`
`INVALIDITY OF U.S. PATENT NO. 10,659,885 (THE “’885 PATENT”)
`
`Exhibit A-14
`
`BY
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`U.S. PATENT NO. 8,766,494 B2 (“Park494”)
`
`U.S. Pat. No. 8,766,494 to Park494 (“Park494”) entitled “Linear Vibrator” renders obvious claims 1-20 of U.S. Patent No. 10,659,885
`(the “’885 Patent”), in combination with other references and/or the knowledge of one of ordinary skill in the art, as set forth in the chart
`below and explained in Apple’s Preliminary Invalidity Contentions. This invalidity claim chart is based on Apple’s present
`understanding of the asserted claims and Taction Technology, Inc.’s (“Taction”) apparent construction of the claims, as set forth in
`Taction’s Preliminary Infringement Contentions. Apple is not adopting Taction’s apparent constructions, nor is Apple agreeing that any
`of Taction’s apparent constructions are correct. Apple reserves all rights to advance claim construction positions different from Taction’s
`apparent constructions. In addition to being explicitly disclosed in the prior art, each limitation of the asserted claims would have been
`inherent and/or obvious. By mapping claim language to this reference, Apple does not imply or admit that the claim language satisfies
`35 U.S.C. § 112. To the extent any cell lacks citations to the charted reference, this should not be taken as an admission that the reference
`does not disclose the corresponding limitation but rather indicates that Apple does not presently intend to rely on the reference as
`disclosing the limitation based on Apple’s present understanding of the claim limitation.
`
`
`’885 Patent
`
`Claim 1
`1[pre]. An apparatus for imparting
`motion to the skin of a user, the
`apparatus comprising:
`
`Park494
`
`
`To the extent the preamble is limiting, Park494 discloses an apparatus for imparting
`motion to the skin of a user explicitly, inherently, or as a matter of common sense or
`common knowledge, or it would have been obvious to add missing aspects of the
`limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`
`
`
`1
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`IPR2022-00057
`TACTION EX2009 PAGE001
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 1
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`Park494 at FIG. 2
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`2
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`IPR2022-00057
`TACTION EX2009 PAGE002
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`Exhibit A-14 (Park494)
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`’885 Patent
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`
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`Park494
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`Park494 at FIG. 3
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`3
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`TACTION EX2009 PAGE003
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`
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`Park494 at FIG. 4
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`“A linear vibrator is disclosed, characterized by: a housing; a stator fixed inside the
`housing; a vibrating unit formed with an opening for surrounding the stator and vibrating
`inside the housing by being interactive with the stator; and an elastic member elastically
`supporting the vibrator inside the housing, whereby the vibrating unit is vibrated in the
`width direction to enable a reduced thickness of the housing.”
`Park494 at Abstract
`
`“The present invention relates to a linear vibrator.”
`Park494 at 1:15
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`4
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`TACTION EX2009 PAGE004
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`Exhibit A-14 (Park494)
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`’885 Patent
`
`1[a]. a housing;
`
`1[b]. a plurality of coils capable of
`carrying electrical current;
`
`Park494
`“Referring to FIGS. 1 through 4, a linear vibrator mounted on a product such as a mobile
`terminal may include a housing (110), a stator (140), a vibrating unit (160) and an elastic
`member (170).”
`Park494 at 2:31-34
`
`Park494 discloses a housing explicitly, inherently, or as a matter of common sense or
`common knowledge, or it would have been obvious to add missing aspects of the
`limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`“A linear vibrator is disclosed, characterized by: a housing; a stator fixed inside the
`housing; a vibrating unit formed with an opening for surrounding the stator and vibrating
`inside the housing by being interactive with the stator; and an elastic member elastically
`supporting the vibrator inside the housing, whereby the vibrating unit is vibrated in the
`width direction to enable a reduced thickness of the housing.”
`Park494 at Abstract
`
`“Referring to FIGS. 1 through 4, a linear vibrator mounted on a product such as a mobile
`terminal may include a housing (110), a stator (140), a vibrating unit (160) and an elastic
`member (170).”
`Park494 at 2:31-34
`
`Park494 discloses a plurality of coils capable of carrying electrical current explicitly,
`inherently, or as a matter of common sense or common knowledge, or it would have
`been obvious to add missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`“The stator (140) inclusive of the coil is fixed at a floor plate (112) of the case (111) at
`the housing (110), and the stator (140) is fixed at the detachment prevention plate (130).
