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`1/31/2022 12:44:50 AM
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`v5.0.100.42
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`Original Document
`Modified Document
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`Sources
`060 Paper 1 - Petition for Inter Partes Review of U.S. Patent No. 10,820,117.docx
`058 Paper 1 - Petition for Inter Partes Review of U.S. Patent No. 10,820,117.docx
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`IPR2022-00058
`IPR2022-00060
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` Claim [1(h)]
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`Claim 17
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`1.
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`The Miyazaki-Park494-Bang combination renders claim 16 obvious. See
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`Section V.A.2. (Claim 16), supra.
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`Miyazaki in view of Park494 and Miyazaki (as modified by Park494) in
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`view of Kajiwara renders obvious , the ferrofluid (e.g., magnetic fluid 180)
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`reducing at least a resonance within reduces a Q-Factor of a response of the
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`apparatus (e.g., vibrating motor 1) over at least a portion of a frequency range of
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`40-200 Hz in response to signals applied to the plurality of conductive coils coil
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`(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 drivecurrent to the planar coils at a predetermined frequency resulting
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`in a linear
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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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`¶ 119144.
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`The Miyazaki-Park494-Bang Vibrating Motor
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`In the Miyazaki-Bang vibrating motor as modified by Park494, a ferrofluid is
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`used to damp the resonance (or movement) of the movable portion 3. Sections
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`V.A.2.j. (claim limitation [16(i)]), V.A.2.l. (claim limitation [16(k)]), supra. A
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`PHOSITA would have known that a Q-factor refers to a dimensionless parameter
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`that measures the persistence of damped oscillations in a resonator. Decl., ¶¶ 148,
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`52-54, 61. The Q-factor is related to resonance and describes how sharp, or steep,
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`the resonance is, as demonstrated by a resonance peak. Id.. 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. A PHOSITA would have thus
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`understood that a damping mechanism, such as Park494’s magnetic fluid, which
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`causes the moving portion to “stop when it is to be stopped,” reduces a Q-factor,
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`because the moving portion will come to a stop more quickly (or oscillate for a
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`shorter period). Id., ¶¶ 148, 136-139. Thus, Miyazaki as modified by Park494 as
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`described above teaches the ferrofluid reduces the Q-Factor of the response of the
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`apparatus in response to signals applied to the coil. Id., ¶¶ 145-148.
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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., ¶ 121149.
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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
`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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`122-123150-151, 52-55.
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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., ¶ 124As shown in the Figure, the resonance peak
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`occurs around 150 Hz and the operating range is between 120-180 Hz. Decl., ¶ 152.
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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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`¶ 125153.
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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). Further, the
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`resonance peak is reduced from a sharper peak to a broader flatter peak. Decl., ¶
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`125153.
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`10
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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, both the vibration level and a mechanical resonance are
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`reduced with the damping material. Decl., ¶ 125. Because the reduction in resonance
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`occurs at or around 150 Hz, this reduction in resonance Kajiwara teaches that the
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`use of a damping material causes both a reduction in the amplitude of the
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`resonance peak and a broadening or flattening of the resonance peak. Decl., ¶ 153.
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`Because the device operates in the range of 120-180Hz and the resonance peak
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`occurs around 150 Hz, this reduction occurs within the frequency range of 40-
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`200Hz40-200 Hz. Id., ¶¶ 125-126.153-154.
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`Kajiwara notes that the degree of sharpness Q is higher in the structure that
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`does not have a damping material than those of the structure provided with the
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`damping material. Id., [0110]. A PHOSITA would have understood that the Q
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`referenced by Kajiwara is the Q-factor. Decl., ¶¶ 155, 52-54, 61. Accordingly,
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`Kajiwara teaches that when the electromagnetic exciter is damped the Q-factor is
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`also decreased. Id., ¶ 155. Because a PHOSITA would have known that the Q-factor
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`describes the sharpness or steepness of resonance as measured by a resonance peak,
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`a PHOSITA would have understood that the reduction in the amplitude of a
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`resonance peak and the broadening and flattening of a resonance peak is the
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`reduction of the Q-factor. Id., ¶¶ 155, 52-54, 61. And in a device with a resonant
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`frequency of 150 Hz (and operating between 120-180 Hz), this reduction would
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`therefore occur at those same frequencies. Id. Accordingly, Kajiwara expressly
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`discloses an example of a damping material that “reduces the Q-Factor of the
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`response of the apparatus over at least a portion of the frequency range of 40-200 Hz
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`in response to signals applied to the coil.” Id., ¶ 155.
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`Motivation to Combine Miyazaki, Park494, Bang and Kajiwara
`Accordingly, Kajiwara teaches that when the electromagnetic exciter is
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`damped a reduction in the resonance amplitude will occur, and the time it takes for
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`the moving portion to come to rest substantially decreases (i.e., improved stopping
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`characteristics). Id., ¶ 127. Because Kajiwara teaches that the resonant frequency
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`occurs around 150 Hz and that damping will directly result in the reduction of the
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`amplitude at the resonance frequency, Kajiwara expressly discloses an example of
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`a damping material that “reduces at least a resonance within a frequency range of
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`40-200 Hz.” Id.
