`
` Case No. IPR2024-00556
`US Patent 8,748,507
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________________
`
`
`
`VALVE CORPORATION
`Petitioner,
`
`v.
`
`
`IMMERSION CORPORATION
`Patent Owner.
`
`
`
`__________________________________
`
`Case No. IPR2024-00556
`U.S. Patent No. 9,748,507
`__________________________________
`
`EXHIBIT 2001
`
`DECLARATION OF CRAIG ROSENBERG, Ph.D.
`IN SUPPORT OF IMMERSION CORPORATION’S
`PATENT OWNER RESPONSE
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`
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`Valve Corp. v. Immersion Corp.
`IPR2024-00556
`Immersion Exhibit 2001
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`TABLE OF CONTENTS
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`I.
`
`II.
`
`BACKGROUND AND QUALIFICATIONS ................................................. 2
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`BASES OF OPINIONS ................................................................................... 9
`
`III.
`
`SUMMARY OF OPINIONS ......................................................................... 10
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`IV. APPLICABLE LEGAL STANDARDS ........................................................ 11
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`A. Ordinary Skill in the Art ........................................................... 11
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`B.
`
`C.
`
`Claim Construction ................................................................... 12
`
`Anticipation ............................................................................... 13
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`D. Obviousness .............................................................................. 14
`
`V. OVERVIEW OF THE ’507 PATENT .......................................................... 17
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`VI. File History of the ’507 PATENT ................................................................. 21
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`VII. ASTALA-SHAHOIAN DOES NOT Teach THE CHALLENGED
`CLAIMS OF THE ’507 PATENT................................................................. 25
`
`A.
`
`B.
`
`C.
`
`The Astala Reference (Ex. 1005) .............................................. 25
`
`The Shahoian Reference (Ex. 1004) ......................................... 27
`
`Astala-Shahoian Does Not Disclose “Determining a
`Press” as Recited in Claim 1 of the ’507 Patent ....................... 27
`
`VIII. Keely + Kolmyko-Zotov DOES NOT Teach THE CHALLENGED
`CLAIMS OF THE ’507 PATENT................................................................. 30
`
`A.
`
`B.
`
`C.
`
`The Keely Reference (Ex. 1007) .............................................. 30
`
`Kolmykov-Zotov Reference (Ex. 1008) ................................... 32
`
`Keely combined with Kolmykov-Zotov Does Does Not
`Disclose “Determining a Press” as Recited in the
`Independent Claims of the ’507 Patent ..................................... 34
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`I, Craig Rosenberg, declare as follows:
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`1.
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`I have been retained by Folio Law Group PLLC, counsel for Patent
`
`Owner Immersion Corporation (“Immersion”) to assess the challenged claims of
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`U.S. Patent No. 8,749,507 (“the ’507 patent”) in connection with this case which is
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`the Petition for Inter Partes Review of the ’507 patent (“the Petition”).
`
`2.
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`I am being compensated for my work on this case and my fee is not
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`contingent on the outcome of this case or on any of my opinions or the technical
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`positions I explain in this report. In addition, I have no financial interest in the
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`outcome of this case or any of the parties involved in this case.
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`3.
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`I believe I am qualified to serve as a technical expert in this proceeding
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`based on my educational and work experience, including my 30+ years of experience
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`in human factors, user interface design, user interaction design, human-computer
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`interaction, and software engineering from 1988 through today.
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`4.
`
`This declaration sets forth my opinions, which I formed based on my
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`study of the evidence; my understanding as an expert in the field; and my training,
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`education, research, knowledge, and personal and professional experience. All of
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`my opinions stated in this declaration are based on my own personal knowledge,
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`expertise, training, education, and professional judgment. In forming my opinions,
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`I have relied on my knowledge and experience in human factors, user interface
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`design, user interaction design, human-computer interaction, and software
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`engineering.
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`5.
