Title
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`1/28/2022 4:19:06 PM
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`IPR2022-00059
`TACTION EX2022 PAGE001
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`Date & Time
`Comparison Time
`compareDocs version
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`Summary Report
`compareDocs Comparison Results
`1/28/2022 4:19:06 PM
`2.66 seconds
`v5.0.100.42
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`Original Document
`Modified Document
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`Sources
`PTAB-IPR2022-00057-1.docx
`PTAB-IPR2022-00059-1.docx
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`28
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`71
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`compareDocs Settings Used
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`Character Level
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`Include Quotation Marks
`Show Moves
`Include Tables
`Include Text Boxes
`Show Reviewing Pane
`Summary Report
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`Standard
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`Name
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`IPR2022-00057
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`U.S. Patent No. 10,659,885
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` Claim [1(g)]420(g)]5
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`Miyazaki in view of Park494 and Kajiwara The Miyazaki-Park494-
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`Kajiwara combination renders obvious, the ferrofluid (e.g., magnetic fluid 180)
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`reducing at least a mechanical resonance within reduces the Q-Factor of the
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`response of the apparatus (e.g., vibrating motor 1) over at least a portion of the
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`frequency range of 40-200 Hz in response to electrical signals applied to the
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`plurality of conductive coils coil (e.g., planar coils 25 and /or 26).
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`Miyazaki’s Teachings
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`Miyazaki teaches that in operation, a drive current is first supplied to the
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`current lines of planar coils 25 and 26, which causes currents to flow through the
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`coils and results resulting in the movable portion moving linearly in one direction
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`(e.g., X2 direction). Miyazaki, [0032]. A drive current is then supplied in an opposite
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`direction after a predetermined time, which causes the movable portion 3 to move
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`linearly in the opposite direction (e.g., X1 direction). Id., [0033]. “[B]y switching
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`the direction of the drive current at a predetermined frequency, the movable portion
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`3 undergoes reciprocating motion by alternating linear movement in the arrow X1
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`direction and the arrow X2 direction.” Id. Because Miyazaki teaches alternately
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`switching a drive
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`4 5 For the purposes of this Petition only, Petitioner interprets “the frequency
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`range” as “a frequency range.”
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`current to the planar coils at a predetermined frequency resulting in a linear
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`movement of the moving portion in the X1 and X2 directions, a PHOSITA would
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`have understood that Miyazaki teaches driving a moving portion at a predetermined
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`frequency in response to a drive current (i.e., signal) that is applied to the coils. Decl.,
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`¶ ¶¶ 157, 112.
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`The Miyazaki-Park494 Vibrating Motor
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`As discussed above, in the proposed the Miyazaki-Park494 vibrating motor, a
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`ferrofluid is used to damp the resonance (or movement) of the movable portion 3.
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`Section V.A.2.g. (claim limitation [20(f)]), supra. A PHOSITA would have known
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`that a Q-factor refers to a dimensionless parameter that measures the persistence of
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`damped oscillations in a resonator. Decl., ¶¶ 158-159, 113, 48, 55. The Q-factor is
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`related to resonance and describes how sharp, or steep, the resonance is, as
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`demonstrated by a resonance peak. Id., ¶¶ 160, 46-48. A high Q-factor has less
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`energy loss than a low Q-factor, which causes the oscillations to stop more slowly
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`(e.g., continues oscillating for a longer period). Id., ¶¶ 160, 48, 55. A PHOSITA
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`would have thus understood that a damping mechanism, such as Park494’s magnetic
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`fluid, which causes the moving portion to “stop when it is to be stopped,” reduces a
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`Q-factor, because the moving portion will come to a stop more quickly (or oscillate
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`for a shorter period). Id., ¶ 160. Thus, Miyazaki as modified by Park494 as described
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`above teaches the ferrofluid reduces the Q-Factor of the response of the apparatus in
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`response to signals applied to the coil. Id., ¶¶ 158-160, 113.
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`Kajiwara’s Teachings
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`Kajiwara teaches an electromagnetic exciter (i.e., a linear vibration motor)
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`that includes a casing, a stator having an electromagnet and fixed in the casing, an
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`oscillator, and an elastic support member, and the electromagnetic exciter operates
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`within the frequency range of 120-180 Hz and has a resonance peak around 150 Hz.