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`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-
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`Park494 Miyazaki- Park494-Bang vibrating motor such that it operated at least in a
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`frequency range of 120-180Hz120-180 Hz, by selecting a resonant frequency
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`IPR2022-00060
`around 150 Hz, as taught by Kajiwara. Decl., ¶¶ 128-132156-161. Implemented to
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`operate in at least the frequency range of 120-180Hz 120-180 Hz taught by
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`Kajiwara, the damping ferrofluid (e.g., magnetic fluid 180 of Park494) would have
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`reduced at least a mechanical resonance the Q-Factor of the response of the
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`apparatus in response to signals applied to the coil in a manner similar to that taught
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`by Kajiwara. Id., ¶¶ 128, 120¶ 156. Specifically, the mechanical resonance Q-
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`Factor of the response of the apparatus within the operating frequency range would
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`have been reduced with respect to the resonance peak (e.g., decreasing and
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`flattening the resonance peak) as a result of the damping. Id., ¶¶ 156, 145-148, 136-
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`139, 52-54, 61. And because the operating frequency is
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`between at least 120-180 Hz, which is within the range of 40-200 Hz, the ferrofluid
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`of the Miyazaki-Park494-Kajiwara combination reduces at least a mechanical
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`resonance Q-Factor of the response of the apparatus within the frequency range of
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`40-200 Hz in response to the application of the electrical signals to the plurality of
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`coils. Id., ¶ 128. Indeed, the Federal Circuit has found that an overlap in ranges
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`creates a presumption of obviousness.
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`E.I. DuPont de Nemours & Co. v. Synvina C.V., 904 F.3d 996, 1006 (Fed. Cir. 2018).
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`Miyazaki teaches driving the vibrating motor 1 at a predetermined frequency.
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`Decl., ¶¶ 119157, 129 144. 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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`129157. Because Kajiwara discloses a frequency range for a vibrating motor for use
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`in mobile devices and Miyazaki and Park494 each describe a vibrating motor for use
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`in mobile devices, a PHOSITA would have been motivated to use the frequency
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`range taught by Kajiwara in the Miyazaki-Park494 -Bang 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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`¶¶ 130158, 64-68. 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 -Bang vibrating motor
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`to operate
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`in at least Kajiwara’s range of 120-180 Hz. Id., ¶ 130158. Such a modification
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`would have involved only routine experimentation to discover the optimal workable
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`ranges and thus would have been well-within the skillset of a PHOSITA. Id. E.I.
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`DuPont, 904 F.3d at 1006 (Fed. Cir. 2018) (“The legal principle at issue in this
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`case is old. For decades, this court and its predecessor have recognized that ‘where
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`the general conditions of a claim are disclosed in the prior art, it is not inventive to
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`discover the optimum or workable ranges by routine experimentation.’”) (citing In
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`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 -Bang combination. Decl., ¶ 131159. 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
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`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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`¶¶ 131159, 145-148, 136-139, 42-43, 64. And a PHOSITA would have known that
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`the primary elements involved in adjusting the resonant frequency of an actuator is
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`are the mass of the weight and the strength of the suspension. Id., ¶¶ 131159, 69.
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`Because each
`Because each
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`reference teaches the inclusion of both a weight and springs (or elastic member),
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`modifying the Miyazaki-Park494 -Bang vibrating motor to operate within the
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`frequency range taught by Kajiwara would not have required undue experimentation
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`and would have yielded predictable results. Id., ¶ 131159.
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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); Decl., ¶ 160.
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`A PHOSITA would have understood all damping mechanisms would have damped
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`at least the resonance peak, as physics dictates that they must. Decl., ¶¶ 160, 145-
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`148, 136-139, 52-54. And a PHOSITA would have further understood that because
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`damping results in a reduction in the amplitude of the resonance peak and a
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`broadening and flattening of the peak, such damping also reduces the Q-factor. Id.,
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`resonance peak, as physics dictates that they must. Decl., ¶¶ 132, 120, ¶¶ 160, 52-
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`54. Further, magnetic fluids were well known damping agents used in vibrating
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`motors and linear actuators, id., ¶¶ 132¶ 160, 51, 53-63, . and Park494 teaches that
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`its magnetic fluid “serves as a damper for rapidly stopping the vibrating unit (160)
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`when the vibrating unit (160) is to be stopped.” Park494, 4:23-28. And because
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`Kajiwara teaches that other vibration isolating materials may be used (Kajiwara,
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`[0105]), a PHOSITA would have understood that a magnetic fluid was also a
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`vibration isolating material that would perform damping like the vibration isolating
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`material comprising the deformable members taught by Kajiwara. Decl., ¶ 132160.
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`IPR2022-00060
`U.S. Patent No. 10,820,117
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`Because the Miyazaki-Park494-Bang-Kajiwara vibrating motor would have
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`operated within the frequency range of 120-180 Hz, a PHOSITA would thus have
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`understood that use of damping reduces the Q-factor within that operating range.
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`Decl., ¶ 161. And Kajiwara’s disclosure expressly confirms this, explaining that
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`when the damping mechanism is not provided, the resonance amplitude is higher
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`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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