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`If I am called upon to do so, I would be competent to testify to the
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`matters set forth herein. My qualifications to testify about the technical subject
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`matter in this case and the relevant technology are outlined in my curriculum vitae
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`and this section of this declaration. A copy of my current curriculum vitae is
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`provided for this proceeding as Exhibit 2002.
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`6.
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`This declaration is based on the information currently available to me.
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`If additional information becomes available to me, I reserve the right to continue my
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`analysis, which may include a review of documents and information that may be
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`provided to me, as well as testimony from depositions that have not yet been taken
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`at this time.
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`I.
`
`BACKGROUND AND QUALIFICATIONS
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`7.
`
`I earned my Bachelor of Science degree in Industrial Engineering, my
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`Master of Science degree in Human Factors, and a Doctor of Philosophy in Human
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`Factors from the University of Washington School of Engineering. For over 30
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`years, I have worked in human factors, user interface design, software development,
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`software architecture, systems engineering, and modeling and simulation across
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`various application areas, including aerospace, communications, entertainment, and
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`healthcare.
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`8.
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`I graduated from the University of Washington in 1988 with a Bachelor
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`of Science in Industrial Engineering. After graduation, I continued my studies at the
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`University of Washington College of Engineering. In 1990, I obtained a Master of
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`Science degree in Human Factors. Human Factors is an engineering discipline that
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`studies the design of products, processes, equipment, and systems to work more
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`efficiently with humans. Human factors is concerned with reducing human error,
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`increasing productivity and efficiency, and enhancing safety and comfort with a
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`specific focus on the interactions and interfaces between humans and the products,
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`processes, or systems with which they interact. In 1994, I graduated with a Doctor
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`of Philosophy in Human Factors, focusing on advanced interface design. My
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`Bachelor of Science, Master of Science, and Doctor of Philosophy degrees were all
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`obtained at the University of Washington College of Engineering.
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`9.
`
`During my doctoral studies, I worked as an Associate Assistant Human
`
`Factors Professor at the University of Washington Industrial Engineering
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`Department. My duties included teaching, writing research proposals, designing and
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`conducting funded human factors experiments for the National Science Foundation,
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`and hiring and supervising students. While studying at the University of
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`Washington, I also worked as a human factors researcher. I designed and performed
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`advanced human factors experiments relating to virtual environments and interface
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`design, stereoscopic displays, and advanced visualization research, which the
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`National Science Foundation funded. My duties included user interface design,
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`systems design, software development, graphics programming, experimental design,
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`and hardware and software interfacing.
`
`10.
`
`I have published twenty-one research papers in professional journals
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`and proceedings in user interface design, computer graphics, and the design of
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`spatial, stereographic, and auditory displays. I also authored a book chapter on
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`augmented reality displays in the book “Virtual Environments and Advanced
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`Interface Design” (Oxford University Press, 1995). In addition, I created one of the
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`first virtual spatial musical instruments called the MIDIBIRD that, utilized the MIDI
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`protocol, two six-dimensional spatial trackers, a music synthesizer, and a computer
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`graphics workstation to create an advanced and novel musical instrument.
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`11. For the past 21 years, I have been a consultant for Global Technica,
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`Sunny Day Software, Stanley Associates, Techrizon, CDI Corporation, and the Barr
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`Group. In this capacity, I have provided advanced engineering services for many
`
`companies.
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`12.
`
`I consulted for the Boeing Company for 15 years as a senior human
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`factors engineer, user interface designer, and software architect for various advanced
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`commercial and military programs. Many of the projects that I was involved with
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`at Boeing involved advanced software development, user interface design, agent-
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`based software, and modeling and simulations in the areas of missile defense,
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`homeland security, battle command management, computer-aided design,
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`networking and communications, air traffic control, location-based services, flight
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`simulation, and Unmanned Aerial Vehicle (“UAV”) command and control.