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`Kajiwara, [0121], [0081], Fig. 20. Like the movable portion 3 of Miyazaki and the
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`vibrator of Park494, Kajiwara’s oscillator includes a weight and a permanent
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`magnet. Id., [0092]. “The oscillator is oscillated by an alternating magnetic field
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`generated by application of an alternating voltage to the electromagnet of the stator.”
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`Id., [0095]-[0100]. A PHOSITA would thus have understood that Kajiwara’s
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`oscillator is a moving portion. Decl., ¶ ¶¶ 161, 114.
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`Kajiwara’s exciter utilizes a damping technique. Kajiwara, [0105]. Kajiwara
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`accomplishes this damping technique using deformable members 7. Id., [0106].
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`Although Kajiwara primarily discusses resin-based deformable members, Kajiwara
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`also teaches that other vibration isolating materials may be used. Id. Kajiwara
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`explains that in a situation where no damping material is used, the oscillator vibrates
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`freely by inertia due to the weight. Id., [0106]. However, when a damping material
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`is used, an interfering effect occurs between the oscillator and the elastic support
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`member 4, which damps the action. Id., [0106].
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`The damped oscillation characteristics of the electromagnetic exciter 1 are
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`shown in the figure below:
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`Id., Fig. 19. Part (a) shows oscillation characteristics when damping material is
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`provided and part (b) shows oscillation characteristics when damping material is not
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`provided. Id., [0107]. “When the supply of the driving voltage Vm stops at the
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`time axis 0, the damping of the vibration of the oscillator 20 starts and the
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`vibration decreases with the passage of time.” Id., [0108]. As shown in the above
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`figure, when
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`a damping material is used, the vibration of the oscillator 20 is damped to a level
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`where the amplitude is substantially 0 in about a half of the time as an oscillator 20
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`that does not utilize a damping material (shown in part (b)). Id., [0109]. Accordingly,
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`when a damping material is used, the vibration energy of oscillator 20 is absorbed,
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`which effectively damps the vibration. Id. As such, the damping material more
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`rapidly stops the vibrating unit when the vibrating unit is to be stopped. Decl., ¶¶
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`161, 115-116, 46-48.
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`The driving frequency characteristics of the electromagnetic exciter 1 are
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`depicted in the figure below:
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`Kajiwara, Fig. 20. The horizontal or x-axis represents the frequency (Hz) of the
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`driving signal, and the vertical or y-axis represents the vibration level (G). Id.,
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`[0110]. The curve Fl shows the oscillation characteristics when a damping material
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`is used while the curve F2 shows the oscillation characteristics when no damping
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`material is used. Id. A PHOSITA would have understood that the oscillation
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`characteristics represent an example of mechanical resonance that occurs when the
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`oscillator is oscillated. Decl., ¶ As shown in the Figure, the resonance peak occurs
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`around 150 Hz and the operating range is between 120-180 Hz. Decl., ¶¶ 161, 117.
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`As shown by the figure, when a damping material is not used, the resonance
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`amplitude (e.g., resonance peak) is higher than when a damping material is used. Id.,
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`¶ ¶¶ 161, 118.
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`Kajiwara, Fig. 20 (annotated to show the lower resonance peak of the damped
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`exciter in red and the higher resonance peak of the undamped exciter in blue); id.,
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`[110] (“the resonance amplitude is higher” when not damped).
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`Further, the resonance peak is reduced from a sharper peak to a broader flatter
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`peak. Decl., ¶ ¶¶ 161, 118.
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`U.S. Patent No. 10,659,885
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`
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`Kajiwara, Fig. 20 (excerpt annotated to show the broader flatter resonance peak of
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`the damped exciter in red and the sharper narrower resonance peak of the undamped
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`exciter in blue). Thus, Kajiwara teaches that the use of a damping material causes
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`both a reduction in the amplitude of the resonance peak and a broadening or
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`flattening of the resonance peak. Decl., ¶¶ 161, 118-120. Because the device
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`operates in the range of 120-180Hz and the resonance peak occurs around 150 Hz,
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`this reduction occurs within the frequency range of 40-200Hz. Id., ¶¶ 161, 119.
