT&T import, sell for importation, and/or sell after importation several versions of
`mobile phones, including the iPhone 6s and iPhone 6s Plus.
`
`1. A method of
`producing a
`haptic effect
`comprising:
`
`
`Ex. 141 at 1 (downloaded from http://www.apple.com/iphone/compare/).
`
`
`1 All citations to exhibits in this claim chart refer to exhibits to the Complaint of Immersion Corporation Under Section 337 of the
`Tariff Act of 1930, filed Feb. 11, 2016.
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`7939754
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0002
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`The Apple iPhone 6s, iPhone 6s Plus, and other models with the same functionality (collectively
`referred to as “Apple iPhones”) infringe this claim by practicing a method of producing a haptic
`effect, as follows.
`
`
`Ex. 14 at 98 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0003
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 136 (downloaded from http://www.apple.com/iphone-6s/technology/).
`
`To the extent the preamble is found to be a limitation, each of the Apple iPhones satisfy the
`limitation(s) of this claim element literally and/or under the doctrine of equivalents.
`
`[a] receiving a
`first gesture
`signal;
`
`The Apple iPhones receive a first gesture signal. See, e.g.,:
`
`The Apple iPhones include a touch screen with 3D Touch capability.
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0004
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`
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`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`
`Ex. 14 at 77 (downloaded from http://www.apple.com/iphone-6s/specs).
`
`
`Ex. 14 at 135-36 (downloaded from http://www.apple.com/iphone-6s/technology/).
`
`A first gesture signal is received, for example, when the user touches or presses lightly on an
`email, photo, web link, etc., that has 3D Touch functionality.
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`7939754
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0005
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`
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`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 98 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`
`Ex. 14 at 135 (downloaded from http://www.apple.com/iphone-6s/technology/).
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`7939754
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`- 5 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0006
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 99 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`- 6 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0007
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 99-100 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`- 7 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0008
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 100 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`- 8 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0009
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 100-01 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`- 9 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0010
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`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`
`
`
`"Tapping, swiping and pinching have forever changed the way we navigate and experience our
`digital world. Until now, these gestures had been defined by a singular plane in two dimensional
`space. For iPhone 6s and 6s Plus we're introducing an entirely new interaction and a whole new
`dimension to the way you experience your iPhone. It's made possible by a technology called 3-D
`Touch. This is the next generation of Multi-touch. For the first time, along with recognizing
`familiar gestures, iPhone also recognizes faults, enabling new gestures, peek and pop."
`
`Ex. 25, video (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`
`“At its heart are capacitive sensors integrated into the backlight of the retina HD display.” Ex. 25,
`video at 2:19 (downloaded from http://www.apple.com/iphone-6s/#product-demo).
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`- 10 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0011
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“With each press, these sensors measure microscopic changes in the distance between the cover
`glass and the backlight.” Ex. 25, video at 2:31 (downloaded from http://www.apple.com/iphone-
`6s/#product-demo).
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`- 11 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0012
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`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`“These measurements are then combined with signals from the touch sensor and accelerometer to
`provide fast, accurate, and continuous response to finger pressure.” Ex. 25, video at 2:37
`(downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`The iOS operating system tracks an object contacting the iPhone touch screen by, for example,
`creating UITouch data structures and passing them to an application’s UIResponder interface.
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0013
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 174 (downloaded from
`https://developer.apple.com/library/ios/documentation/EventHandling/Conceptual/EventHandling
`
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`- 13 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0014
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`
`
`U.S. Patent No. 8,659,571
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`
`Claim Language Apple iPhones
`iPhoneOS/multitouch_background/multitouch_background.html).
`
`A UITouch data structure contains data about the object contacting the iPhone touch screen,
`including data about location, radius, and force of the contact.
`
`Ex. 14 at 215 (downloaded from
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`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0015
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`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`https://developer.apple.com/library/ios/documentation/UIKit/Reference/UITouch_Class/index.ht
`ml#//apple_ref/occ/instp/UITouch/force).
`
`For example, the force associated with the contact can be retrieved by inspecting the force
`property of the UITouch data structure.
