Ex. 2001
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`Apple Inc.
`
`Petitioner,
`
`v.
`
`Taction Technology, Inc.,
`
`Patent Owner.
`
`________________
`
`Case IPR2022-00058
`U.S. Patent No. 10,820,117
`________________
`
`DECLARATION OF ALLISON OKAMURA, PH.D.
`IN SUPPORT OF TACTION TECHNOLOGY, INC.’S
`PATENT OWNER PRELIMINARY RESPONSE
`
`
`
`
`
`
`
`IPR2022-00058
`TACTION EX2001 PAGE001
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`TABLE OF CONTENTS
`
`Page
`
`I.
`
`Introduction ........................................................................................ 4
`
`II.
`
`Summary of Opinions .......................................................................... 4
`
`III. Qualifications and Experience ............................................................... 5
`
`IV. Legal Standards ................................................................................... 9
`
`A. Claim Construction ..................................................................... 9
`
`B. Obviousness ............................................................................. 10
`
`V.
`
`The ’117 Patent ................................................................................. 11
`
`VI. Overview of the Cited Art ................................................................... 16
`
`A. Miyazaki ................................................................................. 16
`
`B.
`
`C.
`
`Park494 ................................................................................... 21
`
`Park728 ................................................................................... 23
`
`D. Kajiwara .................................................................................. 27
`
`VII. Level of Ordinary Skill in the Art......................................................... 30
`
`VIII. Claim Construction ............................................................................ 33
`
`IX. Ground 1: Obviousness Based on the Combination of Miyazaki,
`Park494, and Kajiwara ....................................................................... 33
`
`A.
`
`The Combination of Miyazaki, Park494, and Kajiwara Fails to
`Disclose or Render Obvious “Wherein the Viscous Ferrofluid
`Reduces at Least a Resonance Within a Frequency Range of 40-
`200 Hz” ................................................................................... 33
`
`1.
`
`2.
`
`No Reference Discloses Reducing a 40-200 Hz
`Resonance with Ferrofluid ................................................ 34
`
`The Frequency Response of Kajiwara’s Deformable
`Members Is Not Transferrable to Ferrofluid ........................ 41
`
`
`
`1
`
`IPR2022-00058
`TACTION EX2001 PAGE002
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`B.
`
`C.
`
`3.
`
`4.
`
`The Frequency Response of Kajiwara’s Device Is Not
`Transferrable to Miyazaki’s Device .................................... 44
`
`Kajiwara’s 120-180 Hz Range Does Not Disclose or
`Render Obvious the Claimed 40-200 Hz Range ................... 46
`
`The Combination of Miyazaki, Park494, and Kajiwara Fails to
`Disclose or Render Obvious “Ferrofluid” ..................................... 49
`
`Petitioner Has Not Established that Miyazaki, Park494, and
`Kajiwara Can Be Combined to Yield the Challenged Claims .......... 53
`
`1.
`
`2.
`
`3.
`
`Petitioner Fails to Show Why a Person of Ordinary Skill
`in the Art Would Select Miyazaki, Park494, and
`Kajiwara and Combine Them ............................................ 54
`
`Petitioner Fails to Show How a Person of Ordinary Skill
`in the Art Would Modify Miyazaki’s Device to Include
`Ferrofluid from Park494 to Yield the Challenged Claims
`With a Reasonable Expectation of Success .......................... 56
`
`Petitioner Fails to Show Why a Person of Ordinary Skill
`in the Art Would Be Motivated to Modify Miyazaki’s
`Device to Replace or Supplement Its Damping Solution
`with Ferrofluid from Park494 ............................................ 59
`
`X. Ground 2: Obviousness Based on the Combination of Miyazaki,
`Park494, and Park728......................................................................... 65
`
`A.
`
`The Combination of Miyazaki, Park494, and Park728 Fails to
`Disclose or Render Obvious “Wherein the Viscous Ferrofluid
`Reduces at Least a Resonance Within a Frequency Range of 40-
`200 Hz” ................................................................................... 65
`
`1.