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`Additionally, I was the lead system architect developing advanced air traffic
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`controller workstations and air traffic control analysis applications, toolsets, and
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`trade study simulations for Boeing Air Traffic Management.
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`13.
`
`I was also the architect of the Boeing Human Agent Model. The Boeing
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`Human Agent Model is an advanced model for the simulation of human sensory,
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`cognitive, and motor performance as applied to the roles of air traffic controllers,
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`pilots, and UAV operators. In another project, I was the lead human factors engineer
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`and user interface designer for Boeing’s primary vector and raster computer-aided
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`drafting and editing system that produces the maintenance manuals, shop floor
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`illustrations, and service bulletins for aircraft produced by the Boeing Commercial
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`Aircraft Company. Additional responsibilities in my time as a consultant include
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`system engineering, requirements analysis, functional specification, use case
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`development, user stories, application prototyping, modeling and simulation, object-
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`oriented software architecture, graphical user interface analysis, and design, as well
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`as UML, C++, C#, and Java software development.
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`14.
`
`In 1995 and 1996, I was hired as the lead human factors engineer and
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`user interface designer for the first two-way pager produced by AT&T. Before this
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`technology, individuals could receive pages but had no way to respond utilizing their
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`pager. This new technology allowed users to use a small handheld device to receive
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`and send canned or custom text messages, access and update an address book, and
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`access and update a personal calendar. This high-profile project involved designing
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`the entire feature set, user interface/user interaction design and specification, and all
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`graphical design standards. In addition, I designed the notification alerts for the
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`pager associated with receiving messages, timers, alarms, etc.
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`15. From 1999 to 2001, I was the lead human factors engineer and user
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`interface designer for a company called Eyematic Interfaces, where I was
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`responsible for all user interface design and development activities associated with
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`real-time mobile handheld 3D facial tracking, animation, avatar creation, and editing
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`software for a product for Mattel. My work involved user interface design, human
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`factors analysis, requirements gathering and analysis, and functional specifications.
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`16.
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`I was the lead user interface designer for a company called
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`ObjectSpeed, which developed a portable handheld telephone for use in homes and
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`businesses with many of the same capabilities we take for granted in mobile cellular
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`phones. This portable multifunction device supports voice, email, chat, video
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`conferencing, internet radio, streaming media, Microsoft Outlook integration, photo
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`taking, sharing, notifications, etc. I designed all the user interface elements for this
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`device. The ObjectSpeed device was specifically designed and developed as a
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`portable handheld device.
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`17.
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`I was the lead user interface designer for Ahaza, which was building
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`IPv6 routers. I designed the user interfaces to configure and control these advanced
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`network hardware devices. My responsibilities included requirements analysis,
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`functional specification, user interface design, user experience design, and human
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`factors analysis.
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`18.
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`I am the founder, inventor, user interface designer, and software
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`architect of WhereWuz. WhereWuz is a company that produces advanced mobile
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`software running on GPS-enabled smartphones and handheld devices. WhereWuz
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`allows users to record exactly where they have been and query this data for
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`subsequent retrieval based on time or location. WhereWuz was designed and
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`developed to run on handheld devices.
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`19.
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`I am the co-founder of a medical technology company called Healium.
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`Healium developed advanced wearable and handheld user interface technology to
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`allow physicians to interact more effectively with electronic medical records.
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`20.
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`I am the co-founder of StratoScientific, a medical technology company
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`that is developing innovative technologies that turns a standard handheld smartphone
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`into a full-featured digital stethoscope, incorporating visualization and machine
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`learning for telemedicine.
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`21.
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`I designed and developed a large software project for Disney World
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`called xVR that allowed the operational employees of Disney World to utilize a
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`handheld device to view the current and historical status of all of the guests of Disney
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`World within multiple attractions and one of their restaurants. The application could
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`run in a real-time/live mode where it would display data collected from sensors that
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`showed the location and status of all guests within the attraction; the application
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`could also be run in a fast-time/simulated mode. The application was developed on
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`a laptop computer and designed to run on various devices, including laptops,
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`personal computers, smartphones, and tablets. In addition, I investigated the use of
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`notifications for MagicBand.