`
`Ex. 14 at 216 (downloaded from
`https://developer.apple.com/library/ios/documentation/UIKit/Reference/UITouch_Class/index.ht
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`- 15 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0016
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`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`ml#//apple_ref/occ/instp/UITouch/force).
`
`The force property and other sensor signals may be received from the iPhone touch screen and
`used by applications and the operating system, including in the generation of gesture signals.
`Apple provides example code showing the reception of the sensor signals.
`
`Ex. 14 at 213-14 (downloaded from
`
`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0017
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`https://developer.apple.com/library/ios/samplecode/TouchCanvas/Listings/TouchCanvas_Line_s
`wift.htm).
`
`“Multi-Touch screen
`A few simple gestures—tap, drag, swipe, and pinch—are all you need to use iPhone and its apps.
`
`
`
`3D Touch
`
`With the iPhone 6s and iPhone 6s Plus, you can use 3D Touch to see previews, find useful
`shortcuts, and more.
`
`For example, in Mail, press a message in the mailbox list for a peek at the message contents, then
`slide up to see a list of actions. Or press a little deeper to pop the message open. In Photos, press
`to peek at an image; then swipe up to share or copy it, or press a little deeper to pop the image to
`full screen.
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0018
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`
`
`
`
`
`In some cases you can press an item to get a Quick Actions menu. For example, you can press the
`Camera icon on the Home screen, then choose Take Selfie. Or press a name in Messages, then
`choose to create an email message, make a voice or video call, or send a message.
`
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`7939754
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0019
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`
`
`3D Touch lets you vary the pressure when you draw to change the quality of your lines (in some
`apps). For example, press as you draw in Notes to make a line darker. You can also use 3D
`Touch to turn your keyboard into a trackpad and select text when typing.
`
`Among other things, you can use 3D Touch to:
` View or get information about a location by pressing a pin or an address in Maps.
` View the contents of a playlist in Music by pressing the playlist.
` Preview a webpage by pressing a link.
` Preview a specific note’s content within a list by pressing the note in Notes.
` Preview a video by pressing a thumbnail in Photos.
` Make a Live Photo come to life by pressing it in Photos.
` Access your default card, relevant pass, or last transaction by pressing Wallet on the Home
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`- 19 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0020
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`screen.
` Get more information about movies, TV shows, and music videos in the Videos app by
`pressing a thumbnail.
` Learn how far you’ve read in a book in iBooks by pressing its cover.
` Call, send a message to, or email a contact by pressing his or her phone number in
`Contacts.
` See a list of recommended games by pressing Games in Game Center.
`
`
`Change 3D Touch sensitivity. Go to Settings > General > Accessibility > 3D Touch, then set 3D
`Touch sensitivity to Light, Medium, or Firm.”
`
`Ex. 22 at 3-6, iPhone User Guide for iOS 9.2, at 4-6 (downloaded from
`http://help.apple.com/iphone/9/).
`
`Each of the Apple iPhones satisfies the limitation(s) of this claim element literally and/or under
`the doctrine of equivalents.
`
`[b] receiving a
`second gesture
`signal;
`
`The Apple iPhones receive a second gesture signal. See, e.g.,:
`
`The Apple iPhones include a touch screen with 3D Touch capability.
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`- 20 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0021
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 77 (downloaded from http://www.apple.com/iphone-6s/specs).
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`
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`7939754
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`- 21 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0022
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 135-36 (downloaded from http://www.apple.com/iphone-6s/technology/).
`
`A second gesture signal is received, for example, when the user presses deeply to pop into an
`email, photo, web link, etc.
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`7939754
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`- 22 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0023
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 98 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`
`Ex. 14 at 135 (downloaded from http://www.apple.com/iphone-6s/technology/).
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`7939754
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`- 23 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0024
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 99 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`- 24 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0025
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 99-100 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`- 25 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0026
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 100 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`7939754
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`- 26 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0027
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 100-01 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
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`
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`7939754
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`- 27 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0028
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`
`
`
`"Tapping, swiping and pinching have forever changed the way we navigate and experience our
`digital world. Until now, these gestures had been defined by a singular plane in two dimensional
`space. For iPhone 6s and 6s Plus we're introducing an entirely new interaction and a whole new
`dimension to the way you experience your iPhone. It's made possible by a technology called 3-D
`Touch. This is the next generation of Multi-touch. For the first time, along with recognizing
`familiar gestures, iPhone also recognizes faults, enabling new gestures, peek and pop."
