Ex. 2001
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`Apple Inc.
`
`Petitioner,
`
`v.
`
`Taction Technology, Inc.,
`
`Patent Owner.
`
`________________
`
`Case IPR2022-00060
`U.S. Patent No. 10,820,117
`________________
`
`DECLARATION OF ALLISON OKAMURA, PH.D.
`IN SUPPORT OF TACTION TECHNOLOGY, INC.’S
`PATENT OWNER PRELIMINARY RESPONSE
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`
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`IPR2022-00060
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`Case No. IPR2022-00060
`U.S. Patent No. 10,820,117
`TABLE OF CONTENTS
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`Page
`Introduction ........................................................................................ 3
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`I.
`
`Summary of Opinions .......................................................................... 3
`II.
`III. Qualifications and Experience ............................................................... 4
`IV. Legal Standards ................................................................................... 8
`A. Claim Construction ..................................................................... 8
`B. Obviousness ............................................................................... 9
`The ’117 Patent ................................................................................. 10
`V.
`VI. Overview of the Cited Art ................................................................... 15
`A. Miyazaki ................................................................................. 15
`
`Park494 ................................................................................... 20
`B.
`Bang ....................................................................................... 22
`C.
`Park728 ................................................................................... 24
`D.
`E. Kajiwara .................................................................................. 25
`VII. Level of Ordinary Skill in the Art......................................................... 25
`VIII. Claim Construction ............................................................................ 27
`IX. Ground 1: Obviousness of Claim 16 Based on the Combination of
`Miyazaki, Park494, and Bang .............................................................. 28
`
`A.
`
`The Combination of Miyazaki, Park494, and Bang Fails to
`Disclose or Render Obvious “Wherein the Ferrofluid Damps at
`Least a Resonance in Response to Signals Applied to the
`Conductive Coil” ...................................................................... 28
`1.
`No Reference Discloses Damping a Resonance with
`Ferrofluid ....................................................................... 28
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`2.
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`B.
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`C.
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`Case No. IPR2022-00060
`U.S. Patent No. 10,820,117
`Damping in Park494’s Device Is Not Transferrable to
`Miyazaki’s Device ........................................................... 37
`The Combination of Miyazaki, Park494, and Bang Fails to
`Disclose or Render Obvious “Ferrofluid” ..................................... 38
`Petitioner Has Not Established that Miyazaki, Park494, and
`Bang Can Be Combined to Yield Claim 16 .................................. 42
`1.
`Petitioner Fails to Show Why a Person of Ordinary Skill
`in the Art Would Select Miyazaki, Park494, and Bang
`and Combine Them .......................................................... 43
`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 .......................... 46
`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 ............................................ 49
`X. Ground 2: Obviousness of Claim 17 Based on the Combination of
`Miyazaki, Park494, Bang, and Kajiwara ............................................... 54
`
`2.
`
`3.
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`XI. Ground 3: Obviousness of Claim 17 Based on the Combination of
`Miyazaki, Park494, Bang, and Park728 ................................................ 55
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`Case No. IPR2022-00060
`U.S. Patent No. 10,820,117
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`1.
`
`I, Allison Okamura, declare as follows:
`
`I.
`
`Introduction
`I have been engaged by Taction Technology, Inc. (“Taction”) as an
`2.
`
`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.
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`This declaration is based on the information currently available to me.
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`To the extent that additional information becomes available, I reserve the right to
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`continue my investigation and study, which may include a review of documents and
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`information that may be produced, as well as testimony from depositions that have
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`not yet been taken.
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`II.
`
`Summary of Opinions
`4.
`The Petition raises three grounds, each based on obviousness under
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`post-AIA 35 U.S.C. § 103.
`
`5.
`
`Ground 1 alleges that independent claim 16 is 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.
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`Patent Publication No. 2012/0187780 to Bang et al. (Ex. 1008, Bang). Petition at
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`12-52. Based on studying the Petition and the exhibits cited in the Petition as well
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`
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`3
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`U.S. Patent No. 10,820,117
`as other documents, it is my opinion that claim 16 of the ’117 patent is not rendered
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`obvious by the combination of Miyazaki, Park494, and Bang.
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`6.
`
`Ground 2 alleges that dependent claim 17 is obvious over Miyazaki in
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`view of Park494, Bang, and U.S. Patent Publication No. 2009/0267423 to Kajiwara
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`(Ex. 1006, “Kajiwara”). Petition at 53-66. Based on studying the Petition and the
`
`exhibits cited in the Petition as well as other documents, it is my opinion that claim
`
`17 of the ’117 patent is not rendered obvious by the combination of Miyazaki,
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`Park494, Bang, and Kajiwara.
