1
`
`
`
`the claim limitations below.
`(“Taptic Engine”), haptic controller(s), and associated circuitry, as described in connection with
`For example, each of the Apple iPhone 14 and the Apple Watch Ultra contain a linear actuator
`
`See, e.g.:
`
`module.
`To the extent the preamble is limiting, each Accused Product includes or constitutes a vibration
`
`comprising:
`[1pre]. A vibration module
`
`Accused Products
`
`Claim 1
`
`Claim 1
`
`any, particular claim limitations it believes are not met by the Accused Products.
`substantially the same way, to achieve the same result as the claimed invention. Notably, Defendant has not yet articulated which, if
`limitation and each Accused Product would be insubstantial, and each Accused Product performs substantially the same function, in
`claim limitation is not met literally, it is nonetheless met under the doctrine of equivalents because the differences between the claim
`applicable to each Accused Product. Each claim limitation is literally infringed by each Accused Product. However, to the extent any
`
`Each Accused Product infringes the claims in substantially the same way, and the evidence shown in this chart is similarly
`
`thereof (collectively, “Accused Products”), infringe at least Claims 1, 2, 3, 4, 5, 6, 7, 8, 14, 15, 16, 17, 19, and 20 of the ’830 Patent.
`3, Series 4, Series 5, SE, Series 6, Series 7, SE (second generation), Series 8, Ultra, Series 9, Ultra 2), and all variants and iterations
`Pro from 2015, MacBook from 2018, MacBook Air from 2018) and Apple Watch products (1st generation, Series 1, Series 2, Series
`13 Pro Max, SE (third generation), 14, 14 Plus, 14 Pro, 14 Pro Max, 15, 15 Plus, 15 Pro, 15 Pro Max), MacBook products (MacBook
`8 Plus, X, XR, XS, XS Max, 11, 11 Pro, 11 Pro Max, SE (second generation), 12, 12 mini, 12 Pro, 12 Pro Max, 13, 13 mini, 13 Pro,
`
`Apple products with Taptic Engine technology,, including without limitation iPhone products (iPhone 6s, 6s Plus, 7, 7 Plus, 8,
`
`Accused Instrumentalities
`
`U.S. Patent No. 9,941,830 (“’830 Patent”)
`
`APPLE 1044
`
`1
`
`

`

`2
`
`
`
`Engine at bottom left.
`Photograph of iPhone 14 with rear cover removed, with A15 Bionic SoC at center right and Taptic
`
`
`
`2
`
`

`

`3
`
`
`
`Photograph of Taptic Engine housing from the iPhone 14.
`
`
`
`Photograph of Taptic Engine housing from the iPhone 14.
`
`
`
`Accused Products
`
`Claim 1
`
`3
`
`

`

`4
`
`
`
`Photograph of Hall sensor controller and motor control driver from the iPhone 14.
`
`
`
`Accused Products
`
`Claim 1
`
`4
`
`

`

`5
`
`
`
`https://developer.apple.com/accessories/Accessory-Design-Guidelines.pdf
`Accessory Design Guidelines for Apple Devices, Release R20, available at
`
`
`
`Accused Products
`
`Claim 1
`
`5
`
`

`

`6
`
`
`
`
`
`Photograph of Apple Watch Ultra.
`
`Accused Products
`
`Claim 1
`
`6
`
`

`

`7
`
`
`
`cavity that is soldered together to form a housing surrounding the moveable component and coils.
`For example, the Taptic Engine in each of the iPhone 14 and Apple Watch Ultra has a hollow
`
`See, e.g.:
`
`system board.
`Annotated photographs of Apple Watch Ultra showing linear actuator (Taptic engine) and main
`
`
`
`Each Accused Product comprises a housing.
`
`[1a] a housing;
`
`Accused Products
`
`Claim 1
`
`
`
`7
`
`

`

`8
`
`
`
`Photograph of Taptic Engine housing from the iPhone 14.
`
`
`
`Photograph of Taptic Engine housing from the iPhone 14.
`
`
`
`Accused Products
`
`Claim 1
`
`8
`
`

`

`9
`
`
`
`movable component comprising permanent magnet(s) and a mass.
`For example, the Taptic Engine in each of the iPhone 14 and Apple Watch Ultra includes a
`
`See, e.g.:
`
`Each Accused Product comprises a moveable component.
`
`[1b] a moveable component;
`
`
`
`Photograph of Taptic Engine housing from Apple Watch Ultra.
`
`Accused Products
`
`Claim 1
`
`9
`
`

`

`10
`
`
`
`
`
`Photograph of moveable component from Apple Watch Ultra.
`
`14.
`Photograph of moveable component (at right, connected to housing with springs) from the iPhone
`
`
`
`Accused Products
`
`Claim 1
`
`10
`
`