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`5
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`TACTION EX2009 PAGE005
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
`The detachment prevention plate (130) is coupled to a support bracket (150) while the
`stator (140) is fixed at an inside of the support bracket (150).”
`Park494 at 3:15-20
`
`
`“The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:33-48
`
`To the extent that Taction contends Park494 does not disclose or render obvious this
`claim element, it would have been obvious to combine this reference with other prior art,
`such as the prior art listed below, or the additional prior art listed in Apple’s Disclosure
`of Invalidity Contentions that teach this concept:
`
`See, e.g., Apple Watch Taptic Engine Module (X201) at Claim 1[b]
`See, e.g., Apple Watch Taptic Engine Module (X410) at Claim 1[b]
`See, e.g., Apple iPhone 6 Linear Motor Module at Claim 1[b]
`See, e.g., Apple iPhone 6 Plus Linear Motor Module at Claim 1[b]
`See, e.g., Miyazaki at Claim 1[b]
`See, e.g., Yoshikane690 at Claim 1[b]
`See, e.g., Yoshikane470 at Claim 1[b]
`See, e.g., Yoshikane894 at Claim 1[b]
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`6
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`TACTION EX2009 PAGE006
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
`
`1[c]. a plurality of magnets arranged in
`operative proximity to the plurality of
`coils;
`
`See, e.g., Hideaki at Claim 1[b]
`See, e.g., Miyazaki at Claim 1[b]
`See, e.g., Miyamoto at Claim 1[b]
`See, e.g., Choi at Claim 1[b]
`
`Park494 discloses a plurality of magnets arranged in operative proximity to the plurality
`of coils explicitly, inherently, or as a matter of common sense or common knowledge, or
`it would have been obvious to add missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:27-48
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`
`
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`7
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`TACTION EX2009 PAGE007
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`Exhibit A-14 (Park494)
`
`’885 Patent
`1[d]. a moving portion comprising an
`inertial mass and the plurality of
`magnets;
`
`1[e]. a suspension comprising a plurality
`of flexures that guides the moving
`portion in a planar motion with respect
`to the housing and the plurality of
`conductive coils;
`
`Park494
`Park494 discloses a moving portion comprising an inertial mass and the plurality of
`magnets explicitly, inherently, or as a matter of common sense or common knowledge,
`or it would have been obvious to add missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:27-48
`
`Park494 discloses a suspension comprising a plurality of flexures that guides the moving
`portion in a planar motion with respect to the housing and the plurality of conductive
`coils explicitly, inherently, or as a matter of common sense or common knowledge, or it
`would have been obvious to add missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`
`
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`8
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`TACTION EX2009 PAGE008
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 1
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`Park494 at FIG. 2
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`9
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`TACTION EX2009 PAGE009
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 3
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`10
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`TACTION EX2009 PAGE010
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 4
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`11
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`TACTION EX2009 PAGE011
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 5
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`12
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`TACTION EX2009 PAGE012
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 7
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`Park494 at FIG. 8
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`13
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`TACTION EX2009 PAGE013
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`
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`Park494 at FIG. 9
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`“The housing (110) may be of a flat hexagonal shape having an accommodation space
`therein, where a longer surface direction of the hexagonal housing (110) is defined as a
`first direction while a shorter surface direction perpendicular to the longer surface
`direction of the hexagonal housing (110) is referred to as a second direction. The housing
`(110) may include a case 111 for forming the accommodation space and a cover (116).”
`Park494 at 2:35-43
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`
`
`
`14
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`TACTION EX2009 PAGE014
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`
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`Exhibit A-14 (Park494)
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`’885 Patent
`
`Park494
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:27-48
`
`“The elastic member (170) elastically supports the vibrating unit (160) inside the
`housing. That is, the elastic member (160) is shaped of a “U” letter, and both distal ends
`of the elastic member (160) are coupled to the vibrating unit (160). The elastic member
`(160) is centrally coupled to the housing (110) to transfer the vibration generated by the
`vibrating unit (160) to the housing (110). The center and the both distal ends of the
`elastic member (170) may be folded or angled at 90 degrees.”
`Park494 at 3:59-67
`
`“Referring to FIG. 5, an elastic member (270) is comprised of first and second elastic
`members (271, 275) each having corresponding shape. Each of the first and second
`elastic members (271, 275) may be bent at an angle of 90 degrees in the shape of “L”
`letter.