`
`Ex. 25, video (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`
`“At its heart are capacitive sensors integrated into the backlight of the retina HD display.” Ex. 25,
`video at 2:19 (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`7939754
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`- 28 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0029
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`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“With each press, these sensors measure microscopic changes in the distance between the cover
`glass and the backlight.” Ex. 25, video at 2:31 (Downloaded from http://www.apple.com/iphone-
`6s/#product-demo).
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`7939754
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`- 29 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0030
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`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`“These measurements are then combined with signals from the touch sensor and accelerometer to
`provide fast, accurate, and continuous response to finger pressure.” Ex. 25, video at 2:37
`(downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`The iOS operating system tracks an object contacting the iPhone touch screen by, for example,
`creating UITouch data structures and passing them to an application’s UIResponder interface.
`
`7939754
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`- 30 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0031
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 174 (downloaded from
`
`
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`7939754
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`- 31 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0032
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`https://developer.apple.com/library/ios/documentation/EventHandling/Conceptual/EventHandling
`iPhoneOS/multitouch_background/multitouch_background.html).
`
`A UITouch data structure contains data about the object contacting the iPhone touch screen,
`including data about location, radius, and force of the contact.
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`7939754
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`- 32 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0033
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`Ex. 14 at 215 (downloaded from
`https://developer.apple.com/library/ios/documentation/UIKit/Reference/UITouch_Class/index.ht
`ml#//apple_ref/occ/instp/UITouch/force).
`
`For example, the force associated with the contact can be retrieved by inspecting the force
`property of the UITouch data structure.
`
`Ex. 14 at 216 (downloaded from
`
`
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`7939754
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`- 33 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0034
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`https://developer.apple.com/library/ios/documentation/UIKit/Reference/UITouch_Class/index.ht
`ml#//apple_ref/occ/instp/UITouch/force).
`
`The force property and other sensor signals may be received from the iPhone touch screen and
`used by applications and the operating system, including in the generation of gesture signals.
`Apple provides example code showing the reception of the sensor signals.
`
`7939754
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`- 34 -
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0035
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`Ex. 14 at 213-14 (downloaded from
`https://developer.apple.com/library/ios/samplecode/TouchCanvas/Listings/TouchCanvas_Line_s
`wift.htm).
`
`“Multi-Touch screen
`A few simple gestures—tap, drag, swipe, and pinch—are all you need to use iPhone and its apps.
`
`
`
`
`3D Touch
`
`With the iPhone 6s and iPhone 6s Plus, you can use 3D Touch to see previews, find useful
`shortcuts, and more.
`
`For example, in Mail, press a message in the mailbox list for a peek at the message contents, then
`slide up to see a list of actions. Or press a little deeper to pop the message open. In Photos, press
`
`7939754
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`- 35 -
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`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0036
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`to peek at an image; then swipe up to share or copy it, or press a little deeper to pop the image to
`full screen.
`
`
`
`
`
`In some cases you can press an item to get a Quick Actions menu. For example, you can press the
`Camera icon on the Home screen, then choose Take Selfie. Or press a name in Messages, then
`choose to create an email message, make a voice or video call, or send a message.
`
`
`7939754
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`
`- 36 -
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`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0037
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`
`
`3D Touch lets you vary the pressure when you draw to change the quality of your lines (in some
`apps). For example, press as you draw in Notes to make a line darker. You can also use 3D
`Touch to turn your keyboard into a trackpad and select text when typing.
`
`Among other things, you can use 3D Touch to:
` View or get information about a location by pressing a pin or an address in Maps.
` View the contents of a playlist in Music by pressing the playlist.
` Preview a webpage by pressing a link.
` Preview a specific note’s content within a list by pressing the note in Notes.
` Preview a video by pressing a thumbnail in Photos.
` Make a Live Photo come to life by pressing it in Photos.
