Case IPR2016-00896
`Patent No. 8,659,571
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`
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`APPLE INC.,
`Petitioner,
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`v.
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`IMMERSION CORPORATION,
`Patent Owner.
`___________________
`
`Case IPR2016-00896
`Patent No. 8,659,571
`___________________
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`
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`DECLARATION OF YON VISELL, PH.D.
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`IN SUPPORT OF IMMERSION CORPORATION’S
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`PATENT OWNER PRELIMINARY RESPONSE
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`TABLE OF CONTENTS
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`I. 
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`II. 
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`INTRODUCTION ........................................................................................ 1 
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`SUMMARY OF OPINIONS ........................................................................ 1 
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`III.  QUALIFICATIONS AND EXPERIENCE .................................................. 3 
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`IV.  LEVEL OF ORDINARY SKILL IN THE ART .......................................... 6 
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`V. 
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`LEGAL PRINCIPLES .................................................................................. 7 
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`A. 
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`B. 
`
`C. 
`
`Claim Construction ............................................................................ 7 
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`Anticipation ........................................................................................ 8 
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`Obviousness ........................................................................................ 9 
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`VI.  THE ’571 PATENT ...................................................................................... 9 
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`VII.  CLAIM CONSTRUCTION ....................................................................... 12 
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`A. 
`
`B. 
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`“gesture signal” (claims 1-7, 23-29) ................................................ 12 
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`“dynamic interaction parameter” (claims 1, 4-7, 12, 15-18,
`23, 26-29) ......................................................................................... 13 
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`C. 
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`“vector signal” (claims 2, 13, 24) ..................................................... 14 
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`VIII.  GROUND 1: POUPYREV DOES NOT RENDER CLAIMS 1-4, 7,
`23-26 and 29 OBVIOUS UNDER 35 U.S.C. § 103(a) .............................. 14 
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`A. 
`
`B. 
`
`C. 
`
`D. 
`
`E. 
`
`F. 
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`Poupyrev does not disclose or render obvious claim 1 .................... 14 
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`Poupyrev does not disclose or render obvious claim 2 .................... 22 
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`Poupyrev does not disclose or render obvious claim 3 .................... 24 
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`Poupyrev does not disclose or render obvious claim 4 .................... 24 
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`Poupyrev does not disclose or render obvious claim 7 .................... 25 
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`Poupyrev does not disclose or render obvious claims 23-26
`or 29 .................................................................................................. 26 
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`IX.  GROUNDS 2-3: POUPYREV IN VIEW OF OTHER
`REFERENCES DOES NOT RENDER CLAIMS 5-6 AND 27-28
`OBVIOUS UNDER 35 U.S.C. § 103(a) .................................................... 27 
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`X. 
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`CONCLUSION ........................................................................................... 27 
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`1.
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`I, Yon Visell, declare as follows:
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`Case IPR2016-00896
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`I.
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`INTRODUCTION
`2.
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`I have been engaged by Immersion Corporation (“Immersion”) as an
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`expert in connection with matters raised in the Petition for Inter Partes Review
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`(“Petition”) of U.S. Patent No. 8,659,571 (the “’571 patent”) filed by Apple Inc.
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`(“Apple” or “Petitioner”).
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`3.
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`This declaration is based on the information currently available to me.
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`To the extent that additional information becomes available, I reserve the right to
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`continue my investigation and study, which may include a review of documents
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`and information that may be produced, as well as testimony from depositions that
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`have not yet been taken.
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`II.
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`SUMMARY OF OPINIONS
`4.
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`The ’571 patent is entitled “Interactivity Model for Shared Feedback
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`on Mobile Devices.” The ’571 patent is directed to a novel way of producing
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`haptic effects in electronic devices. The fundamental insight that is described and
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`claimed in the ’571 patent is that the user’s gesture interactions with the device
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`need to be tracked and analyzed in order to properly synchronize haptic feedback
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`with a user’s input. Reflecting this focus, the claims specify that both a first and a
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`second gesture signal (each based on a user’s gestural inputs) are used to generate
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`something called a “dynamic interaction parameter.” The petition challenges
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`claims 1-7 and 23-29 of the ’571 patent.
