UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`APPLE INC.,
`Petitioner
`
`v.
`
`IMMERSION CORPORATION
`Patent Owner
`
`U.S. Patent No. 8,773,356
`Filing Date: January 31, 2012
`Issue Date: July 8, 2014
`Title: Method and Apparatus for Providing Tactile Sensations
`
`
`
`Inter Partes Review No.: (Unassigned)
`
`
`DECLARATION OF DR. RICHARD T. MIHRAN
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`APPLE INC.
`EXHIBIT 1102 - PAGE 1
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`APPLE INC.,
`Petitioner
`
`v.
`
`IMMERSION CORPORATION
`Patent Owner
`
`U.S. Patent No. 8,773,356
`Filing Date: January 31, 2012
`Issue Date: July 8, 2014
`Title: Method and Apparatus for Providing Tactile Sensations
`
`
`
`Inter Partes Review No.: (Unassigned)
`
`
`DECLARATION OF DR. RICHARD T. MIHRAN
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`
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`APPLE INC.
`EXHIBIT 1102 - PAGE 1
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`Exhibit
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`Description
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`No.
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`EXHIBIT LIST
`
`1101
`1102
`1103
`
`1112
`1113
`
`U.S. Patent No. 8,773,356 (“’356 patent”)
`Reserved.
`Administrative Judge’s Construction of Terms ITC Investigation No.
`337-TA-1004
`File History of U.S. Patent No. 8,773,356
`1104
`U.S. Provisional App. No. 60/335,493 (“First Provisional”)
`1105
`U.S. Provisional App. No. 60/399,883 (“Second Provisional”)
`1106
`1107 WO 2002/12991 A1 (“Fukumoto WO”)
`1108
`Translation of WO 2002/12991 A1 Fukumoto WO
`1109
`U.S. Pat. App. Pub. No. 2002/0149561 (“Fukumoto US”)
`1110
`Japanese Published Application No. H11-212725
`1111
`Translation of Japanese Published Application No. H11-212725
`(“Tsuji”)
`U.S. Pat. App. Pub. No. US2008/0068350 (“Rosenberg 350”).
`IBM Model M Keyboard Release, April 1986 (available at http://www-
`01.ibm.com/common/ssi/ShowDoc.wss?docURL=/common/ssi/rep_ca/
`8/877/ENUSZG86-4008/index.html&lang=en&request_locale=en)
`(“IBM Release”)
`IBM Model M Keyboard Photograph
`https://upload.wikimedia.org/wikipedia/commons/4/48/IBM_Model_M
`.png
`U.S. Pat. No. 5,575,576 (“Roysden”)
`
`
`1114
`
`1115
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`APPLE INC.
`EXHIBIT 1102 - PAGE 2
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`I.
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`INTRODUCTION
`1.
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`I have been retained by counsel for Apple Inc. as an expert witness in
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`the above-captioned proceeding. I have been asked to provide my opinion about
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`the patentability of claims 1-26 of U.S. Patent No. 8,773,356 (the “’356 patent”).
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`2.
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`I have been retained at my normal hourly rate of $600 per hour. No
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`part of my compensation is dependent upon the outcome of this matter or the
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`specifics of my testimony.
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`A. Background and Qualifications
`3. My curriculum vitae (“CV”) is attached as Appendix A.
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`4.
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`I am a Professor Adjunct in the Department of Electrical and
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`Computer Engineering at the University of Colorado at Boulder, where I have been
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`on the faculty since 1990. I teach a wide variety of classes at the undergraduate
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`and graduate level covering general electrical and computer engineering theory and
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`practice, including circuit theory, microelectronics, signal processing, and medical
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`devices and systems. Many of these classes incorporate both lecture and
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`laboratory components that include hardware and software design.
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`5.
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`Courses I have taught include topics such as analog and digital circuit
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`theory and design, microelectronics, signal processing, radio-frequency
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`identification devices, miniaturized implantable medical devices incorporating
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`embedded systems, and optics and optical electronics, including semiconductor
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`laser diodes, Fourier optics, non-linear optics, optical sensors, and wave
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`propagation in optical fibers. Many of these courses include components directly
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`related to the design and implementation of portable electronic devices such as
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`smartphones and computers, as well as subject matter relating to haptic feedback
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`that may be used in such devices. These courses further include components and
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`concepts directly relevant to electronic devices and systems and their interfaces
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`with other devices, including communications networks, general principles of
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`wired and wireless RF communications, and data signal modulation and encoding
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`in a variety of applications.