` Access your default card, relevant pass, or last transaction by pressing Wallet on the Home
`
`7939754
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`- 37 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0038
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`screen.
` Get more information about movies, TV shows, and music videos in the Videos app by
`pressing a thumbnail.
` Learn how far you’ve read in a book in iBooks by pressing its cover.
` Call, send a message to, or email a contact by pressing his or her phone number in
`Contacts.
` See a list of recommended games by pressing Games in Game Center.
`
`
`Change 3D Touch sensitivity. Go to Settings > General > Accessibility > 3D Touch, then set 3D
`Touch sensitivity to Light, Medium, or Firm.”
`
`Ex. 22 at 3-6, iPhone User Guide for iOS 9.2, at 4-6 (downloaded from
`http://help.apple.com/iphone/9/).
`
`Each of the Apple iPhones satisfies the limitation(s) of this claim element literally and/or under
`the doctrine of equivalents.
`
`The Apple iPhones generate a dynamic interaction parameter using the first gesture signal and the
`second gesture signal. See, e.g.,
`
`For example, the Apple iPhones generate a dynamic interaction parameter corresponding to the
`amount of pressure exerted on the touch screen.
`
`- 38 -
`
`
`
`[c] generating a
`dynamic
`interaction
`parameter using
`the first gesture
`signal and the
`second gesture
`signal; and
`
`7939754
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0039
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 98 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`
`Ex. 14 at 135 (downloaded from http://www.apple.com/iphone-6s/technology/).
`
`"Tapping, swiping and pinching have forever changed the way we navigate and experience our
`digital world. Until now, these gestures had been defined by a singular plane in two dimensional
`space. For iPhone 6s and 6s Plus we're introducing an entirely new interaction and a whole new
`dimension to the way you experience your iPhone. It's made possible by a technology called 3D
`Touch. This is the next generation of Multi-touch. For the first time, along with recognizing
`familiar gestures, iPhone also recognizes faults, enabling new gestures, peek and pop. 3D Touch
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`7939754
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`- 39 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0040
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`works on the home screen, giving you short cuts to the things you do frequently. It also works
`inside applications themselves. Press lightly and it gives you a peek at the content. Continue
`pressing and it pops you into the content itself. Sensors embedded in the display read how hard
`you are pressing and react in a smooth, linear way. This is a dynamic system, deeply integrated
`into iOS 9."
`
`Ex. 25, video (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`
`“At its heart are capacitive sensors integrated into the backlight of the retina HD display.” Ex. 25,
`video at 2:19 (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`7939754
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`- 40 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0041
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“With each press, these sensors measure microscopic changes in the distance between the cover
`glass and the backlight.” Ex. 25, video at 2:31 (downloaded from http://www.apple.com/iphone-
`6s/#product-demo).
`
`7939754
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`- 41 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0042
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“These measurements are then combined with signals from the touch sensor and accelerometer to
`provide fast, accurate, and continuous response to finger pressure.” Ex. 25, video at 2:37
`(downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`The iOS operating system tracks an object contacting the iPhone touch screen by, for example,
`creating UITouch data structures and passing them to an application’s UIResponder interface.
`
`7939754
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`- 42 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0043
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 174 (downloaded from
`
`
`
`7939754
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`- 43 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0044
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`https://developer.apple.com/library/ios/documentation/EventHandling/Conceptual/EventHandling
`iPhoneOS/multitouch_background/multitouch_background.html).
`
`A UITouch data structure contains data about the object contacting the iPhone touch screen,
`including data about location, radius, and force of the contact.
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`7939754
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`- 44 -
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`
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0045
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`Ex. 14 at 215 (downloaded from
`https://developer.apple.com/library/ios/documentation/UIKit/Reference/UITouch_Class/index.ht
`ml#//apple_ref/occ/instp/UITouch/force).
`
`For example, the force associated with the contact can be retrieved by inspecting the force
`property of the UITouch data structure.
`
`Ex. 14 at 216 (downloaded from
`
`
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`7939754
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`- 45 -
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`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0046
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`https://developer.apple.com/library/ios/documentation/UIKit/Reference/UITouch_Class/index.ht
`ml#//apple_ref/occ/instp/UITouch/force).