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`5.
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`The petition raises three grounds, each based on obviousness under
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`pre-AIA 35 U.S.C. § 103(a). Ground 1 argues that claims 1-4, 7, 23-26 and 29 of
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`the ’571 patent are obvious in light of U.S. Patent No. 7,952,566 (“Poupyrev”), Ex.
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`1013. Based on studying the petition and the exhibits cited in the petition as well
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`as other documents, it is my opinion that claims 1-4, 7, 23-26 and 29 of the ‘571
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`patent are not rendered obvious by Poupyrev.
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`6.
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`Ground 2 argues that claims 5 and 27 are obvious in light of Poupyrev
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`and A FORCE FEEDBACK PROGRAMMING PRIMER by Louis Rosenberg (“Primer”),
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`Ex. 1017. Based on studying the petition and the exhibits cited in the petition as
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`well as other documents, it is my opinion that claims 5 and 27 are not rendered
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`obvious by Poupyrev in view of Primer.
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`7.
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`Ground 3 argues that claims 6 and 28 are obvious in light of Poupyrev
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`and Canadian Patent App. No 2,059,893 A1 (“Tecot”), Ex. 1015. Based on
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`studying the petition and the exhibits cited in the petition as well as other
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`documents, it is my opinion that claims 6 and 28 are not rendered obvious by
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`Poupyrev in view of Tecot.
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`8.
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`Grounds 4 and 5 argue invalidity of claims 1-6 and 23-29 in view of
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`U.S. Patent No. 5,734,373 (“Rosenberg ‘373,” Ex. 1004) alone, or in combination
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`with U.S. Patent No. 6,429,846 (“Rosenberg ‘846,” Ex. 1006). I understand that
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`these grounds are duplicative with grounds that the Board has previously denied,
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`and Immersion has not asked me to evaluate these grounds as part of this
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`declaration. If the Board decides to institute a trial on these grounds, I reserve the
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`right to provide opinions regarding Petitioner’s grounds 4 and 5.
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`III. QUALIFICATIONS AND EXPERIENCE
`9.
`I obtained my Ph.D. degree in Electrical and Computer Engineering
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`from McGill University in 2011. Before that, I received my MA in Physics from
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`the University of Texas at Austin in 1999, and my BA in Physics from Wesleyan
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`University in 1995.
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`10. Since 2015, I have worked as an Assistant Professor at UCSB. From
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`2013 to 2015, I worked as an Assistant Professor in the Department of Electrical
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`and Computer Engineering at Drexel University.
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`11. At UCSB, I lead the RE Touch Lab as its Director and Principal
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`Investigator. The RE Touch Lab includes six Ph.D. students and numerous
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`affiliated researchers and undergraduate students. Some of the topics that my
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`teams at the RE Touch Lab have explored include computational perception, such
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`as how the mechanical signatures of contact elicit conscious perception of touch,
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`and the creation of novel haptic devices for simulating the feel of touched objects.
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`12. My personal research focuses on haptic engineering, robotics, and the
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`mechanics and neuroscience of touch. My work is motivated by creative
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`applications in haptic human-computer interaction, sensorimotor augmentation,
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`and interaction in virtual reality.
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`13.
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`In addition to my research at the RE Touch Lab, I also teach classes,
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`including linear and nonlinear control systems, haptics, human-computer
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`interaction, interactive arts, artificial intelligence, and robotics.
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`14.
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`I am the author of over 60 articles in journals and conference
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`proceedings. I hold one issued patent, U.S. Patent No. 9,041,521 (“Floor-Based
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`Haptic Communication System”), and one pending patent application (“Stretchable
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`Tactile Sensing Array”), both pertaining to haptic technology. I am the editor of
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`two books on virtual reality, including Human Walking in Virtual Reality. I have
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`received several awards and honors, including the Google Faculty Research Award
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`in 2016, and several best paper awards at haptics symposia. I have chaired and
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`edited several conferences and symposia.