`
`One side of the first elastic member (271) is coupled to the left lateral surface of the
`weight (261) facing the vibrating direction of the vibrating unit (260), and the other side
`of the first elastic member (271) is coupled to an upper lateral plate (213 c) of a case
`(211) perpendicularly erected to the left lateral surface of a weight (261).”
`Park494 at 5:7-15
`
`“Referring to FIG. 7, an elastic member (470) is formed with first and second elastic
`members (471, 475), each facing the other, and the first and second elastic members
`(471, 475) are folded at an acute angle.
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`
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`15
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`Exhibit A-14 (Park494)
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`’885 Patent
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`1[f]. wherein movement of the moving
`portion is damped by a ferrofluid in
`physical contact with at least the moving
`portion; and
`
`Park494
`Each distal end of the first and second elastic members (471, 475) is formed with
`coupling pieces (471 a,475 a) and a weight (461) of a vibrating unit (460) is formed with
`a coupling groove (461 b) to be coupled with each coupling piece (471 a, 475 a), where a
`coupling power between the elastic member (470) and the weight (461) is reinforced by
`the coupling pieces (471 a, 475 a) and the coupling groove (461 b). The other end of the
`first elastic member (471) and the other end of the second elastic member (475) may be
`integrally formed, whereby the elastic member according to the fourth exemplary
`embodiment comes to have the same structure as that (370) of the third exemplary
`embodiment.”
`Park494 at 6:7-22
`
`“Referring to FIG. 8, an elastic member (570) is formed with first and second elastic
`members (571, 575), each facing the other, and an upper side and a bottom side of the
`first elastic member (571) are formed in parallel, while a central side is bent at an acute
`angle relative to the upper side and the bottom side. The second elastic member (575) is
`configured in the same way as that of the first elastic member (571).”
`Park494 at 6:34-40
`
`“Referring to FIG. 9, an elastic member (670) is formed with first and second elastic
`members (671, 675), each facing the other. Each of the central portion of the first and
`second elastic members (671, 675) is protruded upwards when seen from a plan view.”
`Park494 at 6:64-67
`
`Park494 discloses wherein movement of the moving portion is damped by a ferrofluid in
`physical contact with at least the moving portion explicitly, inherently, or as a matter of
`common sense or common knowledge, or it would have been obvious to add missing
`aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`
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`16
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`TACTION EX2009 PAGE016
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
`“Referring to FIGS. 1 through 4, a linear vibrator mounted on a product such as a mobile
`terminal may include a housing (110), a stator (140), a vibrating unit (160) and an elastic
`member (170).”
`Park494 at 2:31-34
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:27-48
`
`“The elastic member (170) elastically supports the vibrating unit (160) inside the
`housing. That is, the elastic member (160) is shaped of a “U” letter, and both distal ends
`of the elastic member (160) are coupled to the vibrating unit (160). The elastic member
`(160) is centrally coupled to the housing (110) to transfer the vibration generated by the
`vibrating unit (160) to the housing (110). The center and the both distal ends of the
`elastic member (170) may be folded or angled at 90 degrees.”
`Park494 at 3:59-67
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`17
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`Exhibit A-14 (Park494)
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`’885 Patent
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`1[g]. wherein the ferrofluid reduces at
`least a mechanical resonance within the
`frequency range of 40-200 Hz in
`response to electrical signals applied to
`the plurality of conductive coils.
`
`Park494
`“Now, referring to FIG. 3, a magnetic fluid (180) may be coated on a bottom surface and
`an upper surface of the weight (161) respectively facing the pad (112) of the case (111)
`and the cover (116), The magnetic fluid (180) contacts the pad (112) of the case (111)
`and the cover (116) to prevent the vibrating unit (160) from being inclined relative to the
`pad (112) and the cover (116). Furthermore, the magnetic fluid (180) serves as a damper
`for rapidly stopping the vibrating unit (160) when the vibrating unit (160) is to be
`stopped.”
`Park494 at 4:20-28
`
`Park494 discloses wherein the ferrofluid reduces at least a mechanical resonance within
`the frequency range of 40-200 Hz in response to electrical signals applied to the plurality
`of conductive coils inherently, or as a matter of common sense or common knowledge,
`or it would have been obvious to add missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).”