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`22.
`
`I have worked on multiple user interface projects involving haptics for
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`AT&T, Boeing, Disney, and ObjectSpeed. For AT&T, I designed and developed
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`the entire user interface for AT&T’s first two-way pager, including vibratory alerts
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`associated with new messages. For Boeing, I worked on improving the realism of
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`flight simulators, including the fidelity of vibratory alerts associated with their stick
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`shakers. For Disney, I investigated the use of vibrotactile alerting for MagicBand
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`users. For ObjectSpeed, I designed the vibratory alerting associated with
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`notifications.
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`23.
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`I have worked on many projects that utilized touchscreen interfaces,
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`including projects for ObjectSpeed, WhereWuz, Disney, US ARMY, Healium, and
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`StratoScientific.
`
`24.
`
`I have received several awards for my engineering work relating to
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`interface design, computer graphics, and the design of spatial, stereographic, and
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`auditory displays, including a $10,000 scholarship from the I/ITSEC for advancing
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`the field of interactive computer graphics for flight simulation and a Link Foundation
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`award for furthering the field of flight simulation and virtual interface design. I have
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`also created computer graphic illustrations for several popular book covers and
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`animations for a movie produced by MIRAMAR.
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`25. My curriculum vitae, Exhibit 2002 provides more information about
`
`my educational and professional background.
`
`26. The combination of my education, research, training, and work
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`experience in software development, human factors, user interface design, user
`
`interaction design, and human-computer interaction enables me to provide analysis
`
`and opinions on the subject matter of this litigation.
`
`II. BASES OF OPINIONS
`
`27.
`
`In the course of performing my analysis and forming my opinions, I
`
`have reviewed the Petition and its Exhibits 1001–1008 including the materials listed
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`below and the materials I cite within this declaration:
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` IPR Petition IPR2024-00556
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` U.S. Patent No. 8,749,507 (“the ’507 Patent”) (Ex. 1001)
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` Prosecution History of the ’507 Patent. (Ex. 1002)
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` Declaration of Jean R. Ward (Ex. 1003)
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` US Patent No. 6,590,569 (“Astala”) (Ex. 1005)
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` U.S. Patent Pub. No. 2002/0033795 (“Shahoian”) (Ex. 1006)
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` U.S. Patent Pub. No. 2002/0057263 (“Keely”) (Ex. 1007)
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` U.S. Patent No. 7,256,773 (“Kolmykov-Zotov”) (Ex. 1008)
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`III. SUMMARY OF OPINIONS
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`28. The Petition raises three grounds of invalidity. Ground 1 of the Petition
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`alleges that claims 1-18 are rendered obvious by Astala (Ex. 1005) in combination
`
`with Shahoian (Ex. 1006). Ground 2 alleges that claims 1, 6-9, 13-14 and 18 are
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`rendered obvious by Keely (Ex. 1007) in combination with Kolmykov-Zotov (Ex.
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`1008). Ground 3 alleges that claims 2-5, 10-12, and 15-17 are rendered obvious by
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`Keely (Ex. 1007) in combination with Kolmykov-Zotov (Ex. 1008) and Shahoian
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`(Ex. 1006).
`
`29. Based on my analysis of the Petition and the exhibits cited in the
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`Petition, it is my opinion that none of Grounds 1 to 3 render claims 1-18 of the ’507
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`patent anticipated or obvious.
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`IV. APPLICABLE LEGAL STANDARDS
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`A. Ordinary Skill in the Art
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`30. My opinions in this declaration are based on the understandings of a
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`person of ordinary skill in the art—sometimes referred to as an “ordinary artisan” or
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`by the acronyms “POSITA” or “POSA” (person of ordinary skill in the art)—as of
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`the time of the invention, which I understand to be the earliest priority date
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`(November 26, 2003) of the ’507 Patent. I understand that the person of ordinary
`
`skill in the art is a hypothetical person who is presumed to have known the art
`
`relevant to the challenged claims of the ’507 Patent at the time of the invention.