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`6.
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`The devices and methods claimed in the ’356 patent encompass
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`several technology areas, including the basic architecture of smart
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`devices/embedded systems (controller, memory, display, data structures, etc.),
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`general principles of tactile feedback (physiology of human tactile perception, such
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`as sensitivity to vibration frequency/amplitude), haptic actuators and drive signals
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`(e.g. piezoelectric and voice-coil actuators and control of their signal sources), and
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`the integration of these elements within the context of the user interface.
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`7. With respect to basic embedded systems implementation, I have been
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`involved in microcontroller-based designs of portable data acquisition, processing
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`and computing devices for over 35 years, utilizing commercial microprocessors
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`manufactured by Intel, Motorola, Zilog, Microchip, among others. These devices
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`generally included various forms of displays and user interfaces as part of their
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`implementation, along with various sensors and actuators. Research projects I
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`have directed involving microprocessor-based systems include the development of
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`embedded system biosensor and immunoassay devices, radar signal processing
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`devices, spread-spectrum data telemetry devices, and microprocessor-controlled
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`drug infusion devices utilizing various mechanical actuators.
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`8. With respect to the integration of tactile feedback with electronic
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`devices, I have an extensive background in neuroscience and electrophysiology,
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`including performing research on the effects of various forms of mechanical
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`stimuli on nerve cells. This research included the development of systems to
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`deliver low-level mechanical stimuli to neural and other tissues using both direct
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`mechanical/vibratory stimulation, as well as mechanical stimuli delivered using
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`pulsed acoustic/ultrasonic stimuli. This work included the design and
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`implementation of the mechanical actuators, including voice-coil and piezoelectric
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`actuators, to deliver the mechanical stimuli to the neural tissue over a broad range
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`of frequencies and amplitudes.
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`9.
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`I have further taught courses at the undergraduate and graduate level
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`in basic neuronal electrophysiology, as well as the development of implantable
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`medical devices with neural interfaces, including cochlear and retinal implants,
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`spinal cord stimulation devices, and motor neuron stimulation devices for
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`Functional Electrical Stimulation (FES).
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`10. As part of my faculty role at the University of Colorado, I participate
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`in the supervision of doctoral research performed by graduate students as part of
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`obtaining their doctoral degrees, including the development of a haptic interfaces
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`and communications for providing touch/tactile feedback for virtual environments
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`during the late 1990’s.
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`11. Many of these research projects have further involved the
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`development of devices utilized in systems for acquiring, processing, storing and
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`retrieving data, as well as computational algorithms and analytical techniques
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`implemented in both software and firmware on a variety of computing platforms,
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`including embedded microprocessor systems and personal computers (PCs). I am
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`an inventor on three issued U.S. patents and one Canadian patent associated with
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`some of these activities, two involving computer-based Doppler radar signal
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`processing and data analysis, and two involving data telemetry utilizing spread
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`spectrum wireless links and database analysis systems for agricultural
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`management.
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`12. Since obtaining my Ph.D. in 1990, I have actively consulted in
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`industry in many areas of technology development, analysis and assessment,
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`directed to both product development and analysis of intellectual property
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`portfolios, patent infringement and validity. The fields of technology in which I
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`have consulted and/or served as a technical expert include computers, storage and
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`data systems (Hewlett Packard, Maxtor Corp.); Smart Card and Radio Frequency
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`identification systems (HID/AssaAbloy, Inc.; Vue Technology Corp.);
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`Smartphones, telecommunications and networking and associated devices (e.g.