`
`The force property and other sensor signals may be received from the iPhone touch screen and
`used by applications and the operating system, including in the generation of gesture signals.
`Apple provides example code showing the reception of the sensor signals.
`
`7939754
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`- 46 -
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`
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0047
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 213-14 (downloaded from
`https://developer.apple.com/library/ios/samplecode/TouchCanvas/Listings/TouchCanvas_Line_s
`wift.htm).
`
`Each of the Apple iPhones satisfies the limitation(s) of this claim element literally and/or under
`the doctrine of equivalents.
`
`The Apple iPhones apply a drive signal to a haptic output device according to the dynamic
`interaction parameter. See, e.g.,:
`
`The Apple iPhones include a Taptic Engine haptic output device that receives a drive signal
`according to the dynamic interaction parameter.
`
`
`
`[d] applying a
`drive signal to a
`haptic output
`device according
`to the dynamic
`interaction
`parameter.
`
`7939754
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`- 47 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0048
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 17 at 16, photograph from teardown of Apple iPhone 6s #16 (red box added).
`
`7939754
`
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`- 48 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0049
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 17 at 17, photograph from teardown of Apple iPhone 6s (red box added) #17.
`
`7939754
`
`
`- 49 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0050
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`7939754
`
`
`- 50 -
`
`
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0051
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`
`Ex. 17 at 18, photograph from teardown of Apple iPhone 6s #18 (red box added).
`
`
`Ex. 14 at 98 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`
`
`
`Ex. 14 at 136 (downloaded from http://www.apple.com/iphone-6s/technology/).
`
`7939754
`
`
`- 51 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0052
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`"3D Touch works on the home screen, giving you short cuts to the things you do frequently. It
`also works inside applications themselves. Press lightly and it gives you a peek at the content.
`Continue pressing and it pops you into the content itself. Sensors embedded in the display read
`how hard you are pressing and react in a smooth, linear way. This is a dynamic system, deeply
`integrated into iOS 9. You can dip in and out of where you are without losing a sense of your
`context. It provides distinct, tactile feedback for your actions, letting you know exactly what
`you've done and what to expect."
`
`Ex. 25, video (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`
`
`7939754
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`- 52 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0053
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“For a truly communicative experience, we had to develop a more precise level of haptic
`feedback.” Ex. 25, video at 2:50 (downloaded from http://www.apple.com/iphone-6s/#product-
`demo).
`
`7939754
`
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`- 53 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0054
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`
`
`
`7939754
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`- 54 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0055
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“While the vibrating system on a typical phone requires 10 or more oscillations to reach full
`power, the Taptic Engine in iPhone 6s reaches peak output in just one cycle and stops just as
`quickly.” Ex. 25, video at 2:57 (downloaded from http://www.apple.com/iphone-6s/#product-
`demo).
`
`7939754
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`
`- 55 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0056
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`
`
`
`7939754
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`- 56 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0057
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`“This allows us to create shorter, more distinct feedback events, like a mini-tap lasting just 10
`milliseconds, and a full tap, which lasts 15 milliseconds.” Ex. 25, video at 3:13 (downloaded
`from http://www.apple.com/iphone-6s/#product-demo).
`
`The Taptic Engine is connected to the motherboard and coupled to the various processors in the
`Apple iPhones. The actuator may be driven by a drive circuit, e.g., the Qualcomm PMD9635 or
`Dialog 338S00120-A1 power management chips coupled to the A9 processor.
`
`Ex. 17 at 21, photograph from teardown of Apple iPhone 6s #21.
`
`
`
`7939754
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`- 57 -
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`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0058
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`
`Ex. 17 at 22, photograph from teardown of Apple iPhone 6s #22.
`
`Each of the Apple iPhones satisfies the limitation(s) of this claim element literally and/or under
`the doctrine of equivalents.