`
`2.
`
`3.
`
`No Reference Discloses Reducing a 40-200 Hz
`Resonance with Ferrofluid ................................................ 65
`
`The Frequency Response of Park728’s Device Is Not
`Transferrable to Ferrofluid ................................................ 69
`
`The Frequency Response Effect of Park728’s Device Is
`Not Transferrable to Miyazaki’s Device.............................. 70
`
`
`
`2
`
`IPR2022-00058
`TACTION EX2001 PAGE003
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`4.
`
`Park728’s 80-180 Hz or 100-300 Hz Range Does Not
`Disclose or Render Obvious the Claimed 40-200 Hz
`Range............................................................................. 72
`
`B.
`
`C.
`
`The Combination of Miyazaki, Park494, and Park728 Fails to
`Disclose or Render Obvious “Ferrofluid” ..................................... 73
`
`Petitioner Has Not Established that Miyazaki, Park494, and
`Park728 Can Be Combined to Yield the Challenged Claims ........... 73
`
`1.
`
`2.
`
`3.
`
`Petitioner Fails to Show Why a Person of Ordinary Skill
`in the Art Would Select Miyazaki, Park494, and Park728
`and Combine Them .......................................................... 74
`
`Petitioner Fails to Show How a Person of Ordinary Skill
`in the Art Would Modify Miyazaki’s Device to Include
`Ferrofluid from Park494 to Yield the Challenged Claims
`With a Reasonable Expectation of Success .......................... 75
`
`Petitioner Fails to Show Why a Person of Ordinary Skill
`in the Art Would Be Motivated to Modify Miyazaki’s
`Device to Replace or Supplement Its Damping Solution
`with Ferrofluid from Park494 ............................................ 75
`
`
`
`3
`
`
`
`
`
`
`IPR2022-00058
`TACTION EX2001 PAGE004
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`1.
`
`I, Allison Okamura, declare as follows:
`
`I.
`
`Introduction
`
`2.
`
`I have been engaged by Taction Technology, Inc. (“Taction”) as an
`
`expert in connection with matters raised in the Petition for Inter Partes Review
`
`(“Petition”) of U.S. Patent No. 10,820,117 (the “’117 patent”) filed by Apple Inc.
`
`(“Apple” or “Petitioner”).
`
`3.
`
`This declaration is based on the information currently available to me.
`
`To the extent that additional information becomes available, I reserve the right to
`
`continue my investigation and study, which may include a review of documents and
`
`information that may be produced, as well as testimony from depositions that have
`
`not yet been taken.
`
`II.
`
`Summary of Opinions
`
`4.
`
`The Petition raises three grounds, each based on obviousness under
`
`post-AIA 35 U.S.C. § 103.
`
`5.
`
`Ground 1 alleges that claims 1-15 are obvious over Japanese PCT
`
`Application No. WO2011013570 to Miyazaki et al. (Ex. 1004, “Miyazaki”) in view
`
`of U.S. Patent No. 8,766,494 to Park et al. (Ex. 1005, “Park494”), and U.S. Patent
`
`Publication No. 2009/0267423 to Kajiwara (Ex. 1006, “Kajiwara”). Petition at 11-
`
`69. Based on studying the Petition and the exhibits cited in the Petition as well as
`
`
`
`4
`
`IPR2022-00058
`TACTION EX2001 PAGE005
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`other documents, it is my opinion that claims 1-15 of the ’117 patent are not rendered
`
`obvious by the combination of Miyazaki, Park494, and Kajiwara.
`
`6.
`
`Ground 2 alleges that claims 1-11 are obvious over Miyazaki in view
`
`of Park494, and U.S. Patent No. 8,461,728 to Park et al. (Ex. 1007, “Park728”).
