UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`MIDLAND-ODESSA DIVISION
`
`RESONANT SYSTEMS, INC., d/b/a
`RevelHMI,
`
`v.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendants.
`
`Case No. 7:23-cv-000077-DC
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S IDENTIFICATION OF PROPOSED CONSTRUCTIONS
`Plaintiff Resonant Systems, Inc. (“Plaintiff” or “Resonant”) hereby provides the following
`disclosure of proposed constructions for the claim terms identified by Defendant Apple Inc.
`(“Defendant” or “Apple”) for construction. Plaintiff’s disclosure is based on currently available
`information, and Plaintiff reserves the right to modify this disclosure should additional information
`become available through discovery. Plaintiff further reserves the right to modify this disclosure
`once it has reviewed Defendant’s proposed constructions.
`
`No.
`1
`
`Term
`Preambles: “linear resonant vibration
`module”; “linear vibration module”;
`“vibration module”; “oscillating
`resonant module[s]”
`
`2
`
`“control component . . .”
`
`Proposed Construction
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`
`Claim(s)
`’767 patent,
`claim 1; ’337
`patent, claims
`1, 2, 4; ’830
`patent, claims
`1, 19, 20; ’882
`patent, claims
`1, 10
`’767 patent,
`claims 1, 3, 5;
`’337 patent,
`claims 1, 2, 4;
`’830 patent,
`
`APPLE 1033
`
`1
`
`

`

`Claim(s)
`claims 1–6, 15,
`17, 19, 20;
`’882 patent,
`claims 1, 3–7,
`10
`’767 patent,
`claim 1
`
`Proposed Construction
`
`No construction necessary;
`plain and ordinary meaning
`
`No.
`
`Term
`
`3
`
`“a control component that includes a
`microprocessor and that controls
`supply of power from the power
`supply to the driving component to
`cause the moveable component to
`linearly oscillate, the control
`component including, in addition to
`the microprocessor,
`
`a control program, stored in one
`of a separated electronic memory
`or within the processor, that is
`executed by the microprocessor
`to control operation of the linear
`resonant vibration module, and
`
`a switch that receives a
`directional signal d from the
`processor and that selects a
`corresponding direction of the
`two opposite directions in which
`the driving component drives the
`moveable component,
`
`the control component receiving
`output signals from sensors within
`the linear resonant vibration module
`during operation of the linear
`resonant vibration module and
`adjusting one or more operational
`control outputs of the control
`component according to the received
`output signals from the sensors in
`order that subsequent operation of
`linear resonant vibration module
`produces desired outputs from the
`one or more sensors corresponding
`to one or more operational control
`parameters”
`
`2
`
`

`

`Claim(s)
`’337 patent,
`claims 1, 2, 4
`
`Proposed Construction
`No construction necessary;
`plain and ordinary meaning
`
`’830 patent,
`claims 1, 19,
`20
`
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`
`No.
`4
`
`5
`
`6
`
`Term
`“a control component that controls
`supply of power from the power
`supply to the driving component to
`cause the moveable component to
`oscillate at a frequency and an
`amplitude [that are independently]
`specified by user input received from
`the user-input features
`
`the control component
`[wherein
`drives simultaneous oscillation of the
`moveable component at two or more
`frequencies
`to generate complex
`vibration modes.]”
`“a control component that controls
`supply of power from the power
`supply to the driving component to
`cause the moveable component to
`oscillate at a frequency and an
`amplitude specified by one or more
`stored values
`
`[wherein the control component drives
`simultaneous oscillation of the
`moveable component at two or more
`frequencies to generate complex
`vibration modes.]”
`“a control component that
`
`receives control signals input to
`the oscillating resonant module
`[by the controller],
`
`receives outputs from the one or
`more sensors, and
`
`controls oscillation of the mass to
`produce a vibration response
`according to the received control
`signals by generating, using one or
`more of the received sensor
`outputs, control outputs to an
`actuator that drives the mass to
`oscillate”
`
`3
`
`

`

`No.
`7
`
`Term
`“driving component . . .”
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`“a driving component that drives the
`moveable component in each of two
`opposite directions”
`“a driving component that drives the
`moveable component in each of two
`opposite directions within the housing”
`“a driving component that drives the
`moveable component to oscillate
`within the housing”
`“an oscillation path, which represents a
`segment of a space curve”
`“the one or more sensors”
`
`“the d”
`
`“desired outputs”
`
`“the one or more operational control
`outputs”
`“the received output signals”
`
`“the sensors”
`
`“the mass”
`
`“the oscillating resonant module[s]” /
`“the one or more oscillating resonant
`module[s]”
`“the physical device”
`
`“is are” (or all of claim 7)
`
`“claim 1”
`
`Claim(s)
`’767 patent,
`claim 1; ’337
`patent, claims
`1, 2, 4; ’830
`patent, claims
`1, 19, 20
`’767 patent,
`claim 1
`
`Proposed Construction
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`
`’337 patent,
`claims 1, 2, 4
`
`No construction necessary;
`plain and ordinary meaning
`
`’830 patent,
`claims 1, 19,
`20
`’882 patent,
`claims 1, 10
`’767 patent,
`claim 1;
`’830 patent,
`claim 4
`’767 patent,
`claim 2
`’767 patent,
`claim 1;
`’830 patent,
`claim 4
`’830 patent,
`claim 4
`’830 patent,
`claim 4
`’830 patent,
`claim 4
`’882 patent,
`claims 1, 3–7,
`10
`’882 patent,
`claims 10, 17,
`19, 20
`’882 patent,
`claim 17
`’882 patent,
`claim 7
`’830 patent,
`claim 4
`
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`No construction necessary;
`plain and ordinary meaning
`No construction necessary;
`plain and ordinary meaning
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`
`No construction necessary;
`plain and ordinary meaning
`“are”
`
`“claim 3”
`
`4
`
`

`

`No.
`23
`
`“claim 1”
`
`Term
`
`Claim(s)
`’882 patent,
`claim 17
`
`Proposed Construction
`“claim 10”
`
`Dated: February 15, 2024
`
`Respectfully submitted,
`
`/s/ Reza Mirzaie
`
`Reza Mirzaie
`Paul Kroeger
`Kristopher Davis
`Christian Conkle
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard 12th Floor
`Los Angeles, California 90025
`
`Peter Tong
`RUSS AUGUST & KABAT
`4925 Greenville Avenue, Suite 200
`Dallas, Texas 75206
`
`Tel: 310-826-7474
`Fax: 310-826-6991
`rak_revelhmi@raklaw.com
`
`Attorneys for Plaintiff Resonant Systems Inc.,
`d/b/a RevelHMI
`
`5
`
`

`

`CERTIFICATE OF SERVICE
`I certify that this document is being served upon counsel of record for Defendant on
`February 15, 2024 via electronic service.
`
`/s/ Reza Mirzaie
`
`6
`
`