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`AT&T, Kyocera Wireless, Sierra Wireless, Nokia, Verizon Wireless, Sprint, US
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`Cellular, Time Warner Cable, Comcast Corp., Palm, Inc., Lucent Corp., Nortel,
`
`Inc., Qwest Corp. and others); 3-D seismic data analysis and imaging software
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`(Terraspark Geosciences, Inc.); electronic securities trading networks (Sonic
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`Trading, Inc.); medical devices and systems (e.g. Boston Scientific, St. Jude
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`Medical); vision-based surgical tool tracking and navigation systems (Image
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`Guided Technologies, Inc., formerly Pixsys, Inc.); and others.
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`13.
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`I have served as an expert witness in many patent litigation matters in
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`the areas of computers, data storage, telecommunications, medical devices, and
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`others. I have been admitted and recognized in U.S. District Courts as a technical
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`expert in seven separate patent trials, including most recently in a patent matter in
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`the District of Delaware in which I served a technical expert witness addressing
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`two patents covering RFID transponders.
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`14.
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`I have also previously been admitted and recognized as a technical
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`expert by the International Trade Commission (ITC) in Washington D.C., where I
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`provided both a technology tutorial and subsequent testimony at trial in a patent
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`infringement complaint involving multiple patents directed to the function and
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`design of smart phones and other portable computing devices capable of voice and
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`data communications over cellular and other wireless networks.
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`15.
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`I have also been recognized and admitted in the Federal District of
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`Colorado as a technical expert and provided testimony at trial in the field of
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`implantable radio-frequency identification transponders and readers (District of
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`Colorado).
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`16.
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`I have further been admitted and recognized as a technical expert in
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`wireless communications in the Northern District of California, San Jose Division
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`where I served as a technical expert witness on behalf of several manufacturers of
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`wireless networking equipment. The accused products in that matter included
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`PCMCIA wireless network adapters used to provide wireless connectivity to a
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`variety of data networks, including Ethernet and cellular networks.
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`17.
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`I have also been admitted and recognized as a technical expert in the
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`Eastern District of Virginia in which I served as a technical expert witness on
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`behalf of several major cellular service providers and smart phone manufacturers.
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`The accused products in that matter included USB and PCMCIA wireless network
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`adapters used to provide wireless Internet connectivity to computers over cellular
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`data networks, such as GSM and CDMA based networks.
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`18.
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`I have also been admitted and recognized as a technical expert in the
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`Eastern District of Texas in which I served as a technical expert witness addressing
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`patents directed to integrated microcontrollers and associated network adapter
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`modules used to provide Ethernet communications.
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`19.
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`I have also been recognized and admitted in Federal District Courts as
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`a technical expert witness and provided testimony at trial in the field of digital
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`signal processing/optoelectronic image processing (Eastern District of Virginia),
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`and operational algorithms executed by firmware in embedded microprocessor
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`systems included in implantable medical devices (Southern District of Indiana).
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`20.
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`I received a BS in Electrical Engineering and Applied Physics from
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`Case Western Reserve University, Cleveland, Ohio in 1982. I further received an
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`MS in Electrical and Computer Engineering and a Ph.D. in Electrical Engineering
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`from the University of Colorado at Boulder in 1988 and 1990, respectively.
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`B.
`Information Considered
`21. My opinions are based on my years of education, research, and
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`experience, as well as my study of relevant materials. In forming my opinions, I
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`have considered the materials identified in this declaration and in the Petition.
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`22.
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`I may rely upon these materials and/or additional materials to respond
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`to arguments raised by Immersion. I may also consider additional documents and
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`information in forming any necessary opinions, including documents that may
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`have not yet been provided to me.
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`23. My analysis of the materials produced in this matter is ongoing and I
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`will continue to review any new material as it is provided. This declaration
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`represents only those opinions I have formed to date. I reserve the right to revise,
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`supplement, or amend my opinions stated herein based on new information and on
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`my continuing analysis of the materials already provided.
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`II. LEGAL STANDARDS
`A. Legal Standards for Prior Art
`24.
`I understand that a patent or other publication must first qualify as
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`prior art before it can be used to invalidate a patent claim.
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`25.
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`I understand that a U.S. or foreign patent qualifies as prior art to an
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`asserted patent if the date of issuance of the patent is prior to the invention of the
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`asserted patent. I further understand that a printed publication, such as an article
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`published in a magazine or trade publication, qualifies as prior art to an asserted
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`patent if the date of publication is prior to the invention of the asserted patent.