`
`Petition at 69-81. Based on studying the Petition and the exhibits cited in the Petition
`
`as well as other documents, it is my opinion that claims 1-11 of the ’117 patent are
`
`not rendered obvious by the combination of Miyazaki, Park494, and Park728.
`
`7.
`
`Ground 3 alleges that claim 12 is obvious over Miyazaki in view of
`
`Park494, Park728, and Kajiwara. Petition at 81-82.
`
`III. Qualifications and Experience
`
`8.
`
`I obtained my Bachelor of Science degree in Mechanical Engineering
`
`from the University of California, Berkeley in 1994. I continued my education at
`
`Stanford University, where I received my Master of Science degree in Mechanical
`
`Engineering in 1996 and my Ph.D. in Mechanical Engineering in 2000.
`
`9.
`
`I am currently a Professor in the Mechanical Engineering Department
`
`at Stanford, a position I have held since 2015. From 2011-2015, I was an Associate
`
`Professor in the same department. Since 2012 I have held a courtesy appointment
`
`in the Computer Science Department. I am the Director of Graduate Studies for the
`
`Mechanical Engineering Department.
`
`
`
`5
`
`IPR2022-00058
`TACTION EX2001 PAGE006
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`10. At Stanford University, I am the director of the “CHARM” Lab, which
`
`stands for Collaborative Haptics and Robotics in Medicine. I am also currently
`
`involved in Stanford’s Center for Design Research, Wu Tsai Neurosciences Institute,
`
`and eWEAR initiative.
`
`11. Before teaching at Stanford, I was an assistant, associate, and full
`
`professor in the Mechanical Engineering Department at Johns Hopkins University
`
`from 2000-2011 and served as Vice Chair of the department. At Johns Hopkins, I
`
`served as Associate Director of the Laboratory for Computational Sensing and
`
`Robotics (LCSR) from 2007-2011. The LCSR is an interdisciplinary academic
`
`center for engineering, research and development in the field of robotics. I was also
`
`part of the NSF Engineering Research Center for Computer-Integrated Surgical
`
`Systems and Technology, where I served as a faculty member (2000-2009) and
`
`Surgical Assistants Thrust Leader (2004-2009).
`
`12. Before I started teaching, I worked as a Graduate Research Assistant in
`
`the Department of Mechanical Engineering at Stanford from 1994-2000. I also
`
`worked part-time as a Research Engineer at Immersion Corporation in the 1996-
`
`1998 time frame, while pursuing my Ph.D. at Stanford.
`
`13.
`
`I currently teach classes related to mechanical engineering, electrical
`
`engineering, and computer science. In my research, I specialize in robotics and
`
`human-machine interaction, with a particular focus on medical robotics and haptics.
`
`
`
`6
`
`IPR2022-00058
`TACTION EX2001 PAGE007
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`14.
`
`In recent years my research has been sponsored by the National Science
`
`Foundation, National Institutes of Health, Department of Defense, Facebook (now
`
`Meta), Honda Research Institute, Toyota Research Institute, and Intuitive Surgical,
`
`among others. For example, I have a current research grant from the Precision
`
`Health and Integrated Diagnostics Center at Stanford to study how the vibrations
`
`from smartphones can be used for characterizing human perception.
`
`15.
`
`I have published extensively in the areas of human-computer
`
`interaction, robotics, and haptics. I have authored over 200 peer-reviewed articles in
`
`journals and conference proceedings. I have also contributed to 15 books or
`
`collections, including co-authoring a chapter on haptics in the Springer Handbook
`
`of Robotics with Dr. Blake Hannaford, Apple’s expert in this proceeding. I have
`
`also been an associate editor of the IEEE Transactions on Haptics, the editor-in-chief
`
`of the IEEE Robotics and Automation Letters, the editor-in-chief of the IEEE
`
`International Conference on Robotics and Automation Conference Editorial Board,
`
`and co-chair of the IEEE Haptics Symposium.
`
`16.