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`7.
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`Ground 3 alleges that dependent claim 17 is obvious over Miyazaki in
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`view of Park494, Bang, and U.S. Patent No. 8,461,728 to Park et al. (Ex. 1007,
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`“Park728”). Petition at 66-75. Based on studying the Petition and the exhibits cited
`
`in the Petition as well as other documents, it is my opinion that claim 17 of the ’117
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`patent is not rendered obvious by the combination of Miyazaki, Park494, Bang, and
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`Park728.
`
`III. Qualifications and Experience
`8.
`I obtained my Bachelor of Science degree in Mechanical Engineering
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`from the University of California, Berkeley in 1994. I continued my education at
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`Stanford University, where I received my Master of Science degree in Mechanical
`
`Engineering in 1996 and my Ph.D. in Mechanical Engineering in 2000.
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`I am currently a Professor in the Mechanical Engineering Department
`
`9.
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`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
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`Mechanical Engineering Department.
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`10. At Stanford University, I am the director of the “CHARM” Lab, which
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`stands for Collaborative Haptics and Robotics in Medicine. I am also currently
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`involved in Stanford’s Center for Design Research, Wu Tsai Neurosciences Institute,
`
`and eWEAR initiative.
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`11. Before teaching at Stanford, I was an assistant, associate, and full
`
`professor in the Mechanical Engineering Department at Johns Hopkins University
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`from 2000-2011 and served as Vice Chair of the department. At Johns Hopkins, I
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`served as Associate Director of the Laboratory for Computational Sensing and
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`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
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`part of the NSF Engineering Research Center for Computer-Integrated Surgical
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`Systems and Technology, where I served as a faculty member (2000-2009) and
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`Surgical Assistants Thrust Leader (2004-2009).
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`12. Before I started teaching, I worked as a Graduate Research Assistant in
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`the Department of Mechanical Engineering at Stanford from 1994-2000. I also
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`worked part-time as a Research Engineer at Immersion Corporation in the 1996-
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`1998 time frame, while pursuing my Ph.D. at Stanford.
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`13.
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`I currently teach classes related to mechanical engineering, electrical
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`engineering, and computer science. In my research, I specialize in robotics and
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`human-machine interaction, with a particular focus on medical robotics and haptics.
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`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,
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`among others. For example, I have a current research grant from the Precision
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`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
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`journals and conference proceedings. I have also contributed to 15 books or
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`collections, including co-authoring a chapter on haptics in the Springer Handbook
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`of Robotics with Dr. Blake Hannaford, Apple’s expert in this proceeding. I have
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`also been an associate editor of the IEEE Transactions on Haptics, the editor-in-chief
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`of the IEEE Robotics and Automation Letters, the editor-in-chief of the IEEE
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`International Conference on Robotics and Automation Conference Editorial Board,
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`and co-chair of the IEEE Haptics Symposium.
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`I have received a number of awards and honors, including the IEEE
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`16.
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`Engineering in Medicine and Biology Society Technical Achievement Award, the
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`National Science Foundation CAREER award, and the IEEE Technical Committee
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`on Haptics Early Career Award, as well as Best Paper and Best Poster awards from
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`several conferences and journals. I have been an invited or keynote speaker at
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`numerous conferences and symposia, including the National Academy of Engineers
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`Frontiers of Engineering Symposium and the World Haptics Conference, and have
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`been an IEEE Fellow since 2011. In 2016, I was named the Duca Family University
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`Fellow in Undergraduate Education at Stanford University.
`
`17.
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`I am a named inventor on three patents relating to my work at Johns
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`Hopkins and four patents at Stanford, as well as several currently-pending patents.
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`18. My curriculum vitae is attached as Exhibit 2002.
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`19.
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`I am being compensated by Taction for my time spent working on this
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`matter at a rate of $600 per hour. My compensation is not contingent upon the
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`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.
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`20.
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`I have no financial interest in Taction or Apple.
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`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
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`declaration, including the ’117 patent and its prosecution history, the prior art
`
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`references and materials discussed in this declaration, and any other references
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`specifically identified in this declaration.
`
`22.
`
`I am aware of information generally available to, and relied upon by,
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`persons of ordinary skill in the art at the relevant times, including technical
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`dictionaries and technical reference materials (including, for example, textbooks,
`
`manuals, technical papers, articles, and relevant technical standards).
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`23.
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`I reserve the right to supplement my opinions to address any
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`information obtained, or positions taken, based on any new information that comes
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`to light throughout this proceeding.
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`IV. Legal Standards
`A. Claim Construction
`24.