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`26.
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`I understand that a U.S. or foreign patent also qualifies as prior art to
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`an asserted patent if the date of issuance of the patent is more than one year before
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`the filing date of the asserted patent. I further understand that a printed
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`publication, such as an article published in a magazine or trade publication,
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`constitutes prior art to an asserted patent if the publication occurs more than one
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`year before the filing date of the asserted patent.
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`27.
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`I understand that a U.S. patent qualifies as prior art to the asserted
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`patent if the application for that patent was filed in the United Stated before the
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`invention of the asserted patent.
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`B.
`28.
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`Legal Standards for Anticipation
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`I understand that documents and materials that qualify as prior art can
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`be used to invalidate a patent claim via anticipation or obviousness.
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`29.
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`I understand that, once the claims of a patent have been properly
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`construed, the second step in determining anticipation of a patent claim requires a
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`comparison of the properly construed claim language to the prior art on a
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`limitation-by-limitation basis.
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`30.
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`I understand that a prior art reference “anticipates” an asserted claim,
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`and thus renders the claim invalid, if all elements of the claim are disclosed in that
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`prior art reference, either explicitly or inherently (i.e., necessarily present).
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`31.
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`I understand that anticipation in an inter partes review must be shown
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`by a preponderance of the evidence.
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`C. Legal Standards for Obviousness
`32.
`I understand that even if a patent is not anticipated, it is still invalid if
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`the differences between the claimed subject matter and the prior art are such that
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`the subject matter as a whole would have been obvious at the time the invention
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`was made to a person of ordinary skill in the pertinent art.
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`33.
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`I understand that a person of ordinary skill in the art provides a
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`reference point from which the prior art and claimed invention should be viewed.
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`This reference point prevents one from using his or her own insight or hindsight in
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`deciding whether a claim is obvious.
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`34.
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`I also understand that an obviousness determination includes the
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`consideration of various factors such as (1) the scope and content of the prior art,
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`(2) the differences between the prior art and the asserted claims, (3) the level of
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`ordinary skill in the pertinent art, and (4) the existence of secondary considerations
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`such as commercial success, long-felt but unresolved needs, failure of others, etc.
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`35.
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`I understand that an obviousness evaluation can be based on a
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`combination of multiple prior art references. I understand that the prior art
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`references themselves may provide a suggestion, motivation, or reason to combine,
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`but other times the nexus linking two or more prior art references is simple
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`common sense. I further understand that obviousness analysis recognizes that
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`market demand, rather than scientific literature, often drives innovation, and that a
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`motivation to combine references may be supplied by the direction of the
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`marketplace.
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`36.
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`I understand that if a technique has been used to improve one device,
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`and a person of ordinary skill in the art would recognize that it would improve
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`similar devices in the same way, using the technique is obvious unless its actual
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`application is beyond his or her skill.
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`37.
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`I also understand that practical and common sense considerations
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`should guide a proper obviousness analysis, because familiar items may have
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`obvious uses beyond their primary purposes. I further understand that a person of
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`ordinary skill in the art looking to overcome a problem will often be able to fit
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`together the teachings of multiple publications. I understand that obviousness
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`analysis therefore takes into account the inferences and creative steps that a person
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`of ordinary skill in the art would employ under the circumstances.
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`38.
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`I understand that a particular combination may be proven obvious
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`merely by showing that it was obvious to try the combination. For example, when
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`there is a design need or market pressure to solve a problem and there are a finite
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`number of identified, predictable solutions, a person of ordinary skill has good
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`reason to pursue the known options within his or her technical grasp because the
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`result is likely the product not of innovation but of ordinary skill and common
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`sense.
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`39. The combination of familiar elements according to known methods is
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`likely to be obvious when it does no more than yield predictable results. When a
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`work is available in one field of endeavor, design incentives and other market
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`forces can prompt variations of it, either in the same field or a different one. If a
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`person of ordinary skill can implement a predictable variation, the patent claim is
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`likely obvious.
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`40.