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`15.
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`I also have experience working in industry. Before receiving my
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`Ph.D., I worked for several years as the Principal DSP developer, audio at Ableton,
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`a renowned music software company. Before that I worked for several years as a
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`Research Scientist investigating speech recognition at Loquendo Inc., which is
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`now part of Nuance.
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`16. My curriculum vitae is attached as Exhibit 2006.
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`17.
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`I am being compensated by Immersion for my time spent in
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`developing this declaration at a rate of $400 per hour, and for any time spent
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`testifying in connection with this declaration at a rate of $500 per hour. My
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`compensation is not contingent upon the substance of my opinions, the content of
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`this declaration or any testimony I may provide, or the outcome of the inter partes
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`review or any other proceeding.
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`18.
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`I have no financial interest in Immersion, and have financial interests
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`of less than $3000 in Apple through long-term mutual fund investments
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`representing less than 1% of my portfolio.
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`19. My opinions expressed in this declaration are based on the petition
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`and exhibits cited in the petition, and other documents and materials identified in
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`this declaration, including the ’571 patent and its prosecution history, the prior art
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`references and materials discussed in this declaration, and any other references
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`specifically identified in this declaration.
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`20.
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`I am aware of information generally available to, and relied upon by,
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`persons of ordinary skill in the art at the relevant times, including technical
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`dictionaries and technical reference materials (including, for example, textbooks,
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`manuals, technical papers, articles, and relevant technical standards).
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`21.
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`I reserve the right to supplement my opinions to address any
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`information obtained, or positions taken, based on any new information that comes
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`to light throughout this proceeding.
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`IV. LEVEL OF ORDINARY SKILL IN THE ART
`22.
`It is my understanding that the ’571 patent should be interpreted based
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`on how it would be read by a person of ordinary skill in the art at the time of the
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`effective filing date of the application. It is my understanding that factors such as
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`the education level of those working in the field, the sophistication of the
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`technology, the types of problems encountered in the art, the prior art solutions to
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`those problems, and the speed at which innovations are made may help establish
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`the level of skill in the art.
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`23.
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`I am familiar with the technology at issue and the state of the art at the
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`earliest priority date of the ’571 patent.
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`24.
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`It is my opinion, based upon a review of the ’571 patent, its file
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`history, and my knowledge of the field of the art, a person of ordinary skill in the
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`art for the field of the ’571 patent would have at least: (1) a Bachelor's of Science
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`degree in an engineering discipline such as Mechanical Engineering or Computer
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`Science, or (2) at least two years' experience working with human machine
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`interface systems, graphical user interfaces, haptic feedback systems, robotics,
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`biomechanics, or mobile devices or equivalent embedded systems. A person of
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`ordinary skill in the art would also have experience in haptic response technology
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`in multi-touch or multi-gesture systems. This level of skill is commensurate with
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`the interdisciplinary nature of the ’571 patent, which combines knowledge of
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`computer software and user interface design with knowledge of electrical and/or
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`mechanical systems for producing haptic effects.
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`25.
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`I have considered the issues discussed in the remainder of this
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`declaration from this perspective of a person of ordinary skill in the art. Although
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`I use this perspective, I do not believe that any of my opinions would change if a
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`slightly higher or lower level of skill were assumed.
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`V. LEGAL PRINCIPLES
`A. Claim Construction
`26.
`I am not a patent attorney and my opinions are limited to what I
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`believe a person of ordinary skill in the art would have understood, based on the
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`patent documents. I use the principles below, however, as a guide in formulating
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`my opinions.
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`27. My understanding is that a primary step in determining validity of
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`patent claims is to properly construe the claims to determine claim scope and
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`meaning.
