throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE, INC.,
` Petitioner,
`vs. Case IPR2016-01372
` Patent No.8,659,571
`IMMERSION CORPORATION,
` Patent Owner.
`________________________/
`
` DEPOSITION OF YON VISELL, Ph.D.
` July 24, 2017
` San Diego, California
`
`REPORTED BY: STEPHANIE WHITEHEAD, CSR, RPR, CRR
` CSR No. 10093
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 1
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`2
`
` I N D E X
`WITNESS EXAMINED BY PAGE
`YON VISELL, Ph.D. MR. WILLIAMS 4
` MR. WELLS 200
`
`DEPOSITION EXHIBIT PAGE
`
`Exhibit 1 Declaration of Yon 7
` Visell, Ph.D., Support of
` Immersion Corporation's Patent
` Owner Response; 36 pages
`Exhibit 2 U.S. Patent No. 8,659,571 8
` dated Feb 25, 2014
`Exhibit 3 Patent application Burrough, 104
` et al., dated Jun 24, 2010;
` 33 pages
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 2
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`

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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`3
`
` On Monday, July 24, 2017 commencing at the hour of
`9:02 a.m., at 401 B Street, in the City of San Diego,
`State of California, before me, Stephanie L. Whitehead,
`Certified Shorthand Reporter in and for the State of
`California, personally appeared:
` YON VISELL, Ph.D.,
`called as a witness by the Petitioner, who, being by me
`first duly sworn, was thereupon examined as a witness in
`said cause.
`
` A P P E A R A N C E S
`FOR PETITIONER APPLE, INC.:
` DLA Piper
` ROBERT C. WILLIAMS, ESQ.
` 401 B Street, Suite 1700
` San Diego, California 92101-4297
` (619)699-2972
`
`FOR IMMERSION CORPORATION:
` Irell & Manella
` C. MACLAIN WELLS, ESQ.
` JAMES A. MILKEY, ESQ.
` 1800 Avenue of the Stars, Suite 900
` Los Angeles, California 90067-4276
` (310) 277-1010
`
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 3
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`

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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`4
`
`San Diego, California; Monday, July 24, 2017; 9:02 a.m.
`
` YON VISELL, Ph.D.,
`HAVING BEEN ADMINISTERED AN OATH, TESTIFIED AS FOLLOWS:
`
` MR. WILLIAMS: Should we start with
`appearances?
` MR. WELLS: Yeah.
` MR. WILLIAMS: I'm Rob Williams with DLA Piper
`representing Petitioner Apple.
` MR. WELLS: MacLain Wells of Irell and Manella,
`and with me is James Milkey of Irell also on behalf of
`Immersion.
`
` EXAMINATION
`BY MR. WILLIAMS:
` Q Good morning, Doctor. Can you please state
`your name for the record.
` A Yon Visell.
` Q And can you please state your address.
` A Oh, 921 West Campus Lane, Goleta, California
`93117.
` Q Do you understand that your testimony today is
`under oath?
` A Yes, I do.
`
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 4
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`5
`
` Q And do you understand that that means you're
`required to provide truthful answers to my questions?
` A Yes, I do.
` Q If you don't understand one of my questions,
`please let me know and I'll try to rephrase.
` A Thank you. I will.
` Q If you do answer one of my questions, I'll
`assume that you understood the question.
` Is that fair?
` A That's fair.
` Q Now you've been deposed before, correct?
` A I have.
` Q And how many times?
` A Just once.
` Q I think I remember that one. And that
`deposition was in the underlying Immersion versus Apple
`ITC investigation. Correct?
` A That's correct.
` Q What did you do to prepare for today's
`deposition?
` A I reviewed my declaration. I reviewed the most
`pertinent patents, particularly the '571 and '818
`patent, the Institution decision, and also met with
`counsel.
` Q Who did you meet with?
`
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`6
`
` A Mr. Wells and Mr. Milkey.
` Q When did you meet?
` A Yesterday.
` Q Was that your only meeting with counsel in
`preparation for today's deposition?
` A That's a good question. I think -- I think so.
`I was just trying to think if we had a phone call prior
`to discuss, but I'm not sure. But I think perhaps not
`this time.
` Q Okay. But yesterday's was your only in-person
`meeting with counsel in preparation for the deposition.