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`It is further my understanding that a proper obviousness analysis
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`focuses on what was known or obvious to a person of ordinary skill in the art, not
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`just the patentee. Accordingly, I understand that any need or problem known in
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`the field of endeavor at the time of invention and addressed by the patent can
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`provide a reason for combining the elements in the manner claimed.
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`41.
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`I understand that a claim can be obvious in light of a single reference,
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`without the need to combine references, if the elements of the claim that are not
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`found explicitly or inherently in the reference can be supplied by the common
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`sense of one of skill in the art.
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`42.
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`I understand that secondary indicia of non-obviousness may include
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`(1) a long felt but unmet need in the prior art that was satisfied by the invention of
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`the patent; (2) commercial success of processes covered by the patent; (3)
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`unexpected results achieved by the invention; (4) praise of the invention by others
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`skilled in the art; (5) taking of licenses under the patent by others; (6) deliberate
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`copying of the invention; (7) failure of others to find a solution to the long felt
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`need; and (8) skepticism by experts.
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`43.
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`I also understand that there must be a relationship between any such
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`secondary considerations and the invention. I further understand that
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`contemporaneous and independent invention by others is a secondary consideration
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`supporting an obviousness determination.
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`44.
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`In sum, my understanding is that prior art teachings are properly
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`combined where a person of ordinary skill in the art having the understanding and
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`knowledge reflected in the prior art and motivated by the general problem facing
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`the inventor, would have been led to make the combination of elements recited in
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`the claims. Under this analysis, the prior art references themselves, or any need or
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`problem known in the field of endeavor at the time of the invention, can provide a
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`reason for combining the elements of multiple prior art references in the claimed
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`manner.
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`45.
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`I understand that obviousness in an inter partes review must be shown
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`by a preponderance of the evidence.
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`III. OVERVIEW OF THE ’356 PATENT
`A. Technology Background
`46. As discussed in this section and throughout this report, the technology
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`of the asserted claims was well known in the prior art.
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`47. The ’356 patent is directed to well-known human computer
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`interaction components and their interconnections, namely, a controller that
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`receives a signal from an input device comprising a touchscreen, and outputs a
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`corresponding signal to an actuator that creates a desired tactile sensation using
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`stored haptic effect data. The asserted claims of the ’356 patent all require that the
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`haptic effect data used to generate the actuator signal is stored in a lookup table.
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`48. To provide background for the element-by-element analysis of the
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`claims to follow, below I will present an overview of the state of the art existing as
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`of the time of the alleged invention relating to computing devices having
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`touchscreens, touchscreens coupled to actuators to provide haptic feedback, and
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`lookup table that store haptic effect data. As I will describe below, all of these
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`technologies and techniques for applying them to touchscreen devices to provide
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`haptic feedback were well-known to those of ordinary skill in the art at the time of
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`the alleged invention claimed in the ’356 patent, and a person of ordinary skill in
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`the art.
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`a.
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`Touchscreens were well-known and widely applied in
`computing devices at the time of the alleged invention
`49. A touchscreen that might be utilized with computing devices such as
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`smart phones, PDAs, tablets, and the like comprises a touch-sensitive surface
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`overlaying a flat-panel display, such that contact with the display surface by an
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`object such as a stylus or fingertip can be detected and localized with respect to
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`icons, text, or other information appearing on the display. At the time of the
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`alleged invention claimed in the ’356 patent, a variety of technologies were known
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`and available for implementing touchscreen devices. While many variations of
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`such implementations were known, among the more prevalent implementations
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`were those using resistive, capacitive, optical, or acoustical (SAW) designs.
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`50. Touchscreen technologies were well-known and widely deployed well
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`before the alleged invention claimed in the ’356 patent. The ’356 patent admits in
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`the Background section of the specification that utilizing touchscreens in
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`computing devices such as mobile telephones and PDAs was well-known to those
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`of ordinary skill in the art at the time of the alleged invention:
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`Conventional electronic devices, such as mobile telephones and
`Personal Digital Assistants (PDAs), include visual displays. A user of
`such devices interacts with the visual display using any one of a
`number of input devices. . . The user provides instructions, responses,
`and other input to the device using such input devices.
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`Ex. 1101 at 1:30-38, (emphasis added).