`
`I have received a number of awards and honors, including the IEEE
`
`Engineering in Medicine and Biology Society Technical Achievement Award, the
`
`National Science Foundation CAREER award, and the IEEE Technical Committee
`
`on Haptics Early Career Award, as well as Best Paper and Best Poster awards from
`
`several conferences and journals. I have been an invited or keynote speaker at
`
`
`
`7
`
`IPR2022-00058
`TACTION EX2001 PAGE008
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`numerous conferences and symposia, including the National Academy of Engineers
`
`Frontiers of Engineering Symposium and the World Haptics Conference, and have
`
`been an IEEE Fellow since 2011. In 2016, I was named the Duca Family University
`
`Fellow in Undergraduate Education at Stanford University.
`
`17.
`
`I am a named inventor on three patents relating to my work at Johns
`
`Hopkins and four patents at Stanford, as well as several currently-pending patents.
`
`18. My curriculum vitae is attached as Exhibit 2002.
`
`19.
`
`I am being compensated by Taction for my time spent working on this
`
`matter at a rate of $600 per hour. My compensation is not contingent upon the
`
`substance of my opinions, the content of this declaration or any testimony I may
`
`provide, or the outcome of any inter partes reviews or any other proceeding.
`
`20.
`
`I have no financial interest in Taction or Apple.
`
`21. My opinions expressed in this declaration are based on the Petition,
`
`exhibits cited in the Petition, and other documents and materials identified in this
`
`declaration, including the ’117 patent and its prosecution history, the prior art
`
`references and materials discussed in this declaration, and any other references
`
`specifically identified in this declaration.
`
`22.
`
`I am aware of information generally available to, and relied upon by,
`
`persons of ordinary skill in the art at the relevant times, including technical
`
`
`
`8
`
`IPR2022-00058
`TACTION EX2001 PAGE009
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`dictionaries and technical reference materials (including, for example, textbooks,
`
`manuals, technical papers, articles, and relevant technical standards).
`
`23.
`
`I reserve the right to supplement my opinions to address any
`
`information obtained, or positions taken, based on any new information that comes
`
`to light throughout this proceeding.
`
`IV. Legal Standards
`
`A. Claim Construction
`
`24.
`
`I am not a lawyer, and I do not intend to offer any opinions as to the
`
`interpretation of the law. However, I have a general understanding of some relevant
`
`legal standards based on my experience with patents and my conversations with
`
`counsel.
`
`25. My understanding is that a primary step in determining validity of
`
`patent claims is to properly construe the claims to determine claim scope and
`
`meaning.
`
`26.
`
`I understand that claim terms are presumed to have their plain and
`
`ordinary meaning, as understood by a person of ordinary skill in the art at the time
`
`of the invention, in the context of the patent specification, the prosecution history,
`
`and any other relevant evidence.
`
`27.
`
`I am informed that to determine how a person of ordinary skill in the
`
`art would understand a claim term, one should look to those sources available that
`
`
`
`9
`
`IPR2022-00058
`TACTION EX2001 PAGE010
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`show what a person of skill in the art would have understood the disputed claim
`
`language to mean. Such sources include the words of the claims themselves, the
`
`remainder of the patent’s specification, the prosecution history of the patent and the
`
`cited references (all considered “intrinsic” evidence), and “extrinsic” evidence, such
`
`as dictionary definitions, learned treatises and the opinions of qualified experts
`
`concerning relevant scientific principles, the meaning of technical terms, and the
`
`state of the art.
`
`B. Obviousness
`
`28.
`
`It is my understanding that a claim is unpatentable under post-AIA 35
`
`U.S.C. § 103 if the claimed subject matter as a whole would have been obvious to a
`
`person of ordinary skill in the art at the time of the alleged invention. I understand
`
`that the determination of obviousness is made with respect to the subject matter as a
`
`whole, rather than separate pieces of the claim. I understand that obviousness is a
`
`question of law based on underlying factual issues. I also understand that an
`
`obviousness analysis takes into account the scope and content of the prior art, the
`
`differences between the claimed subject matter and the prior art, the level of ordinary
`
`skill in the art at the time of the invention, and the existence of secondary
`
`consideration such as commercial success or long-felt but unresolved needs.