`

`11
`
`
`
`system board.
`Watch Ultra receives power from one or more voltage regulators on or near the Accused Product’s
`For example, the linear motor coil driver (described below) in each of the iPhone 14 and Apple
`
`See, e.g.:
`
`Each Accused Product comprises a power supply.
`
`[1c] a power supply;
`
`Accused Products
`
`Claim 1
`
`11
`
`

`

`12
`
`
`
`Photograph of iPhone 14 system board.
`
`
`
`Accused Products
`
`Claim 1
`
`12
`
`

`

`13
`
`
`
`
`
`X-ray image of Apple Watch Ultra system board.
`
`Accused Products
`
`Claim 1
`
`13
`
`

`

`14
`
`
`
`other user-input features.
`For example, each of the iPhone 14 and Apple Watch Ultra comprises a touchscreen, buttons, and
`
`See, e.g.:
`
`Each Accused Product comprises user-input features.
`
`[1d] user-input features;
`
`Accused Products
`
`Claim 1
`
`See also claim elements below.
`
`14
`
`

`

`15
`
`
`
`https://www.apple.com/iphone-14/.
`Photograph of iPhone 14 touchscreen, buttons, and switch, available at
`
`
`
`Accused Products
`
`Claim 1
`
`15
`
`

`

`16
`
`
`
`driving the moveable component in two directions.
`For example, the Taptic Engine includes one or more coils to form electromagnetic fields for
`
`oscillate within the housing.
`Each Accused Product includes a driving component that drives the moveable component to
`
`the housing; and
`component to oscillate within
`drives the moveable
`[1e] a driving component that
`
`Photograph of Apple Watch Ultra touchscreen, dial, and buttons.
`
`
`
`Accused Products
`
`Claim 1
`
`16
`
`

`

`17
`
`
`
`visible coils would be positioned above and below the moveable component when assembled.
`Photograph of driving coils within disassembled Taptic Engine from the iPhone 14. The two
`
`
`
`Accused Products
`
`Claim 1
`
`See, e.g.:
`
`17
`
`

`

`18
`
`
`
`down from this perspective.
`iPhone 14, with moveable component in place at left. The moveable component travels up and
`Photograph showing one driving coil (at right) within disassembled Taptic Engine from the
`
`
`
`Accused Products
`
`Claim 1
`
`18
`
`

`

`19
`
`
`
`from this perspective.
`bottom) surrounding the moveable component. The moveable component travels left and right
`Photograph of internals of Taptic Engine from the iPhone 14, showing drive coils (top and
`
`
`
`Accused Products
`
`Claim 1
`
`19
`
`

`

`20
`
`
`
`visible coils would be positioned above and below the movable component when assembled.
`Photograph of drive coils within disassembled Taptic Engine from Apple Watch Ultra. The two
`
`
`
`Accused Products
`
`Claim 1
`
`20
`
`

`

`21
`
`
`
`See, e.g.:
`
`stored values specifying frequency and/or amplitude.
`information and belief, the system processor and/or linear motor control driver include additional
`stored at least within the system processor and associated volatile and non-volatile memory. On
`that directly and/or indirectly control the frequency and amplitude of the oscillation and that are
`proprietary Apple APIs and interfaces, specify intensity and sharpness (exemplary stored values)
`amplitude, as demonstrated by public APIs and by testing. The public APIs, as well as any
`below. This control component can drive the moveable component at specified frequencies and
`to drive the coils and thus move the magnetic mass in a linear oscillating motion, as described
`and a Hall sensor controller, which alone or in combination form a control component as claimed
`For example, each Accused Product includes a main system processor, a linear motor coil driver,
`
`frequency and an amplitude specified by one or more stored values.
`power supply to the driving component to cause the moveable component to oscillate at a
`Each Accused Product comprises a control component that controls supply of power from the
`
`Accused Products
`
`more stored values.
`amplitude specified by one or
`oscillate at a frequency and an
`moveable component to
`component to cause the
`the power supply to the driving
`controls supply of power from
`[1f] a control component that
`
`Claim 1
`
`21
`
`

`

`22
`
`
`
`Photographs showing iPhone 14 system board with A15 Bionic processor.
`
`
`
`System processor
`
`Accused Products
`
`Claim 1
`
`22
`
`

`

`23
`
`
`
`Annotated photograph of Hall sensor controller and motor coil driver from the iPhone 14.
`
`
`
`Accused Products
`
`Claim 1
`
`23
`
`