`Correct?
` A Correct.
` Q And how long did that meeting last?
` A Oh, roughly 10:00 a.m., 10:30 a.m. until
`4:00 p.m minus lunch.
` THE WITNESS: Please let me know if I start
`speaking too softly.
` THE REPORTER: Thank you.
`BY MR. WILLIAMS:
` Q You've been engaged in this proceeding as an
`expert for Immersion. Correct?
` A Correct.
` Q And you submitted a declaration along with
`Immersion's patent owner response in this IPR. Correct?
`
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`7
`
` A Correct.
` Q It appears that you may have brought a copy of
`the declaration with you today.
` Is that correct?
` A I did.
` Q Could I take a look at it, please.
` A Of course.
` Q Are there any markings or highlighting in this
`copy?
` A No.
` MR. WILLIAMS: For the purposes of the record
`I'm going to hand you another copy that we're going to
`mark as an exhibit, but feel free to refer to either
`copy you would like.
` THE WITNESS: Thank you.
` MR. WELLS: For the record, Rob, maybe we
`should just use the marked copy just for a clean record.
`We can set this aside.
` MR. WILLIAMS: That's fine with me too.
` (Exhibit 1 was marked for identification.)
`BY MR. WILLIAMS:
` Q So you've just been handed Exhibit 1 to this
`deposition. It's also Exhibit 2009-1 to the IPR
`proceeding.
` Do you recognize this document?
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`8
`
` A I do.
` Q What is it?
` A It's the Declaration of Yon Visell, Ph.D., in
`Support of Immersion Corporation's Patent Owner
`Response.
` Q Okay. And generally speaking, this declaration
`addresses issues relating to the validity of U.S. Patent
`No. 8,659,571. Correct?
` A It addresses issues in response to the petition
`filed by Apple, the declaration of Apple's expert
`witness, and the Institution decision in this case.
` Q Okay. But specifically --
` A But related to the validity of the '571 patent.
` MR. WILLIAMS: I'm going to hand you another
`document. This one we'll mark as Exhibit 2. This
`document is also Exhibit 1001 to this IPR proceeding.
` (Exhibit 2 was marked for identification.)
`BY MR. WILLIAMS:
` Q You recognize this document, right?
` A Yes, this is a copy of the '571 patent.
` Q And the '571 patent is the patent at issue in
`your declaration in this proceeding. Correct?
` A It's the patent about whose claims I've been
`asked to offer opinions specifically in response to the
`materials I mentioned earlier.
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`9
`
` Q In your declaration you provide an overview of
`the '571 patent. Correct? I believe it starts at
`paragraph 29.
` A That's correct.
` Q And the specification of the '571 patent
`describes certain prior art systems for providing haptic
`feedback. Correct?
` A I would say that it describes elements of
`certain prior art -- prior art references, other patents
`that provide haptic feedback.
` Q And let me be a little bit more specific. If
`you could turn to paragraph 30 of your declaration.
` A Yes.
` Q At the bottom of page 9 towards the end of
`paragraph 30 you include a quotation from the '571
`patent specification. Correct?
` A At the bottom of page 9, yeah, I quote the '571
`patent specification with a sentence beginning "Because
`these gestures and system animations."
` Q Correct. And if you could go ahead and read
`that sentence into the record.
` A Sure. "Because these user gestures and system
`animations have variable timing, the correlation to
`haptic feedback in the prior art may be static and
`inconsistent and therefore less compelling to the user."
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`

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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`10
`
` Q Okay. And in this passage, in column 1 of the
`'571 patent, the specification is describing differences
`of the '571 patent from the prior art. Correct?
` MR. WELLS: Objection. Misstates the document.
` THE WITNESS: Looking at the prior art
`reference here.
` Well, as the -- as the next paragraph after the
`one containing that quotation reads "Therefore, there's
`a need for an improved system of providing a dynamic
`haptic effect that includes multiple gestures and device
`sensor signals" speaks to motivation.
`BY MR. WILLIAMS:
` Q Motivation for the '571 patent as compared to
`the prior art. Correct?
` MR. WELLS: Objection. Vague.
` THE WITNESS: I think it's a fairly general
`statement there.