`
`
`
`10
`
`IPR2022-00058
`TACTION EX2001 PAGE011
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`V. The ’117 Patent
`
`29. The ’117 patent is entitled “Systems and Methods for Generating
`
`Damped Electromagnetically Actuated Planar Motion for Audio-Frequency
`
`Vibrations.” It was filed as U.S. Patent Application No. 16/592,631 on October 3,
`
`2019, and issued on October 27, 2020. The ’117 patent claims priority to U.S.
`
`Provisional Patent Application Nos. 62/054,71, filed on September 24, 2014 and
`
`62/101,985, filed on January 10, 2015.
`
`30.
`
`In general, the ’117 patent is directed to ways to more accurately
`
`reproduce a wider range of signals with a haptic actuator. The ’117 patent claims
`
`specific configurations of flexures, coils, magnets, and a ferrofluid to lessen, or
`
`“damp,” undesired vibrations while also allowing the actuator to operate efficiently.
`
`This leads to tactile feedback that can more accurately reproduce complex input
`
`signals, including their amplitudes and frequencies.
`
`31.
`
`In the “Field of the Invention” section, the ’117 patent states: “The
`
`present invention relates to tactile transducers that produce bass frequency vibrations
`
`for perception by touch.” ’117 patent at 1:19-21.
`
`32. The specification of the ’117 patent contrasts prior art axial transducers,
`
`which produce motion perpendicular to the skin, with planar transducers of the
`
`claimed invention that vibrate parallel to the skin. Axial transducers produced
`
`undesired additional noise. Id. at 1:50-56 (“Axial movement of the mass causes a
`
`
`
`11
`
`IPR2022-00058
`TACTION EX2001 PAGE012
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`countermovement of the entire ear cup itself, which is typically sealed over the
`
`pinna. Thus, the same force that stimulates the skin under the ear cup cushions
`
`unfortunately also plunges air into the listener’s ear canal, overwhelming the output
`
`of the audio driver and generating the excess unwanted acoustic noise.”). Axial
`
`vibration also could not accurately reproduce desired input signals. Id. at 1:62-67
`
`(“[S]ignificant audio is added to the acoustic frequency response, causing an
`
`undesirable bump of 10-20 dB in the 50-100 Hz range. The result is a bass-heavy
`
`sound in which upper frequencies are underrepresented, and the user’s perception is
`
`one of muffled, muddy sound.”).
`
`33. The specification of the ’117 patent also discusses how lack of
`
`mechanical damping can lead to unwanted distortion. Id. at 2:1-6 (“The problem of
`
`uneven frequency response is typically made worse by a lack of mechanical
`
`damping. Leaving the system underdamped means that steady state signals near
`
`mechanical resonance achieve high amplitude, leading to a peaked response, and
`
`that the system rings after excitation is stopped, further degrading audio fidelity.”).
`
`34. The specification further notes that prior art un-damped Linear
`
`Resonant Actuators (LRAs), a type of haptic transducer, were handicapped for the
`
`purpose of reproducing input signals by having a strong resonant frequency that
`
`exaggerated vibrations near that frequency while suppressing off-frequency
`
`vibrations. Id. at 2:25-29 (“The main drawback of LRAs is the dependence on the
`
`
`
`12
`
`IPR2022-00058
`TACTION EX2001 PAGE013
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`‘resonance,’ that the name suggests. The devices are designed for tactile alerts, not
`
`fidelity, and so they resonate at a single frequency and produce perceptible vibration
`
`at only that frequency.”).
`
`35. To combat these problems, the ’117 patent proposes using a planar
`
`actuator rather than the prior art axial vibrators. Id. at 3:51-53 (“[P]roposed herein
`
`is a thin, flat vibration module with a movable member that is electromagnetically
`
`actuated to produce motion in-plane.”); 4:37-38 (“Planar motion of the module may
`
`be provided by various arrangements of magnets and coils.”).