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`28.
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`In an inter partes review proceeding, as I understand from Immersion
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`counsel, claims are to be given their broadest reasonable construction (“BRC”) in
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`light of the patent’s specification. 37 C.F.R. § 42.100(b). In other forums, such as
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`in federal courts, different standards of proof and claim interpretation control,
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`which are not applied by the patent office for inter partes review. Accordingly, I
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`reserve the right to argue for a different interpretation or construction of the
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`challenged claims in other proceedings, as appropriate.
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`29.
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`It is my understanding that in determining whether a patent claim is
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`anticipated or obvious in view of the prior art, the patent office must construe the
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`claim by giving the claim its broadest reasonable construction consistent with the
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`specification. For the purposes of this review, I have construed each claim term in
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`accordance with its plain and ordinary meaning under the required broadest
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`reasonable construction.
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`B. Anticipation
`30.
`It is my understanding that a claim is anticipated under 35 U.S.C. §
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`102 if each and every element and limitation of the claim is found either expressly
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`or inherently in a single prior art reference. I understand that anticipation is a
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`question of fact. I further understand that the requirement of strict identity
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`between the claim and the reference is not met if a single element or limitation
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`required by the claim is missing from the applied reference.
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`C. Obviousness
`31.
`It is my understanding that a claim is unpatentable under 35 U.S.C. §
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`103 if the claimed subject matter as a whole would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention. I understand that the
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`determination of obviousness is made with respect to the subject matter as a whole,
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`not separate pieces of the claim. I understand that obviousness is a question of law
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`based on underlying factual issues. I also understand that an obviousness analysis
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`takes into account the scope and content of the prior art, the differences between
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`the claimed subject matter and the prior art, the level of ordinary skill in the art at
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`the time of the invention, and the existence of secondary consideration such as
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`commercial success or long-felt but unresolved needs.
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`VI. THE ’571 PATENT
`32.
`I have read and reviewed the ’571 patent and have an understanding
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`of its background as well as its particular improvements over the prior art. I
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`understand that the ’571 patent is entitled “Interactivity Model for Shared
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`Feedback on Mobile Devices.” In my opinion, the ’571 patent is directed to a
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`novel way of producing haptic effects in electronic devices. A person of ordinary
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`skill in the art would recognize that a fundamental insight that is described and
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`claimed in the ’571 patent is that the user’s gestural interactions with the device
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`need to be tracked and analyzed in order to properly synchronize haptic feedback
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`with a user’s input. Reflecting this focus, the claims specify that both a first and a
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`second gesture signal (each based on a user’s gestural inputs) are used to generate
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`something called a “dynamic interaction parameter.” Ex. 1001 at claim 1
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`(“receiving a first gesture signal; receiving a second gesture signal; generating a
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`dynamic interaction parameter using the first gesture signal and the second gesture
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`signal”). I understand that given the format of the claims, a single gesture signal is
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`insufficient to form the dynamic interaction parameter.
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`33.
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`In my opinion, the dynamic interaction parameter is meant to
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`accurately and responsively track the user’s behavior. As such, a person of
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`ordinary skill in the art would understand that the dynamic interaction parameter
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`changes or reacts in real time to the user’s interactions, and is used to alter the
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`haptic effects produced by the device. This allows the device to provide
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`responsive haptic feedback to the user. Ex. 1001 at 1:29-33 (“[V]ibrotactile haptic
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`effects . . . may be useful in providing cues to users of electronic devices to alert
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`the user to specific events, or provide realistic feedback to create greater sensory
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`immersion within a simulated or virtual environment.”). A person of ordinary skill
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`in the art would recognize that the approach of the ’571 patent is an improvement
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`over the prior art because the ’571 patent’s techniques can improve the timing
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`and/or nature of haptic feedback: “[B]ecause these user gestures and system
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`animations have variable timing, the correlation to haptic feedback [in the prior art]
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`may be static and inconsistent and therefore less compelling to the user.” Id. at
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`1:49-56.