`BY MR. WILLIAMS:
` Q Do you agree that it's the statement of
`motivation for the '571 patent as compared to prior art
`architectures?
` MR. WELLS: Objection. Misstates the document.
` THE WITNESS: I think it's citing that, as the
`passage continues, "There's a further need for providing
`concurrent haptic feedback to multiple devices which are
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`11
`
`connected via a communication link."
` So as the passage says before that, this is
`background information for the patent.
`BY MR. WILLIAMS:
` Q And do you understand the paragraph starting at
`column 1, line 58 as providing the motivation for the
`'571 patent as compared to prior art architectures?
` MR. WELLS: Objection. Vague.
` THE WITNESS: It's not clear what you're
`asking. Your question included the phrase "the
`motivation," which maybe is too specific. I'd say the
`passage more or less speaks for itself.
`BY MR. WILLIAMS:
` Q Do you understand the paragraphs starting at
`column 1, lines 49 and 57 as describing differences
`between the '571 patent invention and prior art
`architectures?
` MR. WELLS: Objection. Vague.
` THE WITNESS: I understand the question of what
`constitutes prior art is a legal question. I'm not
`prepared to comment on that. And this passage doesn't
`specifically refer to differences. One of ordinary
`skill in the art reading this would understand this
`passage to discuss a need for an improved system of
`providing a haptic -- a dynamic haptic effect that
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`12
`
`includes multiple gesture signals and device sensor
`signals. So there's this need.
`BY MR. WILLIAMS:
` Q And is it your opinion that the '571 patent
`provides a solution to that need?
` A In my opinion that question -- that need is so
`broad that it's probably not a specific solution to it.
`But it -- certainly the '571 patent generally -- I think
`it's probably expressed pretty well in the summary of
`the '571 patent.
` It describes a system that "produces a dynamic
`haptic effect and generates a drive signal that includes
`adjustor signal and a real or virtual device sensor
`signal. The haptic effect is modified dynamically based
`on both the adjustor signal and the real or virtual
`device sensor signal," and so on and so forth.
` So the system described in the invention of the
`'571 patent is its own invention. I think this
`background information is useful for understanding the
`context for that.
` Q If we go back to paragraph 30 of your
`declaration.
` A Mm-hmm.
` Q You state that a person of ordinary skill in
`the art would recognize that the approach of the '571
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`13
`
`patent is an improvement over the prior art. And then
`it continues and you cite to the passages in
`column 1 that we've just been looking at. Correct?
` A Correct.
` Q How does the passage at column 1, lines 49 to
`56 reflect that the approach of the '571 patent is an
`improvement over the prior art in your opinion?
` MR. WELLS: Objection. Vague.
` THE WITNESS: The passage you cited doesn't
`describe improvements of the '571 patent; it describes
`background information.
`BY MR. WILLIAMS:
` Q Okay. Can you explain what you meant by the --
`well, let me ask you this: Do you stand by the opinion
`that a person of ordinary skill in the art would
`recognize that the approach of the '571 patent is an
`improvement over the prior art?
` A Yes.
` Q Okay. Can you explain why?
` MR. WELLS: Objection. Vague.
` THE WITNESS: I think I expressed it pretty
`well in my declaration. I can read -- read from that if
`you'd like.
` "Because the '571 patent's techniques can
`improve the timing and/or nature of haptic feedback."
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`14
`
`BY MR. WILLIAMS:
` Q Okay. And how does the passage that you cited
`at column 1, lines 49 to 56 relate to that opinion?
` A It provides context for understanding the field
`in which these -- this invention is taking place.
` Q Let's turn back to column 1, line 49 of the
`'571 patent.
` Are you there?
` A Yes.
` Q Okay. It starts "Traditional architectures
`that provide haptic feedback only with triggered effects
`are available."
` I'll stop there for a moment. Did I read that
`correctly?
` A Yes.
` Q What's your understanding of traditional
`architectures in this passage?
` MR. WELLS: Objection. Vague.
` THE WITNESS: I haven't analyzed that.
` THE REPORTER: I haven't --
` THE WITNESS: I haven't analyzed that. I
`haven't been asked to opine upon what might traditional
`architecture be in this context.
`BY MR. WILLIAMS:
` Q Is it your opinion that traditional
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`15
`
`architectures is referring to prior art?
` MR. WELLS: Objection. Vague.
