`WASHINGTON, D.C.
`
`Inv. No. 337-TA-990
`
`
`
`
`
`
`
`
`In the Matter of:
`
`CERTAIN MOBILE ELECTRONIC
`DEVICES INCORPORATING HAPTICS
`(INCLUDING SMARTPHONES AND
`SMARTWATCHES) AND
`COMPONENTS THEREOF
`
`
`Immersion’s Preliminary Proposed Claim Constructions and Notice Regarding Expert
`Testimony for Claim Construction and/or Tutorial
`
`Pursuant to the Joint Discovery Statement and the procedural schedule in this
`
`investigation, Immersion hereby provides the following list of its preliminary proposed
`
`claim constructions for the terms identified in the April 28, 2016 Joint List of Claim Terms
`
`to Construe. Immersion reserves the right to modify this list, including by adding or
`
`dropping terms or by modifying its proposed claim construction of any term. Further, at
`
`present, Immersion intends to present expert testimony for claim construction and/or
`
`tutorial, including as may be appropriate to respond to expert testimony presented by other
`
`parties.
`
`Patent
`
`U.S. Patent
`No. 8,773,356
`
`U.S. Patent
`No. 8,619,051
`
`Asserted
`Claims
`1, 11, 12,
`21, 22, 26
`
`1, 10, 12,
`20, 22, 25
`3, 9, 13
`
`Term
`
`"lookup table"
`
`"haptic effect data"
`
`"digitized streamed
`envelope construct"
`
`Immersion's Preliminary Proposed
`Construction
`"data structure containing
`associations between interactions
`and haptic effect data"
`"data identifying or describing a
`tactile sensation"
`"file format containing a stream of
`control information (e.g., voltage
`levels) over time for the stored haptic
`effect, encoded as a sequence of
`bytes"
`
`
`
`APPLE INC.
`EXHIBIT 1003 - PAGE 1
`
`
`
`
`
`Patent
`
`U.S. Patent
`No. 8,659,571
`
`
`
`Term
`
`"the entire haptic
`output in response to
`the [haptic effect]
`request consists of
`the [first/requested
`pre-defined] stored
`haptic effect"
`"stored haptic effect"
`
`"dynamic interaction
`parameter"
`
`Asserted
`Claims
`1, 8, 12
`
`1, 5, 6, 8,
`11, 12, 15
`
`1, 4, 5, 6,
`7, 12, 15,
`16, 17, 18,
`23, 26, 27,
`28, 29
`
`Immersion's Preliminary Proposed
`Construction
`"the haptic output is created from a
`single stored haptic effect, rather
`than by assembling multiple effects"
`
`"haptic effect with pre-defined low-
`level haptic parameters such as
`voltage levels over time (e.g., a
`waveform)"
`"an interaction parameter that
`changes over time or reacts in real
`time"
`
`Dated: June 3, 2016
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`/s/
`Richard Birnholz
`
`Morgan Chu
`Richard Birnholz
`Jason Sheasby
`Lisa Glasser
`Babak Redjaian
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Barbara A. Murphy
`David F. Nickel
`Kandis C. Gibson
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1899 L Street NW #1150
`Washington, DC 20036
`Telephone: (202) 822-4100
`
`Counsel for Complainant
`Immersion Corporation
`
`
`
`APPLE INC.
`EXHIBIT 1003 - PAGE 2
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