`

`24
`
`
`
`X-ray image of Apple Watch Ultra system board.
`
`
`
`Accused Products
`
`Claim 1
`
`24
`
`

`

`25
`
`
`
`connection points for haptic motor.
`Annotated photograph of partially disassembled Apple Watch Ultra system board, showing
`
`
`
`Accused Products
`
`Claim 1
`
`25
`
`

`

`26
`
`
`
`https://developer.apple.com/documentation/corehaptics/chhapticevent
`Documentation of CHHapticEvent object,
`
`
`
`Accused Products
`
`Claim 1
`
`26
`
`

`

`27
`
`
`
`https://developer.apple.com/documentation/corehaptics/chhapticevent/parameterid;
`Documentation of haptic event parameters,
`
`
`
`Accused Products
`
`Claim 1
`
`27
`
`

`

`28
`
`
`
`9219fdebdcaa.
`https://medium.com/lofelt/10-things-you-should-know-about-designing-for-apple-core-haptics-
`
`
`
`Accused Products
`
`Claim 1
`
`28
`
`

`

`29
`
`
`
`negative coil driving pins.
`Annotated photograph of Taptic Engine connector from the iPhone 14 showing positive and
`
`
`
`Accused Products
`
`Claim 1
`
`29
`
`

`

`30
`
`
`
`14.
`Photographs of test apparatus with electrical leads connected to motor coil drive traces of iPhone
`
`
`
`Accused Products
`
`Claim 1
`
`30
`
`

`

`31
`
`
`
`at top right with R = 220 Ω, C = 2.2 uF.
`actual motion (from attached vibration transducer) of iPhone 14. Note RC low-pass filter networks
`Photograph of test apparatus for measuring motor coil drive signal (from tapped connection) and
`
`
`
`Accused Products
`
`Claim 1
`
`31
`
`

`

`32
`
`
`
`kHz) to drive the moveable component in one of two directions.
`controller(s); in this case, a pulse width modulated positive signal (modulation frequency 857
`Oscilloscope trace showing, in green (CH4), the drive voltage applied by the iPhone 14 haptic
`
`
`
`Accused Products
`
`Claim 1
`
`32
`
`

`

`33
`
`
`
`moveable component.
`motion of the iPhone 14 resulting (pursuant to Newton’s third law) from the motion of the
`component in a first and second direction. Channels 1 and 2 (yellow and purple) show the actual
`iPhone 14 haptic controller(s), with positive and negative voltages to drive the moveable
`Oscilloscope trace showing, in green (CH4), the PWM-modulated drive voltage applied by the
`
`
`
`Accused Products
`
`Claim 1
`
`33
`
`

`

`34
`
`
`
`filter).
`frequency of 230 Hz and motor drive amplitude of 3.2 V (peak-to-peak, through RC low-pass
`Oscilloscope trace showing the result of CHHapticEvent with intensity = 0.5, sharpness = 1, with
`
`
`
`Accused Products
`
`Claim 1
`
`34
`
`

`

`35
`
`
`
`scale as previous trace) is also significantly higher at intensity = 1 than 0.5.
`filter). Note that the externally measured vibration amplitude (yellow and purple traces, same
`frequency of 230 Hz and motor drive amplitude of 9.6V (peak-to-peak, through RC low-pass
`Oscilloscope trace showing the result of CHHapticEvent with intensity = 1, sharpness = 1, with
`
`
`
`Accused Products
`
`Claim 1
`
`35
`
`

`

`36
`
`
`
`desired frequency and amplitude).
`(e.g., using digital logic) to achieve substantially the same result (e.g., producing oscillations at a
`frequency and an amplitude specified by one or more stored values) in substantially the same way
`the power supply to the driving component to cause the moveable component to oscillate at a
`Engine, which performs substantially the same function (e.g., controlling supply of power from
`Accused Product contains one or more microprocessors that coordinate(s) operation of the Taptic
`differences between the accused functionality and the claimed invention. For example, each
`Accused Products, it is present under the doctrine of equivalents. There are no substantial
`To the extent Defendant contends and/or shows that this limitation is not literally present in the
`
`filter).
`frequency of 80 Hz and motor drive amplitude of 10.8 V (peak-to-peak, through RC low-pass
`Oscilloscope trace showing the result of CHHapticEvent with intensity = 1, sharpness = 0, with
`
`
`
`Accused Products
`
`Claim 1
`
`36
`
`