`I am not a lawyer, and I do not intend to offer any opinions as to the
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`interpretation of the law. However, I have a general understanding of some relevant
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`legal standards based on my experience with patents and my conversations with
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`counsel.
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`25. My understanding is that a primary step in determining validity of
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`patent claims is to properly construe the claims to determine claim scope and
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`meaning.
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`26.
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`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
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`of the invention, in the context of the patent specification, the prosecution history,
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`and any other relevant evidence.
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`27.
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`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
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`show what a person of skill in the art would have understood the disputed claim
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`language to mean. Such sources include the words of the claims themselves, the
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`remainder of the patent’s specification, the prosecution history of the patent and the
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`cited references (all considered “intrinsic” evidence), and “extrinsic” evidence, such
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`as dictionary definitions, learned treatises and the opinions of qualified experts
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`concerning relevant scientific principles, the meaning of technical terms, and the
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`state of the art.
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`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
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`that the determination of obviousness is made with respect to the subject matter as a
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`whole, rather than separate pieces of the claim. I understand that obviousness is a
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`question of law based on underlying factual issues. I also understand that an
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`obviousness analysis takes into account the scope and content of the prior art, the
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`differences between the claimed subject matter and the prior art, the level of ordinary
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`skill in the art at the time of the invention, and the existence of secondary
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`consideration such as commercial success or long-felt but unresolved needs.
`
`V. The ’117 Patent
`29. The ’117 patent is entitled “Systems and Methods for Generating
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`Damped Electromagnetically Actuated Planar Motion for Audio-Frequency
`
`Vibrations.” It was filed as U.S. Patent Application No. 16/592,631 on October 3,
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`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
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`62/101,985, filed on January 10, 2015.
`
`30.
`
`In general, the ’117 patent is directed to ways to more accurately
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`reproduce a wider range of signals with a haptic actuator. The ’117 patent claims
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`specific configurations of flexures, coils, magnets, and a ferrofluid to lessen, or
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`“damp,” undesired vibrations while also allowing the actuator to operate efficiently.
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`This leads to tactile feedback that can more accurately reproduce complex input
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`signals, including their amplitudes and frequencies.
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`31.
`
`In the “Field of the Invention” section, the ’117 patent states: “The
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`present invention relates to tactile transducers that produce bass frequency vibrations
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`for perception by touch.” ’117 patent at 1:19-21.
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`32. The specification of the ’117 patent contrasts prior art axial transducers,
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`which produce motion perpendicular to the skin, with planar transducers of the
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`claimed invention that vibrate parallel to the skin. Axial transducers produced
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`undesired additional noise. Id. at 1:50-56 (“Axial movement of the mass causes a
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`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
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`unfortunately also plunges air into the listener’s ear canal, overwhelming the output
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`of the audio driver and generating the excess unwanted acoustic noise.”). Axial
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`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
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`sound in which upper frequencies are underrepresented, and the user’s perception is
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`one of muffled, muddy sound.”).
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`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
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`uneven frequency response is typically made worse by a lack of mechanical
`
`damping. Leaving the system underdamped means that steady state signals near
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`mechanical resonance achieve high amplitude, leading to a peaked response, and
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`that the system rings after excitation is stopped, further degrading audio fidelity.”).
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`34. The specification further notes that prior art un-damped Linear
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`Resonant Actuators (LRAs), a type of haptic transducer, were handicapped for the
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`purpose of reproducing input signals by having a strong resonant frequency that
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`exaggerated vibrations near that frequency while suppressing off-frequency
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`vibrations. Id. at 2:25-29 (“The main drawback of LRAs is the dependence on the
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`‘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.”).
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`35. To combat these problems, the ’117 patent proposes using a planar
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`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.”).
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`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
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`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
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`of the mass 404 and magnets 402 may be damped by [a] thin layer of viscous
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`ferrofluid 410 retained in a gap between the magnets 402 and bottom plate 405b of
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`housing 405.”). In particular, use of a ferrofluid in direct contact with the moving
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`portion of the actuator, such that it can shear against other surface, can produce a
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`damping effect. Id. at 3:53-58 (“Motion of the movable member can be damped so
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`that the steady-state sinusoidal voltages applied to the module at different
`
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`frequencies produce an acceleration response of the movable member that is
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`substantially uniform over the range of 40-200 Hz.”); see also cl. 1 (“wherein the
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`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”).
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`In particular, the ferrofluid has a specific damping effect on the resonant frequency,
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`or resonance, of the transducer. Id. at 9:25-44. In order for the ferrofluid to have
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`the desired damping effect, it must be positioned between the moving portion and
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`another surface. E.g., id. at 11:34-36 (“Relative movement between the compliant
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`upper membrane 905a and stage 905c is facilitated by the ferrofluid layer 911.”).