`
`36. Additionally, to provide the needed damping, the ’117 patent discusses
`
`using ferrofluid in shearing contact with the moving portion of the actuator. Id. at
`
`4:6-8 (“The vibration of the moving portion may be damped using a suitable
`
`approach, such as the shearing of a layer of ferrofluid . . . .”); 8:38-41 (“[M]ovement
`
`of the mass 404 and magnets 402 may be damped by [a] thin layer of viscous
`
`ferrofluid 410 retained in a gap between the magnets 402 and bottom plate 405b of
`
`housing 405.”). In particular, use of a ferrofluid in direct contact with the moving
`
`portion of the actuator, such that it can shear against other surface, can produce a
`
`damping effect in the specific frequency range of 40-200 Hz. Id. at 3:53-58
`
`(“Motion of the movable member can be damped so that the steady-state sinusoidal
`
`voltages applied to the module at different frequencies produce an acceleration
`
`response of the movable member that is substantially uniform over the range of 40-
`
`
`
`13
`
`IPR2022-00058
`TACTION EX2001 PAGE014
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`200 Hz.”); see also cl. 1 (“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”). In order for the ferrofluid to have the
`
`desired damping effect, it must be positioned between the moving portion and
`
`another surface. E.g., id. at 11:34-36 (“Relative movement between the compliant
`
`upper membrane 905a and stage 905c is facilitated by the ferrofluid layer 911.”).
`
`37. The ’117 patent specification notes that the precise frequency-specific
`
`effects of the ferrofluid were not automatically attained by default with any amount
`
`of any ferrofluid, but rather required a particular viscosity and volume of the
`
`ferrofluid. Id. at 9:36-41 (“The viscosity and volume of the damping fluid (e.g.
`
`viscous ferrofluid 410 of FIG. 4B) in vibration module 500 were adjusted to damp
`
`resonance that would be evident at 30-50 Hz, to achieve the relatively uniform, non-
`
`peaked, response evident in FIG. 5C between 40 and 200 Hz in range 503.”). The
`
`’117 patent specification also includes “experimental results of the measured
`
`acceleration” that show the actual effects of ferrofluid damping in an exemplary test
`
`device. Id. at FIG. 5C; 9:13-24.
`
`38.
`
`In addition to planar motion and the use of a damping ferrofluid to
`
`achieve specific, quantified effects, the ’117 patent also describes structural aspects
`
`of the tactile transducer of the invention. The transducer includes a housing
`
`containing a moving mass with magnets. Id. at 3:63-66 (“[T]he module may consist
`
`
`
`14
`
`IPR2022-00058
`TACTION EX2001 PAGE015
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`of a mass and thin magnets, polarized through their thickness, where the mass and
`
`magnets are movably suspended inside a housing.”). Current applied to electrical
`
`coils in the transducer causes the moving mass containing the magnet to move
`
`reciprocally, vibrating the housing and imparting tactile sensations to anything
`
`contacting the housing. Id. at 11:20-21 (“[T]he magnets are urged laterally by
`
`current passed through coil 907.”). The particular relative structural arrangement of
`
`coils, magnets, and flux guides, plus the amount of current applied to the coils, and
`
`the magnetic field strength of the magnets, affects the Lorentz force that causes the
`
`moving portion to reciprocally vibrate. Id. at 7:52-8:5. The moving mass may be
`
`guided by flexures that attach the mass to the housing. Id. at 8:19-22 (“Flexures 406
`
`provide for movement of inertial mass 404 and magnets 402 along axis 401, which
`
`may be orthogonal to the thinnest dimension of the vibration module.”). These
`
`structural and electrical elements are reflected in challenged independent claims 1
`
`and 17.