` THE WITNESS: My understanding is that prior
`art's a legal question. The word "traditional" says
`that they pertain to tradition. So . . . .
`BY MR. WILLIAMS:
` Q So architecture, you would understand that this
`refers to architectures that existed prior to the '571
`patent. Correct?
` MR. WELLS: Objection. Misstates testimony.
` THE WITNESS: Well, traditional architectures
`referring to architectures for a system or interactivity
`model as this patent's described, or as described here.
`So here it's referring to those that produce triggered
`effects as being kind of traditional architectures.
` I don't know that there's a statement. I don't
`know that that's specifically limiting it to the
`situation that you described; i.e., that -- so this
`notion of prior, even excluding the legal question that
`I'm not prepared to comment on, refers to things that
`occurred before. You know, there's nothing to prevent
`you from producing some traditionally designed haptic
`system today. So there's nothing to prevent you from
`inventing a new -- new system with traditional elements
`today.
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`16
`
`BY MR. WILLIAMS:
` Q Okay. Let's go back to your paragraph 30.
` A Mm-hmm.
` Q The passage that you quoted from the '571
`patent that starts "Because these user gestures."
` Do you see that passage in your paragraph 30?
` A Yes. Yes.
` Q There's a bracketed phrase "in the prior art"
`within that quotation.
` Do you see that?
` A Yes.
` Q The bracketed phrase "In the prior art" is not
`present in column 1, lines 49 to 56. Correct?
` A Correct.
` Q The bracketed phrase "in the prior art" is
`something that you added to that quotation. Correct?
` A That's correct.
` Q And you added the bracketed phrase "in the
`prior art" -- well, let me ask you: When you added the
`bracketed phrase "in the prior art," were you referring
`to traditional architectures, the traditional
`architectures that are described at line 1 -- sorry,
`column 1, line 49?
` A I was referring to prior art in the field of
`the invention.
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`17
`
` Q And why is it that a person of ordinary skill
`in the art would understand that the phrase "because
`these user gestures and system animations have variable
`timing, their correlation to haptic feedback may be
`static and inconsistent and therefore less compelling to
`the user in the prior art"?
` A I'm just trying to make sure I understand the
`question.
` Q I'm just trying to understand why you added the
`"in the prior art." I mean, I think I understand, but
`based on our conversation today, I'm not -- I guess I'm
`not entirely sure.
` A I mean, the --
` MR. WELLS: Wait for the question.
` MR. WILLIAMS: Let me ask my question.
` THE WITNESS: Yeah.
`BY MR. WILLIAMS:
` Q Did you add "in the prior art" to this
`quotation from column 1, lines 49 to 56 because one
`skilled in the art would understand that this
`description is referring to prior art systems?
` MR. WELLS: Objection. Vague.
` THE WITNESS: Certainly that phrase can be
`interpreted as shedding light upon as pertaining to the
`prior art. So the preceding phrase in my declaration
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`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`18
`
`says "A person of ordinary skill in the art would
`recognize that the '571 patent" -- I'm sorry. I tend to
`read quickly at times.
` "The approach of the '571 patent is an
`improvement over the prior art because the '571 patent's
`techniques can improve the timing and/or nature of the
`haptic feedback."
` So I'm discussing improvements over the prior
`art there. That's why I added it.
`BY MR. WILLIAMS:
` Q And one skilled in the art would understand
`that this paragraph is discussing improvements over the
`prior art because the passage refers to prior art
`traditional architectures. Correct?
` MR. WELLS: Objection. Vague. Misstates the
`document.
` THE WITNESS: I'd refer back to my earlier
`comment that this passage is providing context for --
`for the invention. And by necessity it's referring to
`things that have been done before.
`BY MR. WILLIAMS:
` Q Okay. Thank you.
` Returning to column 1, line 49, it states
`"Traditional architectures that provide haptic feedback
`only with triggered effects are available." Again,
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 18
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`19
`
`let's stop there.
` What's your understanding of "triggered
`effects"?
` MR. WELLS: Objection. Vague.
` THE WITNESS: I haven't analyzed that question.
`I've been asked to opine on specific issues raised in
`the Apple petition, and particularly in light of the
`validity of the '571 patent.