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`37. The ’117 patent specification notes that the effects of the ferrofluid on
`
`the resonant frequency, or resonance, were not automatically attained by default with
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`any amount of any ferrofluid, but rather required a particular viscosity and volume
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`of the ferrofluid. Id. at 9:36-41 (“The viscosity and volume of the damping fluid
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`(e.g. viscous ferrofluid 410 of FIG. 4B) in vibration module 500 were adjusted to
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`damp resonance that would be evident at 30-50 Hz, to achieve the relatively uniform,
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`non-peaked, response evident in FIG. 5C between 40 and 200 Hz in range 503.”).
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`The ’117 patent specification also includes “experimental results of the measured
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`acceleration” that show the actual effects of ferrofluid damping in an exemplary test
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`device. Id. at FIG. 5C; 9:13-24.
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`In addition to planar motion and the use of a damping ferrofluid to
`
`38.
`
`achieve specific, quantified effects, the ’117 patent also describes structural aspects
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`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
`
`of a mass and thin magnets, polarized through their thickness, where the mass and
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`magnets are movably suspended inside a housing.”). Current applied to electrical
`
`coils in the transducer causes the moving mass containing the magnet to move
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`reciprocally, vibrating the housing and imparting tactile sensations to anything
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`contacting the housing. Id. at 11:20-21 (“[T]he magnets are urged laterally by
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`current passed through coil 907.”). The particular relative structural arrangement of
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`coils, magnets, and flux guides, plus the amount of current applied to the coils, and
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`the magnetic field strength of the magnets, affects the Lorentz force that causes the
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`moving portion to reciprocally vibrate. Id. at 7:52-8:5. The moving mass may be
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`guided by flexures that attach the mass to the housing. Id. at 8:19-22 (“Flexures 406
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`provide for movement of inertial mass 404 and magnets 402 along axis 401, which
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`may be orthogonal to the thinnest dimension of the vibration module.”). These
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`structural and electrical elements are reflected in challenged independent claims 1
`
`and 17.
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`39. The combined results of these innovations leads to a device with better
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`haptic feedback, in other words, a device that can more accurately represent desired
`
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`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
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`tactile sensations to audio . . . .”); 9:41-44 (“The absence of resonant peak in the
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`response makes it possible to reproduce the tactile component of a musical
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`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
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`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
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`describes “a vibrating motor provided with a movable portion that includes a
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`permanent magnet and with a fixed portion that includes a box-shaped case and a
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`coil that, by being energized, generates a magnetic force that moves the movable
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`portion.” Miyazaki at [0003]. The device described in Maruo enclosed the moving
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`portion with surrounding plates, collectively termed a “yoke.” Id. (“In patent
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`literature 1 above [Maruo], the movable portion is provided with a yoke that is
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`disposed so as to surround an upper face, a lower face, and a lateral face of the
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`permanent magnet.”). The yoke magnetically isolated the moving portion of
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`Maruo’s device. Id. (“By surrounding the permanent magnet by the yoke, a
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`magnetism of the permanent magnet is contained within the yoke, suppressing
`
`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,
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`providing improved magnetic containment. Id. at [0004] (“Here, to suppress
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`magnetic leakage, it is also conceivable to provide the yoke not to the movable
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`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
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`magnet of the movable portion is disposed on an upper face of the fixed portion
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`(case), in this situation as well, magnetic leakage can be suppressed by containing
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`the magnetism of the permanent magnet by the yoke of the movable portion and the
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`yoke of the fixed portion.”).
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`43. A person of ordinary skill in the art reading Miyazaki would have
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`understood that it is concerned with a specific problem that arises when attempting
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`to design the yoke such that it is part of the vibrating motor housing rather than the
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`Case No. IPR2022-00060
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`moving portion. Miyazaki notes that the magnet in the moving portion is
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`magnetically attracted to the yoke on the upper side of the housing, and that the
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`upward force resulting from the attraction distorts the intended motion of the moving
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`portion. Id. at [0006] (“However, when the yoke on the upper-face side of the
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`permanent magnet of the movable portion is disposed on the upper face of the fixed
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`portion (case), the permanent magnet of the movable portion and the yoke of the
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`fixed portion are mutually attracted such that a force that would move the movable
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`portion to a yoke side (upper side) of the fixed portion acts on the movable portion.
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`In this situation, because this force that would move the movable portion to the upper
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`side acts as a resisting force against a vibrating operation of the movable portion,
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`there is a problem wherein the movable portion becomes difficult to vibrate.”).