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`both the vibration level and a mechanical resonance are reduced Kajiwara
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`notes that the degree of sharpness Q is higher in the structure that does not have a
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`damping material than those of the structure provided with the damping material.
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`Decl., ¶¶ 118-120. Because the reduction in resonance occurs at or around 150 Hz,
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`this reduction in resonance occurs within the frequency range of 40-200Hz. Id., ¶
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`119Id., [0110]. A PHOSITA would have understood that the Q referenced by
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`Kajiwara is the Q-factor. Decl., ¶ 162. Accordingly, Kajiwara teaches that when the
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`electromagnetic exciter is damped a reduction in the resonance amplitude will
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`occur, and the time it takes for the moving portion to come to rest substantially
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`decreases (i.e., improved stopping characteristics). Id., ¶¶ 114-120. Because
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`Kajiwara teaches that the resonant frequency occurs around 150 Hz and that
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`damping will directly result in thethe Q-factor is also decreased. Id. Because a
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`PHOSITA would have known that the Q-factor describes the sharpness or
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`steepness of resonance as measured by a resonance peak, a PHOSITA would have
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`understood that the reduction in the amplitude of a resonance peak and the
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`broadening and flattening of a resonance peak is the reduction of the Q-factor. Id.,
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`reduction of the amplitude at the resonance frequency, ¶¶ 162, 46-48, 55. And in a
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`device with a resonant frequency of 150 Hz (and operating between 120-180 Hz),
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`this reduction would therefore occur at those same frequencies. Id., ¶ 162.
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`Accordingly, Kajiwara expressly discloses an example of a damping material that
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`“reduces the Q-Factor of the response of the apparatus over at least a mechanical
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`resonance within a portion of the frequency range of 40-200 Hz .” Id., ¶ 120.in
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`response to signals applied to the coil.” Id.
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`Motivation to Combine Miyazaki, Park494, and Kajiwara
`Combination of Miyazaki and Park494 in Light of Kajiwara’s Teachings
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`A PHOSITA would have been motivated to implement the Miyazaki-Park494
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`vibrating motor such that it operated at least in a frequency range of 120-180 Hz, by
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`selecting a resonant frequency around 150 Hz, as taught by Kajiwara. Decl., ¶¶ 163-
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`165, 121-125. Implemented to operate in at least the frequency range of 120-180 Hz
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`taught by Kajiwara, the damping ferrofluid (e.g., magnetic fluid 180 of Park494)
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`would have reduced at least a mechanical resonance the Q-Factor of the response of
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`the apparatus in response to signals applied to the coil in a manner similar to that
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`taught by Kajiwara. Id., ¶¶ 163, 158, 113, 121. Specifically, the mechanical
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`resonance Q-Factor of the response of the apparatus within the operating frequency
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`range would have been reduced with respect to the resonance peak (e.g., decreasing
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`and flattening the resonance peak) as a result of the damping. Id. And because the
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`operating frequency is between at least 120-180Hz, which is
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`within the range of 40-200 Hz4, the ferrofluid of the Miyazaki-Park494-Kajiwara
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`combination reduces at least a mechanical resonance Q-Factor of the response of
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`the apparatus within the frequency range of 40-200Hz in response to the
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`application of the electrical signals to the plurality of coils. Id., ¶ ¶¶ 163, 121.
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`Indeed, the Federal Circuit has found that an overlap in ranges creates a
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`presumption of obviousness. E.I. DuPont de Nemours & Co. v. Synvina C.V., 904
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`F.3d 996, 1006 (Fed. Cir. 2018).
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`As discussed above, Miyazaki teaches driving the vibrating motor 1 at a
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`predetermined frequency. However, Miyazaki does not specify an operating
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`frequency range. A PHOSITA would have been motivated to look to other
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`references such as Kajiwara to determine the frequency range of operation. Id.,
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`¶ ¶¶ 164, 122. Because Kajiwara discloses a frequency range for a vibrating motor
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`for use in mobile devices and Miyazaki and Park494 each describe a vibrating motor
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`for use in mobile devices, a PHOSITA would have been motivated to use the
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`frequency range taught by Kajiwara in the Miyazaki-Park494 vibrating motor. Id.