`BY MR. WILLIAMS:
` Q How would one of ordinary skill in the art
`understand triggered effects at line 50 of column 1?
` MR. WELLS: Objection. Asked and answered.
` THE WITNESS: As I said, I haven't analyzed
`that. I wouldn't feel comfortable analyzing that
`question on the fly.
`BY MR. WILLIAMS:
` Q So you don't know what "triggered effects"
`refers to?
` MR. WELLS: Objection. Misstates testimony.
` THE WITNESS: That's not what I said.
`BY MR. WILLIAMS:
` Q What does "triggered effects" refer to, then?
` MR. WELLS: Objection. Asked and answered.
` THE WITNESS: As I said, I think mainly the
`questions in the case turn on very nuanced definitions.
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 19
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`20
`
`I haven't analyzed this particular terminology from the
`specification because it wasn't raised in the petition
`as far as I can recall. At least it wasn't pertinent to
`the arguments being forwarded.
`BY MR. WILLIAMS:
` Q Well, in your overview of the '571 patent you
`describe the '571 patent as being an improvement over
`the prior art citing to this particular passage from
`column 1, lines 49 to 56. Correct?
` A Correct.
` Q So do you not have an understanding of what the
`prior art systems -- how the prior art systems operated
`that the '571 patent is allegedly an improvement over?
` MR. WELLS: Objection. Vague.
` THE WITNESS: So these phrases can be very
`context-specific. If you want to point me to a
`particular system, I'd be glad to discuss the specific
`meaning of triggered effects. In general I think the
`phrase "triggered effects" speaks for itself.
`BY MR. WILLIAMS:
` Q How does it speak for itself?
` MR. WELLS: Objection. Vague.
` THE WITNESS: It describes an effect that's
`triggered.
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 20
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`21
`
`BY MR. WILLIAMS:
` Q And what can cause a triggered effect in your
`opinion?
` MR. WELLS: Objection. Vague.
` THE WITNESS: It would be very
`context-specific. It would depend on the system.
`BY MR. WILLIAMS:
` Q Have you ever used the phrase "triggered
`effects" in your work?
` A I don't know. I can't recall right now anyway.
`To be clear, I've written several dozen articles. It's
`possible that I've used that phrase somewhere.
` Q Okay. Well, let's look more at this passage
`and see if we can figure out what triggered effects
`means in context. So again, reading from column 1,
`lines 49 -- or starting at line 49 "Traditional
`architectures that provide haptic feedback only with
`triggered effects are available and must be carefully
`designed to make sure the timing of the haptic effect is
`correlated to user initiated gestures or system
`animations."
` Did I read that correctly?
` MR. WELLS: Objection. Misstates the document.
` THE WITNESS: It says "Traditional
`architectures that provide haptic feedback only with
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 21
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`22
`
`triggered effects are available and must be carefully
`designed to make sure the timing of haptic feedback is
`correlated to user initiated gestures or animations."
`BY MR. WILLIAMS:
` Q Okay. So here the patent is describing prior
`art architectures that provide haptic feedback using
`triggered effects that are designed such that haptic
`feedback is correlated to user initiated gestures.
`Correct?
` MR. WELLS: Objection. Misstates the document.
` THE WITNESS: What this passage says is that
`"such architectures are available and must be carefully
`designed for the reasons that are stated."
`BY MR. WILLIAMS:
` Q Okay. And you would agree that traditional
`architectures in which haptic feedback is correlated to
`user initiated gestures were available at the time of
`the '571 patent. Correct?
` MR. WELLS: Objection. Incomplete
`hypothetical.
` THE WITNESS: Sorry. Could you repeat the
`question.
`BY MR. WILLIAMS:
` Q Sure. Would you agree that traditional
`architectures in which haptic feedback is correlated to
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 22
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`23
`
`user initiated gestures were available at the time of
`the '571 patent?
` MR. WELLS: Objection. Vague.
` THE WITNESS: I think the phrase in that
`passage speaks for itself. So traditional architectures
`that provide haptic feedback only with triggered effects
`are available. That was written at the time that the
`'571 patent was drafted.
`BY MR. WILLIAMS:
` Q Okay. And one of ordinary skill in the art
`would understand that traditional architectures that
`provide haptic feedback correlated to user initiated
`gestures existed prior to the '571 patent. Correct?
