`WASHINGTON, D.C.
`
`Before the Honorable Charles E. Bullock
`Chief Administrative Law Judge
`
`In the Matter of:
`
`CERTAIN MOBILE AND PORTABLE
`ELECTRONIC
`DEVICES INCORPORATING HAPTICS
`(INCLUDING SMARTPHONES AND
`LAPTOPS) AND
`COMPONENTS THEREOF
`
`Inv. No. 337-TA-1004
`Inv. No. 337-TA-990
`(Consolidated)
`
`Immersion’s Preliminary Proposed Claim Constructions (-1004 Investigation Patents)
`
`Pursuant to the Joint Discovery Statement and the procedural schedule in this
`
`investigation, Immersion hereby provides the following list of its preliminary proposed
`
`claim constructions for the terms identified by the parties on August 15, 2016 with respect to
`
`the four patents asserted in the Complaint filed in -1004 Investigation. Terms and proposed
`
`constructions with respect to the three patents asserted in the -990 Investigation were
`
`identified in a previous disclosure served June 3, 2016.
`
`Immersion reserves the right to modify this list, including by adding or dropping
`
`terms or by modifying its proposed claim construction of any term. Further, at present,
`
`Immersion intends to present expert testimony for claim construction and/or tutorial,
`
`including as may be appropriate to respond to expert testimony presented by other parties.
`
`APPLE INC.
`EXHIBIT 1106 - PAGE 1
`
`
`
`Term
`
`“pressure”1
`This is a term
`Respondents proposed for
`construction. Immersion
`disputes that this is a
`single term. The word
`“pressure” appears in
`different phrases from
`four different patents and
`cannot be construed in
`isolation from the
`surrounding claim
`language:
`’260:
`“first/second/third/fourth
`pressure”;
`’488: “first/second
`pressure threshold”
`(claims 1, 9, and 17);
`“first/second pressure”
`(claims 25 and 29); and
`“pressure-sensitive
`touchpad” (claim 25);
`’356: “pressure data”
`(claims 11, 21, and 26);
`’507: “pressure,” “change
`in pressure,” “pressure
`threshold,” “change in
`pressure threshold”
`(claims 1, 9, and 14);
`“actual pressure” and
`“pseudo pressure” (claims
`2, 10, and 15).
`“pseudo pressure”
`
`“first / second / third /
`fourth tactile sensation”
`
`Patent/Asserted
`Claims
`’260 patent: claims
`1, 2
`’488 patent: claims
`1, 9, 17, 25-27, 29
`’507 patent: all
`claims
`’356 patent: claims
`11, 21, 26
`
`Immersion’s Preliminary Proposed
`Construction
`Plain meaning.
`The word “pressure” appears in
`different phrases from four different
`patents and cannot be construed in
`isolation from the surrounding claim
`language. Immersion preliminarily
`construes the word “pressure” to mean
`“application of force from a contact.”
`
`’507 patent: claims
`2, 3, 10, 11, 15, 16
`’260 patent: claims
`1, 2
`
`“A measure of the area of the screen
`contacted by an object.”
`“The first/second/third/fourth tactile
`sensation can be the same as or
`
`
`1 Immersion also objects to Respondents’ proposal of additional terms from the ’356
`patent. Immersion also reserves the right to propose additional or different phrases or terms
`for construction containing “pressure” during the meet and confer process.
`
`APPLE INC.
`EXHIBIT 1106 - PAGE 2
`
`
`
`Term
`
`Patent/Asserted
`Claims
`
`“first/second haptic effect”
`
`’488 patent: claims
`1, 9, 17
`
`“first/second tactile
`sensation”
`
`’488 patent: claims
`25, 29
`
`“first haptic effect /
`second haptic effect”
`“threshold”
`
`“output a second tactile
`sensation associated with
`the second position”
`“determine a press if . . .
`the change in pressure is
`greater than a change in
`pressure threshold”
`
`’710 patent: claims
`1, 8, 12
`’488 patent: claims
`1, 9, 17
`
`’488 patent: claims
`25, 29
`
`’507 patent: claims
`1, 9, 14
`
`“otherwise”
`
`’710 patent: claim 1
`
`“determine a command
`associated with the user
`input”
`
`’710 patent: claim 1
`
`Immersion’s Preliminary Proposed
`Construction
`different from the other tactile
`sensations.”
`“The first haptic effect can be the same
`as or different from the second haptic
`effect.”
`“The first tactile sensation can be the
`same as or different from the second
`tactile sensation.”
`“The first haptic effect is different from
`the second haptic effect.”
`Plain meaning.
`If construed: “level.”
`Plain meaning.
`
`Plain meaning.
`If construed: “determine a press if . . .
`the change in pressure is greater than a
`static or adaptive threshold for the
`change in pressure.”
`Plain meaning.
`
`If construed: “alternatively.”
`
`“determine whether the command
`associated with the user input is
`supported”
`
`Dated: August 29, 2016
`
`Respectfully submitted,
`/s/
`Richard Birnholz
`
`Morgan Chu
`Richard Birnholz
`Jason Sheasby
`Lisa Glasser
`Babak Redjaian
`
`APPLE INC.
`EXHIBIT 1106 - PAGE 3
`
`
`
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Barbara A. Murphy
`David F. Nickel
`Kandis C. Gibson
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1899 L Street NW #1150
`Washington, DC 20036
`Telephone: (202) 822-4100
`
`Counsel for Complainant
`Immersion Corporation
`
`APPLE INC.
`EXHIBIT 1106 - PAGE 4
`
`
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