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`34. Other ingredients may be used in addition to a first gesture signal and
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`a second gesture signal to generate the dynamic interaction parameter. For
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`example, additional device sensor signals may be used. Id. at claim 7. A person of
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`ordinary skill in the art would recognize that using these additional ingredients is
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`another improvement over the prior art. E.g., id. at 1:56-60 (“Further, device
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`sensor information is typically not used in combination with gestures to produce
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`haptic feedback.”). The various ingredients may be combined and processed in
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`several different ways to generate the dynamic interaction parameter. See, e.g., id.
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`at Table 2 (listing 14 different example “methods of synthesis” that may be
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`employed). In my opinion, the dependent claims of the ’571 patent show that the
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`generation of the dynamic interaction parameter using both a first gesture signal
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`and a second gesture signal, including the selection and processing of the
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`ingredients, is the inventive focus. A person of ordinary skill in the art reading the
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`patent would understand that the claims require specific ingredients in specific
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`numbers to be used to generate the dynamic interaction parameter. E.g., id. at
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`claim 7 (“receiving a first device sensor signal; receiving a second device sensor
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`signal; and wherein generating a dynamic interaction parameter comprises
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`generating a dynamic interaction parameter using the first gesture signal and the
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`second gesture signal and the first device sensor signal and the second device
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`sensor signal”).
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`35. Once the dynamic interaction parameter has been generated using a
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`first gesture signal, a second gesture signal, and potentially other ingredients, it is
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`used to modify the haptic output of the system. Id. at 15:8-9 (“At 1313, a drive
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`signal is applied to a haptic actuator according to the interaction parameter.”); see
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`also claim 1 (“applying a drive signal to a haptic output device according to the
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`dynamic interaction parameter”). For example, in one embodiment, a user may
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`scroll between different film frames on an electronic device with a touchscreen,
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`and may receive haptic feedback for that interaction. Id. at 13:56-61 (“By using
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`gestures or device sensor data, a user may scroll the filmstrip from left to right or
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`right to left, and the filmstrip application may then dynamically provide a haptic
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`effect for a first photograph 1101 which is different from a haptic effect for a
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`second photograph 1103 based upon the gestures or device sensor data.”).
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`VII. CLAIM CONSTRUCTION
`A.
`“gesture signal” (claims 1-7, 23-29)
`36.
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`In IPR2016-01372, the Board construed gesture signal to mean “a
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`signal indicating a movement of the body that conveys meaning or user intent.”
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`IPR2016-01372, Paper 7 at 12. I apply that construction in this declaration.
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`37.
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`It is also my opinion that the distinction between signals that do and
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`do not indicate a movement of the body that conveys meaning or user intent was
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`also made by the applicant during prosecution. See Ex. 2005 at 9 (August 2, 2012
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`Applicant Remarks in prosecution of U.S. Patent No. 8,279,193, a prior patent in
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`the same family as the ’571 patent) (“[Prior art reference raised by the examiner]
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`Marvit describes gestures in the context of motion sensor engagement for a
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`handheld device. For example, input movement may be in the form of translation
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`and/or gestures. Translation-based input focuses on a beginning point and
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`endpoint of a motion and difference between such beginning points and
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`endpoints.”). A person of ordinary skill in the art reading this section of the
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`prosecution history would understand that the applicant’s comments, in addition to
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`the disclosure of the Marvit reference, show that translation input is not necessarily
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`a gesture signal because it may not convey the requisite meaning or user intent that
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`the Board has held must be signified by a “gesture signal.”
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`B.
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`“dynamic interaction parameter” (claims 1, 4-7, 12, 15-18, 23, 26-
`29)
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`38.
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`In IPR2016-01372, the Board construed this term to mean “a
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`parameter that changes over time or reacts in real time based on a user’s interaction
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`with a device.” I apply that construction in this declaration.