` MR. WELLS: Objection. Vague. Misstates
`document.
` THE WITNESS: Could you repeat the question.
` MR. WILLIAMS: Could you reread the question,
`please.
` (Record read.)
` MR. WELLS: Objection. Vague. Misstates
`document.
` THE WITNESS: The question you posed is a
`rearrangement of words in the first two sentences of
`that paragraph. I don't know what more you want me to
`say about that.
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 23
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`24
`
`BY MR. WILLIAMS:
` Q Is it true that the '571 patent describes
`traditional architectures that provide haptic feedback
`correlated to user gestures were available prior to the
`'571 patent?
` MR. WELLS: Objection. Misstates document.
`Asked and answered.
` THE WITNESS: I guess I stand by my earlier
`answer there. I think your question is so similar to
`the language that's in this paragraph, there's not much
`for me to add.
`BY MR. WILLIAMS:
` Q So you agree with my question?
` MR. WELLS: Objection. Asked and answered.
`Misstates document.
` THE WITNESS: That's not what I said.
`BY MR. WILLIAMS:
` Q So you disagree with my question?
` A I'm not understanding the question in your
`question.
` Q My question is did systems that provide haptic
`feedback correlated to user gestures exist prior to the
`'571 patent?
` MR. WELLS: Objection. Vague. Asked and
`answered.
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 24
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`25
`
` THE WITNESS: As the patent says, "Traditional
`architectures that provide haptic feedback only with
`triggered effects are available." It goes on to qualify
`it in terms that echo your question.
`BY MR. WILLIAMS:
` Q So is the answer "yes"?
` MR. WELLS: Objection. Asked and answered.
`Misstates testimony, misstates the document.
` THE WITNESS: I think the answer to your
`question is right there in the text. The sentence -- I
`mean, the sentence echoes pretty much many of the words
`used in your question.
` I'm not sure if there's something different
`from what's written there that you're asking.
`BY MR. WILLIAMS:
` Q I'm not trying to ask you a trick question.
`I'm just trying to make sure we have a clear record.
`And I don't understand from your answer when you say
`"echo," whether that means that you agree with my
`question or you disagree.
` A I'm trying to understand.
` MR. WELLS: Hold on a second.
` MR. WILLIAMS: I want to make sure we have a
`clear record. I'm just going to go ahead and ask the
`question again.
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 25
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`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`26
`
` MR. WELLS: And before you do that, I object to
`your colloquy. It is a trick question. So go ahead and
`ask your question.
` MR. WILLIAMS: I'll just ask the question
`again.
`BY MR. WILLIAMS:
` Q Did architectures that provide haptic feedback
`correlated to user initiated gestures exist prior to the
`'571 patent?
` MR. WELLS: Objection. Asked and answered.
`Misstates document.
` THE WITNESS: I think to the extent that your
`question addresses something that's beyond the face
`value of what's written in the patent here, I don't have
`anything particular to add because it would depend on a
`more detailed reading of the terms here. I think at the
`level of background information these phrases kind of
`stand for themselves.
`BY MR. WILLIAMS:
` Q Let's turn back to paragraph 30 of your
`declaration. You quote from column 1 of the '571 patent
`specification "Because these user gestures and system
`animations have variable timing, the correlation of
`haptic feedback in the prior arts may be static and
`inconsistent."
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`APPLE INC. - IPR2016-01372
`Ex. 1015 - Page 26
`
`

`

`Transcript of Yon Visell, Ph.D.
`Conducted on July 24, 2017
`
`27
`
` Did I read that correctly?
` A No. It says "the correlation to haptic
`feedback."
` Q Okay. You would agree that the user gestures,
`at least in this sentence -- strike that.
` At least in this sentence, would you agree that
`in the prior art there were systems in which user
`gestures and system animations had haptic feedback
`correlated with them?
` MR. WELLS: Objection. Vague.
` THE WITNESS: So first, I've been asked to
`render an opinion on the validity of the claims of the
`'571 patent, in particular certain claims that include
`and append to claim 1 which describes dynamic
`interaction parameter is generated from a first gesture
`signal and a second gesture signal. The term "gesture
`signal" is one that's been constructed by the board in a
`very specific way.
` And so to the extent that user gestures are
`refer

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