`
`39. The combined results of these innovations leads to a device with better
`
`haptic feedback, in other words, a device that can more accurately represent desired
`
`audio and tactile waveforms (“high fidelity”). Id. at 8:61-65 (“Providing vibration
`
`modules that generate damped electromagnetically actuated planar motion for audio-
`
`frequency vibrations can advantageously speed a user’s reaction time by adding
`
`tactile sensations to audio . . . .”); 9:41-44 (“The absence of resonant peak in the
`
`
`
`15
`
`IPR2022-00058
`TACTION EX2001 PAGE016
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`response makes it possible to reproduce the tactile component of a musical
`
`experience with previously unattainable high fidelity.”).
`
`VI. Overview of the Cited Art
`
`A. Miyazaki
`
`40.
`
`I understand that Miyazaki, Ex. 1004, is the primary reference relied on
`
`by Petitioner and Dr. Hannaford as the base for all of Petitioner’s proposed
`
`obviousness combinations. Miyazaki is directed to “a vibrating motor provided with
`
`a movable portion that includes a permanent magnet and with a fixed portion that
`
`includes a coil.” Miyazaki at [0001].
`
`41. Miyazaki presents itself as a modification of another particular prior art
`
`reference, Japanese Patent No. 2002-200460 to Maruo et al. (“Maruo”). Maruo
`
`describes “a vibrating motor provided with a movable portion that includes a
`
`permanent magnet and with a fixed portion that includes a box-shaped case and a
`
`coil that, by being energized, generates a magnetic force that moves the movable
`
`portion.” Miyazaki at [0003]. The device described in Maruo enclosed the moving
`
`portion with surrounding plates, collectively termed a “yoke.” Id. (“In patent
`
`literature 1 above [Maruo], the movable portion is provided with a yoke that is
`
`disposed so as to surround an upper face, a lower face, and a lateral face of the
`
`permanent magnet.”). The yoke magnetically isolated the moving portion of
`
`Maruo’s device. Id. (“By surrounding the permanent magnet by the yoke, a
`
`
`
`16
`
`IPR2022-00058
`TACTION EX2001 PAGE017
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`magnetism of the permanent magnet is contained within the yoke, su ppressing
`
`magnetic leakage. As such, the magnetic force of the permanent magnet can be used
`
`effectively to drive the movable portion.”).
`
`42.
`
`In contrast to Maruo, Miyazaki proposes locating the yoke on the upper
`
`side of the housing, in addition to or in lieu of a yoke on the moving portion,
`
`providing improved magnetic containment. Id. at [0004] (“Here, to suppress
`
`magnetic leakage, it is also conceivable to provide the yoke not to the movable
`
`portion but to the fixed portion. For example, in the vibrating motor of patent
`
`literature 1 above [Maruo], when a yoke on an upper-face side of the permanent
`
`magnet of the movable portion is disposed on an upper face of the fixed portion
`
`(case), in this situation as well, magnetic leakage can be suppressed by containing
`
`the magnetism of the permanent magnet by the yoke of the movable portion and the
`
`yoke of the fixed portion.”).
`
`43. A person of ordinary skill in the art reading Miyazaki would have
`
`understood that it is concerned with a specific problem that arises when attempting
`
`to design the yoke such that it is part of the vibrating motor housing rather than the
`
`moving portion. Miyazaki notes that the magnet in the moving portion is
`
`magnetically attracted to the yoke on the upper side of the housing, and that the
`
`upward force resulting from the attraction distorts the intended motion of the moving
`
`portion. Id. at [0006] (“However, when the yoke on the upper-face side of the
`
`
`
`17
`
`IPR2022-00058
`TACTION EX2001 PAGE018
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`permanent magnet of the movable portion is disposed on the upper face of the fixed
`
`portion (case), the permanent magnet of the movable portion and the yoke of the
`
`fixed portion are mutually attracted such that a force that would move the movable
`
`portion to a yoke side (upper side) of the fixed portion acts on the movable portion.