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`“vector signal” (claims 2, 13, 24)
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`It is my opinion that the broadest reasonable construction of “vector
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`C.
`39.
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`signal” is “a signal that includes both a magnitude and direction.” See, e.g.,
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`Petition at 5. I apply that construction in this declaration.
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`VIII. GROUND 1: POUPYREV DOES NOT RENDER CLAIMS 1-4, 7, 23-
`26 AND 29 OBVIOUS UNDER 35 U.S.C. § 103(A)
`40.
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`It is my opinion that Apple has failed to establish that Poupryev,
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`standing alone, renders these claims obvious for at least the reasons expressed
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`below.
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`A.
`41.
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`Poupyrev does not disclose or render obvious claim 1
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`In my opinion, Apple has failed to show that Poupyrev renders any
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`challenged claim of the ’571 patent obvious under pre-AIA 35 U.S.C. § 103(a).
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`Claim 1 of the ’571 patent requires that both a “first gesture signal” and a “second
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`gesture signal” be received, and that both of these signals are used in generating
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`the “dynamic interaction parameter.” Claim 1 reads:
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`1.
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`A method of producing a haptic effect comprising:
`receiving a first gesture signal;
`receiving a second gesture signal;
`generating a dynamic interaction parameter using the first
`gesture signal and the second gesture signal; and
`applying a drive signal to a haptic output device according to
`the dynamic interaction parameter.
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`Ex. 1001 at claim 1.
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`Case IPR2016-00896
`Patent No. 8,659,571
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`42.
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`In my opinion, detection of position and pressure that Apple identifies
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`as the gesture signals in Poupyrev are not gesture signals because standing alone,
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`they do not indicate a movement of the body that conveys meaning or user intent.
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`Instead, the “gesture signal” from which the haptic output is derived is the output
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`from a GUI controller 112.
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`43. The system described in Poupyrev for generating a haptic (or tactile)
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`output to the user is shown in Figure 1, reproduced below. See generally Ex. 1013
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`at 4:61-7:42.
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`44. Apple points to the detection of position (in 2D position sensing unit
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`104) and pressure (in pressure sensing unit 105) as being two different gesture
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`signals. Pet. at 10.
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`45.
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`In my opinion, the detection of position and pressure are each
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`performed together in Poupyrev to determine, at most, a single gesture, rather than
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`two different gestures. As such, the position and pressure signals do not each
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`constitute a gesture signal, because neither of them alone is a signal indicating a
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`movement of the body that conveys meaning or user intent in Poupyrev's system.
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`46. Contrary to Apple’s view, Poupyrev makes clear that its system’s
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`Case IPR2016-00896
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`Graphical User Interface (“GUI”) controller 112, rather than the position and
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`pressure sensing units 104 and 105, determines whether a physical user input is a
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`gesture. See, e.g., Ex. 1013 at 7:14-18 (“The GUI controller 112 determines which
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`GUI object the user 2 is intending to interact with.”) (emphasis added). The
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`process by which a gesture is determined in Poupyrev’s system is further
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`illustrated in Figure 4, reproduced below:
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`47.
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`In this process, Poupyrev’s system determines a position of the user
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`finger or pen in step 210. Ex. 1013 at 8:25-27. In step 211, the process determines
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`whether the position of the finger or pen is inside the boundary of a GUI element.
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`Id. at 8:27-31. If the result of this step is “no,” a gesture has not been performed,
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`and the process returns to step 210 to again track the position of the user’s finger or
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`pen. Id. at Fig. 4. In this case, the pressure information is not used in the process
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`at all, because step 212 is only reached if the position information indicates that the
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`finger or pen is inside a GUI element. See id.
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`48.