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`Additionally, it was well-known at the time that the optimal operating
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`frequency for haptic actuators used in mobile devices was between 100-300 Hz. Id.,
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`¶¶ ¶¶ 164, 123, 58-62. Thus, it was common at the time for most haptic actuators in
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`mobile devices to operate within this optimal frequency range. Id. And because
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`Kajiwara teaches a frequency range within that optimal range, it would have been
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`obvious to a PHOSITA to implement the Miyazaki-Park494 vibrating motor to
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`operate in at least Kajiwara’s range of 120-180 Hz. Id., ¶ ¶¶ 164, 123. Such a
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`modification would have involved only routine experimentation to discover the
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`optimal workable ranges and thus would have been well-within the skillset of a
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`PHOSITA. Id. , ¶ 164; E.I. DuPont, 904 F.3d at 1006 (Fed. Cir. 2018) (“The legal
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`principle at issue in this case is old. For decades, this court and its predecessor have
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`recognized that ‘where the general conditions of a claim are disclosed in the prior
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`art, it is not inventive to discover the optimum or workable ranges by routine
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`experimentation.’”) (citing In re Aller, 220 F.2d 454, 456 (CCPA 1955)).
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`Given the similarities between the references, a PHOSITA would have had a
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`reasonable expectation of success in implementing the teachings of Kajiwara in the
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`Miyazaki-Park494 combination. Decl., ¶ ¶¶ 164, 124. Indeed, like Miyazaki and
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`Park494, Kajiwara teaches a motor or exciter for providing haptics in mobile
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`devices that are driven by electromagnetic forces, including a moving portion (e.g.,
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`oscillator) comprising a weight and magnets, a coil for carrying the electric current,
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`a suspension for supporting the moving portion, and a housing containing each of
`
`the components. Kajiwara, [0082]. A PHOSITA would have understood that the
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`resonant frequency determines the operating frequency of the actuator. Decl.,
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`¶¶ 164, 124, 43, 58-62. And a PHOSITA would have known that primary elements
`
`involved in adjusting the resonant frequency of an actuator is the mass of the weight
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`and the strength of the suspension. Id., ¶¶ 164, 124, 63. Because each reference
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`teaches the inclusion of both a weight and springs (or elastic member), modifying
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`the Miyazaki-Park494 vibrating motor to operate within the frequency range taught
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`by Kajiwara would not have required undue experimentation and would have
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`yielded predictable results. Id., ¶ ¶¶ 164, 124.
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`Further, each reference teaches the use of a damping mechanism. Miyazaki,
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`[0082] (teaching friction-based damping), Park494, 4:20-28 (teaching magnetic
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`fluid), Kajiwara, [0105] (teaching resin-based deformable members). A PHOSITA
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`would have understood all damping mechanisms would have damped at least the
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`resonance peak, as physics dictates that they must. Decl., ¶¶ 164, 125, 158, 113, 46-
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`46-4748. And a PHOSITA would have further understood that because damping
`
`results in a reduction in the amplitude of the resonance peak and a broadening and
`
`flattening of the peak, such damping also reduces the Q-factor. Id., ¶¶ 164, 158-
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`160, 113, 46- 48, 55. Further, magnetic fluids were well known damping agents
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`used in vibrating motors and linear actuators, id., ¶¶ 164, 125, 49-5749-55, and
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`Park494 teaches that its magnetic fluid “serves as a damper for rapidly stopping the
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`vibrating unit (160) when the vibrating unit (160) is to be stopped.” Park494, 4:23-
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`28. And because Kajiwara teaches that other vibration isolating materials may be
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`used (Kajiwara, [0105]), a PHOSITA would have understood that a magnetic fluid
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`was also a vibration isolating material that would perform damping like the
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`vibration isolating material comprising the deformable members taught by
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`Kajiwara. Decl., ¶ 125164.
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`Because the Miyazaki-Park494-Kajiwara vibrating motor would have
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`operated within the frequency range of 120-180Hz, a PHOSITA would thus have
`
`understood that use of damping reduces the Q-factor within that operating range.
`
`Decl., ¶ 165. And Kajiwara’s disclosure expressly confirms this, explaining that
`
`when the damping mechanism is not provided, the resonance amplitude is higher
`
`and “the degree of sharpness Q” is higher than those of the structure provided with
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`the damping mechanism. Kajiwara, [0110].
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