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`When a flat surface interface device is used, such as a touchpad for a
`computer or PDA, these simple mechanical cues are unavailable to the
`user. Often, touchpads are combined with flat-panel display screens
`that display one or more graphically generated buttons or softkeys.
`Normally, the softkeys are visible through the touchpad. A user's
`contact with the touchpad in an area defined by a softkey provides the
`electronic device having the touchpad with the input associated with
`that softkey.
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`Ex. 1101 at 1:62-2:3, (emphasis added).
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`51. The fact that touchscreen technology was well-known and widely
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`used in computing devices prior to the alleged invention is further demonstrated by
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`its disclosure in prior art references, as well as its utilization in commercial
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`devices.
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`52. A further example demonstrating that touchscreen devices were well
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`known prior to the invention claimed in the ’356 patent is found in Tsuji:
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`Devices where a touch panel is arranged on a display are in wide
`use as one type of information display device having an operation
`input function. Touch panels are extremely thin, and have the
`advantage of providing a high degree of freedom for selecting an area
`that can be used as a switch.
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`Ex. 1111 at [0002], (emphasis added).
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`53. One of the embodiments of the system disclosed in Tsuji comprises an
`
`Automatic Teller Machine (ATM) having a touchscreen, as shown in Figure 1.
`
`This figure, along with accompanying description of its touchscreen, is reproduced
`
`below:
`
`WEST\275305286.1
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`16
`
`APPLE INC.
`EXHIBIT 1102 - PAGE 18
`
`
`
`
`
`Ex. 1111 at Figure 1.
`
`
`FIG. 1 is a perspective view of an automatic teller machine (ATM) 1
`as an example of a system incorporating an information display
`device 100 of a first embodiment of the present invention. The
`automatic teller machine 1 is provided with a cashier section 3 and a
`card and bank passbook insertion section 4 on a front surface of a
`chassis 2. The machine is also provided with an information input
`and output section 5, and the information display device 100 is used
`in the information input and output section 5.
`
`Ex. 1111 at [0041], (emphasis added).
`
`54. A further embodiment of the system disclosed in Tsuji comprises a
`
`hand-held information display device having a touchscreen, as shown in Figure 17.
`
`This figure, along with accompanying description of its touchscreen, is reproduced
`
`below:
`
`FIG. 17 is a perspective drawing of the exterior of an information
`display device 200 according to a third embodiment of the present
`invention.
`
`WEST\275305286.1
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`17
`
`APPLE INC.
`EXHIBIT 1102 - PAGE 19
`
`
`
`Ex. 1111 at [0040].
`
`The operating regions R1 through R4 displayed by the liquid crystal
`display panel are visible through the operating surface 11 in FIG.
`17. Typically, these operating regions R1 through R4 are displayed
`along both sides of the operating surface. An operator grips the
`housing 201 by both sides, as illustrated by the broken lines in FIG.
`17, and performs operations by pressing these operating regions R1
`through R4 with his/her thumbs. When the position of this pressing
`operation is sensed, if the pressing force thereof is larger than a
`predetermined threshold, the operation input is accepted, a displayed
`object 210 (FIG. 18) on a screen changes, and the operating surface
`11 is vibrated or slightly displaced based on a predetermined mode.
`The operation at this point is the same as in the first and second
`embodiments.
`
`Ex. 1111 at [0146], (emphasis added).
`
`
`
`Ex. 1111 at Figure 17.
`
`55. A further example from prior art demonstrating that touchscreen
`
`devices were well known prior to the invention claimed in the ‘356 patent is found
`WEST\275305286.1
`18
`
`
`APPLE INC.
`EXHIBIT 1102 - PAGE 20
`
`
`
`in Fukumoto. Fukumoto discloses a touch sensitive input device configured to
`
`output a sensor signal indicating an object contacting the touch-sensitive input
`
`device. This is shown, for example, in Figure 1 of Fukumoto, which is reproduced
`
`below, along with accompanying description of its touchscreen:
`
`
`
`Ex. 1109 at Figure 1.