`
`In this situation, because this force that would move the movable portion to the upper
`
`side acts as a resisting force against a vibrating operation of the movable portion,
`
`there is a problem wherein the movable portion becomes difficult to vibrate.”).
`
`44. Miyazaki proposes to solve this problem by placing an opposing yoke
`
`on the bottom of the housing to counteract the yoke on the top. Id. at [0008] (“Means
`
`for Solving Problem To achieve the above object, a vibrating motor according to one
`
`aspect of this invention is provided with . . . a fixed portion that includes an upper-
`
`face-side yoke and a lower-face-side yoke that are each disposed opposing the
`
`movable portion . . . .”); [0039] (“[T]he fixed portion 2 that includes the planar coils
`
`25 and 26 is provided with an upper-face-side yoke (upper case portion 22
`
`functioning as a yoke) and a lower-face-side yok (yoke 28, and baseplate 21
`
`functioning as a yoke) . . . .”). The two yokes balance out to magnetically isolate the
`
`moving portion while not interfering with its motion. Id. at [0027] (“This causes an
`
`entirety or a portion of an attractive force (downward attractive force) between, on
`
`one hand, the yoke 28 of the yoke-integrated coil portion 24 and the baseplate 21
`
`and, on the other, the permanent magnet 31 to be offset by an attractive force
`
`
`
`18
`
`IPR2022-00058
`TACTION EX2001 PAGE019
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`(upward attractive force) between the upper case portion 22 and the permanent
`
`magnet 31.”). This configuration also enhances the effectiveness of the transducer,
`
`ensuring that “the movable portion can be vibrated easily.” Id. at [0009].
`
`45. Miyazaki notes that using dual yokes in this manner also allows the Q
`
`value of the motor to be adjusted by changing the attractive force of the yoke plates.
`
`Id. at [0040] (“[A] Q value of a vibration system of the vibrating motor 1 can be
`
`adjusted easily. Here, the Q value is a dimensionless number serving to characterize
`
`a vibration state and is a quantity representing a vibration persistence characteristic
`
`of a resonating system.”); [0049] (“In the working example, the Q value is decreased
`
`(Q value = 10) by imparting a resisting force against the vibrations of the movable
`
`portion by adjusting the attractive force in the vertical direction on the movable
`
`portion.”).
`
`46. Miyazaki also notes that planar motion is an integral part of its
`
`operation and that planar motion allows the device to be thinner. Id. at [0036] (“By
`
`configuring a vibrating motor 1 that vibrates horizontally (vibrates in the arrow X1
`
`and X2 directions), making the vibrating motor thinner is easier compared to a
`
`vibrating motor that vibrates vertically (vibrates in the vertical direction (Z
`
`direction)).”); [0037] (“A movable portion 3 is provided that can move along a
`
`direction along a surface of the planar coils 25 and 26 (arrow X1 and X2 directions).
`
`As such, compared to a situation of moving the movable portion 3 linearly in the
`
`
`
`19
`
`IPR2022-00058
`TACTION EX2001 PAGE020
`
`

`

`Case No. IPR2022-00058
`U.S. Patent No. 10,820,117
`
`vertical direction using a coil having a large thickness in the vertical direction (Z
`
`direction), there is no need to provide a movement range (movement space in the
`
`vertical direction) for the movable portion 3. This can ensure freedom in design to
`
`decrease a thickness in this direction. As a result, a vibrating motor 1 that can be
`
`made thinner can be provided.”).
`
`47.
`
`I note in particular that Miyazaki contains no mention of ferrofluid or
`
`magnetic fluid. Miyazaki does state that the vibration response of the device around
`
`an “actual resonance frequency (f0)” in a device may be affected by differing Q
`
`values (i.e., from adjusting the relative attraction of the upper yoke). Id. at [0044],
`
`[0049], Figs. 9-10. I additionally note that Miyazaki does not mention any particular
`
`frequency ranges, or increasing fidelity in respon