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`31.
`
`I understand that, in assessing the level of skill of a person of ordinary
`
`skill in the art, one should consider the type of problems encountered in the art, the
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`prior solutions to those problems found in the prior art references, the rapidity with
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`which innovations are made, the sophistication of the technology, the level of
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`education of active workers in the field, and my own experience working with those
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`of skill in the art at the time of the invention. I have considered these factors in
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`reaching my opinion as to the hypothetical POSITA that I set forth below.
`
`32.
`
`I understand that the Petitioner has proposed that the level of skill in the
`
`art at the time of the ’507 patent is as follows:
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`A person of ordinary skill in the art (“POSA”) on November 26,
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`2003 would have a bachelor’s degree in electrical engineering,
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`computer science, or a related field, plus at least two years of
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`industry or graduate
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`level experience with software
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`engineering, haptics programming, and/or human-computer
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`interaction, including experience with user-interfaces and
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`applications involving touchscreens, touchpads, and related
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`technologies.
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`Pet. at 7 (citing EX1003, ¶¶ 47-51).
`
`33.
`
`In my opinion, the definition of a POSA should be defined as:
`
`A person of ordinary skill in the art would have possessed a
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`bachelor’s degree in electrical engineering or computer science
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`(or an equivalent degree), and two years of practical or industry
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`experience in the field of human-computer interaction,
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`including implementation of computer-based systems and
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`software for providing haptic feedback effects to a user. A
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`person could also have qualified as an ordinarily skilled artisan
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`with more formal education and less practical or industry
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`experience, or vice versa.
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`34. Consistent with either definition, I was at the time of invention, and am,
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`a POSA through my education, research experience and work experience. As of the
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`date of the invention, I was familiar with the types of problems encountered in
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`systems that use haptic feedback and the rapidity at which innovations are made.
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`B. Claim Construction
`
`35.
`
`I understand that Petitioner believes the Board’s construction of the
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`term “determining a press if: the pressure is greater than a pressure threshold, the
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`change in pressure is greater than a change in pressure threshold, and a first interval
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`has elapsed” was wrong. More specifically, Petitioner does not believe that the
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`pressure conditions must “be maintained for the duration of the first interval.” Pet.
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`at 8. For the opinions and analysis I provide below, resolution of this particular
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`question is not necessary. My analysis does not depend on a particular interpretation
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`of when pressure thresholds are met in relation to a time interval and therefore I have
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`not provided any opinions relating to a specific construction of this term.
`
`36.
`
`I understand that in interpreting the claims of the ’507 Patent in this IPR
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`according to their plain and ordinary meaning, one must take into consideration the
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`so-called “intrinsic evidence” of the patent consisting of (1) the claim language; (2)
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`the specification; and (3) the prosecution history.
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`37.
`
`I understand that claim terms may be explicitly defined in the patent
`
`specification or they may be implicitly defined through consistent usage in the
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`specification. I also understand that the scope of claim terms may be limited by
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`statements in the specification or prosecution history where the applicant
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`unambiguously disavows or disclaims subject matter.
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`C. Anticipation
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`38. Counsel has informed me, and I understand, that a showing of
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`anticipation involves a comparison of the construed claims to the alleged prior art
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`and, to anticipate a patent claim, a single prior art reference must disclose each
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`element of the claimed invention, either expressly or inherently. The prior art
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`reference must also have disclosed each element prior to disclosure of the claimed
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`invention.
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`39. Further, a party claiming inherency must prove that the alleged inherent
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`element or feature necessarily is present by clear and convincing evidence. The fact
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`that the feature is likely to have existed is not sufficient. It must be shown that the
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`feature was necessarily present in the reference to show inherency.