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`44. Miyazaki proposes to solve this problem by placing an opposing yoke
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`on the bottom of the housing to counteract the yoke on the top. Id. at [0008] (“Means
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`for Solving Problem To achieve the above object, a vibrating motor according to one
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`aspect of this invention is provided with . . . a fixed portion that includes an upper-
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`face-side yoke and a lower-face-side yoke that are each disposed opposing the
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`movable portion . . . .”); [0039] (“[T]he fixed portion 2 that includes the planar coils
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`25 and 26 is provided with an upper-face-side yoke (upper case portion 22
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`functioning as a yoke) and a lower-face-side yok (yoke 28, and baseplate 21
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`functioning as a yoke) . . . .”). The two yokes balance out to magnetically isolate the
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`moving portion while not interfering with its motion. Id. at [0027] (“This causes an
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`entirety or a portion of an attractive force (downward attractive force) between, on
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`one hand, the yoke 28 of the yoke-integrated coil portion 24 and the baseplate 21
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`and, on the other, the permanent magnet 31 to be offset by an attractive force
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`(upward attractive force) between the upper case portion 22 and the permanent
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`magnet 31.”). This configuration also enhances the effectiveness of the transducer,
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`ensuring that “the movable portion can be vibrated easily.” Id. at [0009].
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`45. Miyazaki notes that using dual yokes in this manner also allows the Q
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`value of the motor to be adjusted by changing the attractive force of the yoke plates.
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`Id. at [0040] (“[A] Q value of a vibration system of the vibrating motor 1 can be
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`adjusted easily. Here, the Q value is a dimensionless number serving to characterize
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`a vibration state and is a quantity representing a vibration persistence characteristic
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`of a resonating system.”); [0049] (“In the working example, the Q value is decreased
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`(Q value = 10) by imparting a resisting force against the vibrations of the movable
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`portion by adjusting the attractive force in the vertical direction on the movable
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`portion.”).
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`46. Miyazaki also notes that planar motion is an integral part of its
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`operation and that planar motion allows the device to be thinner. Id. at [0036] (“By
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`configuring a vibrating motor 1 that vibrates horizontally (vibrates in the arrow X1
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`and X2 directions), making the vibrating motor thinner is easier compared to a
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`vibrating motor that vibrates vertically (vibrates in the vertical direction (Z
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`direction)).”); [0037] (“A movable portion 3 is provided that can move along a
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`direction along a surface of the planar coils 25 and 26 (arrow X1 and X2 directions).
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`As such, compared to a situation of moving the movable portion 3 linearly in the
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`vertical direction using a coil having a large thickness in the vertical direction (Z
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`direction), there is no need to provide a movement range (movement space in the
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`vertical direction) for the movable portion 3. This can ensure freedom in design to
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`decrease a thickness in this direction. As a result, a vibrating motor 1 that can be
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`made thinner can be provided.”).
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`47.
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`I note in particular that Miyazaki contains no mention of ferrofluid or
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`magnetic fluid. Miyazaki does state that the vibration response of the device around
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`an “actual resonance frequency (f0)” in a device may be affected by differing Q
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`values (i.e., from adjusting the relative attraction of the upper yoke). Id. at [0044],
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`[0049], Figs. 9-10. I additionally note that Miyazaki does not mention any particular
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`frequency ranges, or increasing fidelity in response to a wider range of frequencies.
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`Miyazaki focuses instead on avoiding the problem that occurs when “an actual
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`resonance frequency (f0) is shifted from a design value due to a manufacturing error,
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`assembly error, or the like of a component of the vibrating motor 1, in this situation
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`as well, a sufficient vibration amount can be obtained.” Id at [0044]. In my opinion,
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`a person of ordinary skill in the art reading Miyazaki would have understood that, to
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`the extent Miyazaki was focused on decreasing Q, it was to make the product less
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`sensitive to manufacturing tolerances by ensuring that production units will all be
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`capable of vibrating at the same single “design value” frequency.
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`B.
`48.
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`Park494
`I understand that Petitioner and Dr. Hannaford further rely on Park494,
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`Ex. 1005. Park494 is directed to a “linear vibrator” with “a housing; a stator fixed
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`inside the housing; a vibrating unit formed with an opening for surrounding the stator
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`and vibrating inside the housing by being interactive with the stator; and an elastic
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`member elastically supporting the vibrator inside the housing.” Park494 at Abstract.
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`Unlike Miyazaki, the physical structure of Park494 is a moving portion, containing
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`magnets, shaped like a square donut, while the fixed coil is inserted into the middle
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`donut hole of the moving portion. Id. at Fig. 1; see also id. at 3:32-37 (“The weight
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`(161) has a square framed shape with