`Park494 at 3:27-32
`
`“Now, referring to FIG. 3, a magnetic fluid (180) may be coated on a bottom surface and
`an upper surface of the weight (161) respectively facing the pad (112) of the case (111)
`and the cover (116), The magnetic fluid (180) contacts the pad (112) of the case (111)
`and the cover (116) to prevent the vibrating unit (160) from being inclined relative to the
`pad (112) and the cover (116). Furthermore, the magnetic fluid (180) serves as a damper
`for rapidly stopping the vibrating unit (160) when the vibrating unit (160) is to be
`stopped.”
`Park494 at 4:20-28
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`Exhibit A-14 (Park494)
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`’885 Patent
`
`Claim 2
`2. The apparatus of claim 1 wherein said
`housing is generally cuboid in shape.
`
`Park494
`To the extent that Taction contends Park494 does not disclose or render obvious this
`claim element, it would have been obvious to combine this reference with other prior art,
`such as the prior art listed below, or the additional prior art listed in Apple’s Disclosure
`of Invalidity Contentions that teach this concept:
`
`See, e.g., Bae at Claim 1[g]
`See, e.g., Yoshikane690 at Claim 1[g]
`See, e.g., Yoshikane470 at Claim 1[g]
`See, e.g., Park728 at Claim 1[g]
`See, e.g., Hasegawa at Claim 1[g]
`See, e.g., An at Claim 1[g]
`See, e.g., van Halteran at Claim 1[g]
`See, e.g., van Schyndel at Claim 1[g]
`
`
`Park494 discloses said housing is generally cuboid in shape explicitly, inherently, or as a
`matter of common sense or common knowledge, or it would have been obvious to add
`missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`
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`19
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 1
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`Park494 at FIG. 2
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`Exhibit A-14 (Park494)
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`’885 Patent
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`
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`Park494
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`Park494 at FIG. 3
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`TACTION EX2009 PAGE021
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 4
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`TACTION EX2009 PAGE022
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 5
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`TACTION EX2009 PAGE023
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`Park494 at FIG. 7
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`Park494 at FIG. 8
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`Exhibit A-14 (Park494)
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`’885 Patent
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`Park494
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`
`
`Park494 at FIG. 9
`
`“The housing (110) may be of a flat hexagonal shape having an accommodation space
`therein, where a longer surface direction of the hexagonal housing (110) is defined as a
`first direction while a shorter surface direction perpendicular to the longer surface
`direction of the hexagonal housing (110) is referred to as a second direction. The housing
`(110) may include a case 111 for forming the accommodation space and a cover (116).”
`Park494 at 2:35-43
`
`
`Park494 discloses the cuboid-shaped housing has a thickness less than one-third of a
`width, where the thickness and width are both orthogonal to a direction of motion of the
`moving portion, and the thickness is less than the width explicitly, inherently, or as a
`matter of common sense or common knowledge, or it would have been obvious to add
`missing aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`
`Claim 3
`3. The apparatus of claim 2 wherein the
`cuboid-shaped housing has a thickness
`less than one-third of a width, where the
`thickness and width are both orthogonal
`to a direction of motion of the moving
`portion, and the thickness is less than
`the width.
`
`
`
`25
`
`IPR2022-00057
`TACTION EX2009 PAGE025
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`Park494
`“The housing (110) may be of a flat hexagonal shape having an accommodation space
`therein, where a longer surface direction of the hexagonal housing (110) is defined as a
`first direction while a shorter surface direction perpendicular to the longer surface
`direction of the hexagonal housing (110) is referred to as a second direction. The housing
`(110) may include a case 111 for forming the accommodation space and a cover (116).”
`Park494 at 2:35-43
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:27-48
`
`To the extent that Taction contends Park494 does not disclose or render obvious this
`claim element, it would have been obvious to combine this reference with other prior art,
`such as the prior art listed below, or the additional prior art listed in Apple’s Disclosure
`of Invalidity Contentions that teach this concept:
`
`See, e.g., Lee at Claim 3
`
`
`
`26
`
`IPR2022-00057
`TACTION EX2009 PAGE026
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`Park494
`
`Claim 4
`4. The apparatus of claim 2 wherein the
`cuboid-shaped housing has a length
`dimension in a direction of motion of
`the moving portion, and a thickness
`dimension perpendicular to the length
`dimension, wherein the thickness
`dimension is less than one-third of the
`length dimension, and the thickness is
`less than a width.