`
`FIG. 1 is a perspective view illustrating the appearance of a PDA 10
`according to a first embodiment of the present invention. In the figure,
`a transparent touch panel 102 is overlaid on a display screen of a
`liquid crystal display panel 103a covering an opening of a main case
`101. A user inputs operation instructions to the PDA 10 by touching
`the touch panel 102 by his or her fingertip.
`
`Ex. 1109 at [0146].
`
`b.
`
`The use of haptic effects with touchscreens to provide haptic
`feedback was well-known in computing devices at the time
`of the alleged invention
`56. As shown above, the use of touchscreens of various forms and designs
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`WEST\275305286.1
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`19
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`APPLE INC.
`EXHIBIT 1102 - PAGE 21
`
`
`
`was well known to those of ordinary skill in the art at the time of the alleged
`
`invention, and had been described extensively in the literature, as well as utilized
`
`in commercial devices such as smart phones, PDAs, and tablet computing devices.
`
`57. Moreover, the use of haptic effects in conjunction with such
`
`touchscreens to provide haptic feedback to a user was also well known to those of
`
`ordinary skill in the art at the time of the alleged invention. This is supported by
`
`the ’356 patent itself, as well as demonstrated by the disclosures of Tsuji and
`
`Fukumoto.
`
`58. The prior art is also replete with disclosures of the use of haptic
`
`effects in conjunction with touch screens to provide tactile feedback in a variety of
`
`computing devices. For example, Tsuji demonstrates that touchscreen devices
`
`capable of providing haptic feedback were well known prior to the invention
`
`claimed in the ’356 patent:
`
`Devices where a touch panel is arranged on a display are in wide use
`as one type of information display device having an operation input
`function. Touch panels are extremely thin, and have the advantage of
`providing a high degree of freedom for selecting an area that can be
`used as a switch.
`
`Ex. 1111 at [0002], (emphasis added).
`
`59.
`
` One of the embodiments of the system disclosed in Tsuji comprises a
`
`hand-held information display device having a touchscreen which provides haptic
`
`effects in response to user interaction with displayed graphical objects, and is
`
`WEST\275305286.1
`
`
`20
`
`APPLE INC.
`EXHIBIT 1102 - PAGE 22
`
`
`
`shown in Figures 17-18. These figures, along with accompanying description of
`
`haptic feedback provided to a user contacting the touchscreen, is reproduced
`
`below:
`
`
`FIG. 17 is a perspective drawing of the exterior of an information display
`
`device 200 according to a third embodiment of the present invention.
`
`Ex. 1111 at [0040]
`
`The operating regions R1 through R4 displayed by the liquid crystal
`display panel are visible through the operating surface 11 in FIG. 17.
`Typically, these operating regions R1 through R4 are displayed along
`both sides of the operating surface. An operator grips the housing 201
`by both sides, as illustrated by the broken lines in FIG. 17, and
`performs operations by pressing these operating regions R1 through
`R4 with his/her thumbs. When the position of this pressing operation
`is sensed, if the pressing force thereof is larger than a predetermined
`threshold, the operation input is accepted, a displayed object 210
`(FIG. 18) on a screen changes, and the operating surface 11 is vibrated
`or slightly displaced based on a predetermined mode. The operation at
`this point is the same as in the first and second embodiments.
`
`WEST\275305286.1
`
`
`21
`
`APPLE INC.
`EXHIBIT 1102 - PAGE 23
`
`
`
`Ex. 1111 at [0146], (emphasis added).
`
`60. Thus, as further demonstrated by Tsuji and summarized above, use of
`
`actuators coupled to a touchscreen to generate haptic effects and to provide haptic
`
`feedback to a user as they contact the screen while interacting with objects
`
`displayed on the touchscreen was well-known to those of ordinary skill in the art at
`
`the time of the invention claimed in the ’356 patent.
`
`61. A further example demonstrating that touchscreen devices capable of
`
`providing haptic feedback were well known prior to the invention claimed in the
`
`’356 patent is found in Fukumoto. Fukumoto discloses a touch sensitive input
`
`device configured to output a sensor signal indicating an object contacting the
`
`touch-sensitive input device, and generate haptic feedback in response. This is
`
`shown, for example, in Figure 1 of Fukumoto, which is reproduced below, along
`
`with ac
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