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`D. Obviousness
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`40. Counsel has informed me, and I understand, that an issued patent claim
`
`is invalid as obvious if it can be shown that the differences between the patented
`
`subject matter and the prior art are such that the subject matter as a whole would
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`have been obvious, at the time the invention was made, to a person having ordinary
`
`skill in the art. Relevant considerations include the level of ordinary skill in the art;
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`the scope and content of the prior art; differences between the prior art and the claims
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`at issue; and the objective indicia, or secondary considerations, of non-obviousness.
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`41.
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`In this regard, I am informed and I understand that the secondary
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`considerations of non-obviousness could include factors such as commercial
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`success, long felt but unresolved needs, the failure of others, skepticism by experts,
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`praise by others, award and accolades, and copying.
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`42. Counsel has informed me, and I understand, that in order to evaluate
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`the obviousness of any claim of the ’507 Patent over a given prior art combination,
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`I should analyze whether the prior art references, included collectively in the
`
`combination, disclose each and every element of the allegedly invalid claim as those
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`references are read by the person of ordinary skill in the art at the time of the
`
`invention.
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`43. Counsel has informed me, and I understand, that even where all of the
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`claim limitations are expressly disclosed in the prior art references, there must be
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`some showing that a person of ordinary skill in the art would have been motivated
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`to combine such prior art references, and explanation of how the combination would
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`be achieved, and that there would have been a reasonable expectation of successfully
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`achieving the claimed invention from such combination.
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`44. Counsel has informed me, and I understand, that absent some additional
`
`reasoning, mere routine optimization for a person of ordinary skill in the art to arrive
`
`at the claimed invention through the combination of prior art references is
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`insufficient to support a conclusion of obviousness.
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`45. Counsel has informed me, and I understand, that to rely on a reference
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`it must be analogous prior art. Counsel has informed me and I understand that a
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`reference is considered analogous prior art: (1) if the reference is from the same field
`
`of endeavor as the claimed subject matter, or (2) if the reference “is reasonably
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`pertinent to the particular problem with which the inventor is involved,” even though
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`the reference is not within the field of the inventor’s endeavor.
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`46. Counsel has informed me, and I understand in considering the
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`obviousness of a claimed invention, one should not view the invention and the prior
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`art with the benefit of hindsight. In an obviousness analysis, one must be aware of
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`the distortion caused by hindsight bias and must be cautious of arguments reliant
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`upon ex post reasoning. Counsel has instructed me, and I understand that when
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`considering obviousness, I should not consider what is known today or what was
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`learned from the invention of the ’507 patent itself. Instead, obviousness is assessed
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`by the person of ordinary skill in the art at the time the invention of the ’507 Patent
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`was made, but without the knowledge of the invention.
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`47.
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`In this regard, I am informed and I understand that the ’507 Patent may
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`not be used as a guide or roadmap to select, understand, and combine or modify the
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`prior art because such an approach would improperly apply hindsight bias to the
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`obviousness analysis. Also, at a minimum, this approach discounts the value of
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`combining various existing features or principles in the prior art in an inventive way
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`so as to achieve a novel result.
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`48. Counsel has informed me, and I understand, that obviousness cannot be
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`predicated on what was unknown at the time of the invention, even if the inherency
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`of a certain feature is later established. Counsel has also informed me, and I
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`IPR2024-00556
`Immersion Exhibit 2001
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`understand, that unknown or undisclosed properties of the prior art (such as features
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`in the prior art that the obviousness combination or rationale to combine might rely
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`on, but are not disclosed or taught by the reference) may not be relied upon to provide
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`the rationale for modifying or combining the prior art to reach the claimed subject
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`matter.
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`49. Counsel has informed me, and I understand, that a reference may be
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`said to teach away when a person of ordinary skill, upon reading the reference, would
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`be discouraged from following the path set out in the reference or would be led in a
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`direction divergent from the path that was taken by the applicant of the ’507 Patent.