`
`See, e.g., Hideaki at Claim 3
`
`
`Park494 discloses the cuboid-shaped housing has a length dimension in a direction of
`motion of the moving portion, and a thickness dimension perpendicular to the length
`dimension, wherein the thickness dimension is less than one-third of the length
`dimension, and the thickness is less than a width explicitly, inherently, or as a matter of
`common sense or common knowledge, or it would have been obvious to add missing
`aspects of the limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`“The housing (110) may be of a flat hexagonal shape having an accommodation space
`therein, where a longer surface direction of the hexagonal housing (110) is defined as a
`first direction while a shorter surface direction perpendicular to the longer surface
`direction of the hexagonal housing (110) is referred to as a second direction. The housing
`(110) may include a case 111 for forming the accommodation space and a cover (116).”
`Park494 at 2:35-43
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged inside the weight (140). Each
`piece of the pair of magnets (164 a, 164 b: 164) is arranged inside the weight (161) about
`the coil (140) to face the other. In a case a current flows in the stator (140) in the forward
`direction, the magnets (164) become interactive with the stator (140) to vibrate between
`the left plate (113 a) and the right plate (113 b) of the case (111) at the housing (110) and
`to resultantly vibrate the weight (161).
`
`
`
`
`27
`
`IPR2022-00057
`TACTION EX2009 PAGE027
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`Claim 5
`5. The apparatus of claim 4 wherein at
`least one magnetic flux guide comprises
`a portion of said housing and is coupled
`to at least a coil.
`
`Park494
`In a case a current flows in the stator (140), the vibrating unit (160) may be smoothly
`vibrated if magnets (164 a, 164 b) are arranged in such a manner that a gravitational
`force is applied between any one of the magnets (164 a) and the coil (140), and a
`repulsive force is applied between the other magnet (164 b) and the coil (140).”
`Park494 at 3:27-48
`
`To the extent that Taction contends Park494 does not disclose or render obvious this
`claim element, it would have been obvious to combine this reference with other prior art,
`such as the prior art listed below, or the additional prior art listed in Apple’s Disclosure
`of Invalidity Contentions that teach this concept:
`
`See, e.g., Apple Watch Taptic Engine Module (X201) at Claim 4
`See, e.g., Apple Watch Taptic Engine Module (X410) at Claim 4
`See, e.g., Apple iPhone 6 Linear Motor Module at Claim 4
`See, e.g., Apple iPhone 6 Plus Linear Motor Module at Claim 4
`See, e.g., Hideaki at Claim 4
`See, e.g., Lee at Claim 4
`
`
`Park494 discloses at least one magnetic flux guide comprises a portion of said housing
`and is coupled to at least a coil explicitly, inherently, or as a matter of common sense or
`common knowledge, or it would have been obvious to add missing aspects of the
`limitation.
`
`For example, see the following passages and/or figures, as well as all related disclosures:
`
`
`
`
`
`28
`
`IPR2022-00057
`TACTION EX2009 PAGE028
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`Park494
`
`Park494 at FIG. 1
`
`
`
`
`
`
`
`
`Park494 at FIG. 2
`
`29
`
`IPR2022-00057
`TACTION EX2009 PAGE029
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`
`
`Park494
`
`Park494 at FIG. 3
`
`
`
`
`
`
`30
`
`IPR2022-00057
`TACTION EX2009 PAGE030
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`Park494
`
`
`
`Park494 at FIG. 4
`
`“The vibration generating device in the portable electronic equipment alerting a device
`user of arrival of a receiving signal may include a cylindrical coil arranged underneath a
`housing, a yoke disposed at an upper surface of the housing to be connected to a spring, a
`magnet disposed at an inner lateral surface of the yoke to reciprocally move inside the
`cylindrical coil, and a weight disposed at an external surface of the yoke.”
`Park494 at 1:24-31
`
`“The vibrating unit (160) reciprocates along the first direction. To be more specific, the
`vibrating unit (160) vibrates with a predetermined frequency in between a left plate (113
`a) opposite to the housing (110) and a right plate (113 b). The vibrating unit (160) may
`include a weight (161), a pair of magnets (164) and a yoke (167).
`
`
`
`
`31
`
`IPR2022-00057
`TACTION EX2009 PAGE031
`
`
`
`Exhibit A-14 (Park494)
`
`’885 Patent
`
`Claim 6
`6. The apparatus of claim 1 wherein said
`housing comprises at least one magnetic
`flux guide comprising a ferromagnetic
`material.
`
`
`
`
`
`
`
`Park494
`The weight (161) has a square framed shape with a central opening into which a coil
`(140) is inserted, whereby the coil (140) is to be arranged insi
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