`
`In the Apple iPhones, the first or second gesture signal comprises a vector signal. One or more of
`the the gesture signals generated when a user touches or presses lightly on an email, photo, web
`link, etc. that has 3D Touch functionality, or presses deeply to pop into an email, photo, web link,
`etc. contain both a magnitude and direction quantity. See, e.g.:
`
`- 58 -
`
`
`
`2. The method of
`claim 1 wherein
`the first or second
`gesture signal
`comprises a
`
`7939754
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0059
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`vector signal.
`
`
`“At its heart are capacitive sensors integrated into the backlight of the retina HD display.” Ex. 25,
`video at 2:19 (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`
`“With each press, these sensors measure microscopic changes in the distance between the cover
`
`7939754
`
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`- 59 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0060
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`glass and the backlight.” Ex. 25, video at 2:31 (downloaded from http://www.apple.com/iphone-
`6s/#product-demo).
`
`
`
`“These measurements are then combined with signals from the touch sensor and accelerometer to
`provide fast, accurate, and continuous response to finger pressure.” Ex. 25, video at 2:37
`(downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`For example, the iOS operating system tracks vector quantities associated with a touch, which are
`used to build gesture signals. See, e.g.:
`
`7939754
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`
`- 60 -
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`
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`APPLE INC.
`EXHIBIT 1011 - PAGE 0061
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 174 (downloaded from
`https://developer.apple.com/library/ios/documentation/EventHandling/Conceptual/EventHandling
`iPhoneOS/multitouch_background/multitouch_background.html).
`
`
`
`7939754
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`
`- 61 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0062
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`A UITouch data structure contains data about the object contacting the iPhone touch screen,
`including data about location, radius, and force of the contact.
`
`
`
`7939754
`
`
`
`
`- 62 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0063
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`In particular, the iOS operating system tracks both the current and previous location of a touch
`event, expressing a movement direction during the progress of a multi-touch event. See, e.g.:
`
`
`https://developer.apple.com/library/ios/documentation/EventHandling/Conceptual/EventHandling
`iPhoneOS/multitouch_background/multitouch_background.html
`
`Each of the Apple iPhones satisfies the limitation(s) of this claim element literally and/or under
`the doctrine of equivalents.
`
`3. The method of In the Apple iPhones, the first or second gesture signal comprises an on-screen signal. One or
`
`7939754
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`- 63 -
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`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0064
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`claim 1 wherein
`more of the the gesture signals generated when a user touches or presses lightly on an email,
`the first or second
`photo, web link, etc. that has 3D Touch functionality, or presses deeply to pop into an email,
`gesture signal
`photo, web link, etc. are based on on-screen interactions between the user’s finger and the
`touchscreen. See, e.g.:
`comprises an on-
`screen signal.
`
`
`Ex. 14 at 98 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`
`Ex. 14 at 135 (downloaded from http://www.apple.com/iphone-6s/technology/).
`
`
`
`7939754
`
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`- 64 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0065
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 99 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`7939754
`
`
`- 65 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0066
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 99-100 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`7939754
`
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`- 66 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0067
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`Ex. 14 at 100 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`7939754
`
`
`- 67 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0068
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`Ex. 14 at 100-01 (downloaded from http://www.apple.com/iphone-6s/3d-touch/).
`
`
`
`7939754
`
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`- 68 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0069
`
`
`
`Claim Language Apple iPhones
`
`U.S. Patent No. 8,659,571
`
`
`
`“At its heart are capacitive sensors integrated into the backlight of the retina HD display.” Ex. 25,
`video at 2:19 (downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`
`“With each press, these sensors measure microscopic changes in the distance between the cover
`
`7939754
`
`
`- 69 -
`
`
`
`APPLE INC.
`EXHIBIT 1011 - PAGE 0070
`
`
`
`U.S. Patent No. 8,659,571
`
`
`Claim Language Apple iPhones
`glass and the backlight.” Ex. 25, video at 2:31 (downloaded from http://www.apple.com/iphone-
`6s/#product-demo).
`
`
`
`“These measurements are then combined with signals from the touch sensor and accelerometer to
`provide fast, accurate, and continuous response to finger pressure.” Ex. 25, video at 2:37
`(downloaded from http://www.apple.com/iphone-6s/#product-demo).
`
`Each of the Apple iPhones satisfies the limitation(s) of this claim element literal
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