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`In Step 212, the process determines if there is a pressing event (i.e.,
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`whether the user intended to interact with a GUI element). This determination
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`occurs only after the location sensing unit 104 determines that the user’s finger is
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`in a particular location and after the pressure sensing unit 105 determines that the
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`pressure is “more than a predetermined value.” See id. at 8:25-35. Thus, only after
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`both position and pressure information have been analyzed is it determined that a
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`user has intended to activate a particular GUI object, and a corresponding haptic
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`feedback output by the device. See id. at 8:47-49 (“[I]t is possible to let the user 2
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`know[] that the selected GUI object 203 is activated with the haptic feedback.”).
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`49.
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`In the above-described process, neither the pressure detection nor the
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`position detection contain sufficient information to indicate a movement of the
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`body that conveys meaning or user intent. Rather, a movement of the body that
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`conveys meaning or user intent is discernable only after both position and pressure
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`are considered in conjunction with one another. For example, if a user finger or
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`pen is not within a GUI element, no meaning or user intent can be derived from the
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`user input, regardless of the pressure applied. See id. at Fig. 4. Likewise, even if
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`the user’s finger or pen is located over a GUI element, only if sufficient pressure is
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`applied will Poupyrev’s system indicate the meaning or user intent to activate that
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`GUI element. Id. The position or pressure alone are insufficient to indicate a body
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`movement that conveys meaning or user intent in this process.
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`50. Accordingly, a POSITA would understand that in Poupyrev's system,
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`position and pressure information must be considered in tandem to indicate a
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`movement of the body that conveys meaning or user intent. Each of these signals
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`individually is not a gesture signal.
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`51. Poupyrev’s single discussion of the term “gesture” confirms this
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`understanding. In particular, Poupyrev teaches that even if a user moves the finger
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`or pen over a GUI object, the “actuation event” does not occur until a certain
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`pressure is applied to the object. Id. at 10:3-11. Poupyrev defines its “actuation
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`event” as “some gesture that allows the user to specify that the GUI object 310
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`should be actuated.” Id. (emphasis added). Poupyrev thus only teaches a single
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`gesture—the actuation event—that involves both location and pressure together. It
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`is my opinion that a POSITA would understand, based on this teaching, that a
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`location signal or a pressure signal, standing alone, would not indicate a movement
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`of the body that conveys the requisite meaning or user intent to constitute a gesture
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`signal in Poupyrev's system.
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`Case IPR2016-00896
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`52. This understanding is further consistent with other discussions in
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`Poupyrev of “interactions” that require complex sequences of pressure and position
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`over time in order to identify a movement of the body that conveys meaning or
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`user intent. Ex. 1013 at 7:47-54 (discussing "interactions" in a prior art system).
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`For instance, one of the interactions involves “drag[ging] a finger across the input
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`space,” (id.) which could generate dozens, hundreds, or even thousands of updates
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`from a position-sensing unit. Under Apple’s interpretation, each of these updates
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`would individually be a gesture signal, even though each location update, taken
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`individually, does not indicate a movement of the body that conveys meaning or
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`user intent in Poupyrev's system.
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`53. Each of the examples cited by Apple do not teach that a pressure or
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`position reading, by itself, can indicate a movement of the body that conveys
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`meaning or user intent in Poupyrev's system. For example, Petitioner alleges that
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`Poupyrev discloses “multiple ‘pressure’ gestures,” which actually depend on both
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`pressure and position (i.e., whether the finger is “inside of the GUI object”). Pet.
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`at 14-15. Apple also cites to a “typical touch-screen interaction,” but does not
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`identify any pressure or position reading that indicates a movement of the body
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`that conveys meaning or user intent that is used to generate a haptic effect. Id. at
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`14. In any event, it is unclear why Apple relies on this discussion, as Poupyrev
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`makes clear that this “typical touch-screen interaction” is “of related art,” and thus
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`does not describe how Poupyrev itself is implemented. See Pet. at 14; see also Ex.
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`1013 at 3:58-59 (“FIG. 2. is a schematic diagram showing an example of
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`interaction with touch screens of prior art.”). Apple provides no explanation for
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`why a POSITA would have modified Poupyrev to incorporate the prior art
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`approach expressly distinguish