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`V. OVERVIEW OF THE ’507 PATENT
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`50. The ’507 Patent, filed on April 6, 2012, claims priority to an application
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`from November 26, 2003. It describes techniques for accurately sensing a user’s
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`intended input on standard touchpad and touchscreen devices. Unlike other input
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`devices like mice, which primarily respond to movement or button presses, both
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`changes in position and pressure on the touchpad are necessary to discern the user's
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`intent. This is described in Ex. 1001 at 1:46-55. According to the ’507 Patent, “a
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`conventional mouse includes a ball or optical sensor for determining changes in
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`position of the mouse, The mouse also includes one or more buttons for performing
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`a control function, such as selecting a graphical representation on a screen. In these
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`systems, a user’s intent to make a position change or provide control input is
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`apparent to the system. In contrast, conventional touchpads combine the position
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`and control functionality in a way that often masks a user’s intent to make a
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`positional change or control input . . . Changes in position on the touchpad and in
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`the pressure exerted on the surface of the touchpad must be used to determine the
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`user’s intent.” Ex. 1001 at 1:39-55. This often results in misinterpretations between
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`intentional touches and accidental contact, as noted in Ex. 1001 at 1:55-60.
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`51. The limitations of conventional touch devices arise from their method
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`of input detection. As described in the ‘507 Patent, “[t]ouchpads work by utilizing
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`resistance, capacitance, or membrane switches.” Ex. 1001 at 2:55-56. These sensing
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`methods do not directly measure pressure but instead provide what the ’507 Patent
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`refers to as “pseudo pressure.” Ex. 1001 at 2:54-55. This “pseudo pressure” does not
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`necessarily represent the amount of force actually exerted on the touch-sensitive
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`input device (Ex. 1001 at 3:19-21) because variations in the size of users’ fingers or
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`the manner in which they press on the device can alter the readings. Ex. 1001 at
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`3:40-42 and 3:28-31. “The larger the surface of the conductor used on the touchpad
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`102, e.g., a user’s finger, the larger the change in capacitance per amount of pressure
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`exerted.” Ex. 1001 at 3:22-24. Additionally, “[i]f a user presses heavily against the
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`touchpad 102 with a fleshy part of the finger, the amount of the touchpad 102
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`covered by the finger is greater than when the same part of the finger is touching
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`lightly.” Ex. 1001 at 3:24-28. “[P]seudo pressure, is also greater when the user
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`presses heavily with a bony part of a finger.” Ex. 1001 at 3:28-31.
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`52. The ’507 Patent describes a number of factors that affect pseudo
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`pressure measurements:
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`Variables affecting the ability of a program to determine what a
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`user is attempting to do include the following: the physical
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`difference between users; the different angles at which a user may
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`place their finger while using a touchpad; the variance in pressure
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`between different users and between the same user; the movement
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`of the finger across the touchpad while simultaneously attempting
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`to perform actions on the touchpad.
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`Ex. 1001 at 1:58-65.
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`53. The ’507 Patent proposes solutions to the problem of determining
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`intended touches versus accidental or incidental contact with the surface of the
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`touch-sensitive input device. Ex. 1001 at 4:56-63. According to the ’507 Patent,
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`determining whether a user intended a press includes determining whether the
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`pressure associated with the press exceeds a pressure threshold, whether the change
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`in pressure exceeds a change in pressure threshold, and whether a time interval has
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`elapsed. E.g., Ex. 1001 at 10:31-42.
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`54. The ’507 Patent describes these various thresholds as adaptable to
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`compensate for the different ways different users may touch the device. Ex. 1001 at
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`5:44-48. Some example adaptable thresholds include: “thresholds for pressure,
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`IPR2024-00556
`Immersion Exhibit 2001
`Page 21 of 40
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