`

`37
`
`
`
`control component.
`and a Hall sensor controller, which alone or in combination form a microprocessor within the
`For example, each Accused Product includes a main system processor, a linear motor coil driver,
`
`
`
`See, e.g.:
`
`In each Accused Product, the control component includes a microprocessor.
`See supra claim element [1f] and infra claim elements [2c]-[2d].
`
`[2c] a microprocessor,
`
`Each Accused Product comprises a control component as claimed.
`
`
`
`meets claim limitation [2b].
`Each Accused Product comprises the vibration module of claim 1 wherein the control component
`
`Accused Products
`
`See infra claim element [2b].
`
`includes
`[2b] a control component that
`circuitry; and
`circuit with additional control
`[2a] an variable oscillator
`component is one of:
`claim 1 wherein the control
`[2pre] The vibration module of
`
`Claim 2
`
`Claim 2
`
`37
`
`

`

`38
`
`
`
`Photographs showing iPhone 14 system board with A15 Bionic processor.
`
`
`
`Accused Products
`
`Claim 2
`
`38
`
`

`

`39
`
`
`
`Annotated photograph of Hall sensor controller and motor coil driver from the iPhone 14.
`
`
`
`Accused Products
`
`Claim 2
`
`39
`
`

`

`40
`
`
`
`X-ray image of Apple Watch Ultra system board.
`
`
`
`Accused Products
`
`Claim 2
`
`40
`
`

`

`41
`
`
`
`memory within, or separate from, the microprocessor, the control program executed by the
`In each Accused Product, a control component includes a control program, stored in an electronic
`
`in an electronic memory
`[2d] a control program, stored
`
`connection points for haptic motor.
`Annotated photograph of partially disassembled Apple Watch Ultra system board, showing
`
`
`
`Accused Products
`
`Claim 2
`
`41
`
`

`

`42
`
`
`
`response.
`the Hall effect sensor(s) themselves and the precision and quality of the resulting vibration
`feedback received from the Hall effect sensor(s), as demonstrated by, for example, the presence of
`processor. On information and belief, the control outputs are generated based on the closed-loop
`vibration response as directed by the application processor and software running on the application
`(actuator) that cause alternating magnetic fields, moving the mass and therefore producing a
`For a further example, the control component generates electrical outputs to the driving coils
`
`the received output signals from the sensors.
`module and adjusts one or more operational control outputs of the control component according to
`receives output signals from sensors within the vibration module during operation of the vibration
`Each Accused Product comprises the vibration module of claim 1 wherein the control component
`
`
`
`Accused Products
`
`the sensors.
`received output signals from
`component according to the
`outputs of the control
`more operational control
`module and adjusts one or
`operation of the vibration
`vibration module during
`signals from sensors within the
`component receives output
`claim 1 wherein the control
`[3] The vibration module of
`
`Claim 3
`
`Claim 3
`
`frequency and/or amplitude. See supra claim element [1f].
`the system processor and/or linear motor control driver include additional stored values specifying
`the system processor and associated volatile and non-volatile memory. On information and belief,
`indirectly control the frequency and amplitude of the oscillation and that are stored at least within
`APIs and interfaces, specify intensity and sharpness (exemplary stored values) that directly and/or
`demonstrated by public APIs and by testing. The public APIs, as well as any proprietary Apple
`control component can drive the moveable component at specified frequencies and amplitude, as
`linear resonant vibration motor. When the control program is executed by the microprocessor, the
`microprocessor contains confidential and proprietary software and/or firmware to control the
`For example, one or more of the system processor and/or linear motor coil driver forming the
`
`
`
`more stored values.
`cause the moveable component to oscillate at a frequency and an amplitude specified by the one or
`microprocessor to control supply of power from the power supply to the driving component to
`
`Accused Products
`
`or more stored values.
`amplitude specified by the one
`oscillate at a frequency and an
`moveable component to
`component to cause the
`power supply to the driving
`supply of power from the
`microprocessor to control
`program executed by the
`microprocessor, the control
`within, or separate from, the
`
`Claim 2
`
`42
`
`

`

`43
`
`
`
`patterns resulting from various control inputs
`https://developer.apple.com/documentation/corehaptics/chhapticevent, describing vibration
`Documentation of CHHapticEvent object,
`
`
`
`Accused Products
`
`Claim 3
`
`See, e.g.:
`
`43
`
`

`

`44
`
`
`
`https://developer.apple.com/documentation/corehaptics/chhapticevent/parameterid;
`Documentation of haptic event parameters,
`
`
`
`Accused Products
`
`Claim 3
`
`44
`
`

`

`45
`
`
`
`9219fdebdcaa.
`https://medium.com/lofelt/10-things-you-should-know-about-designing-for-apple-core-haptics-
`
`
`
`Accused Products
`
`Claim 3
`
`45
`
`

`

`46
`
`
`
`actual motion (from attached vibration transducer) of iPhone 14.
`Photograph of test apparatus for measuring motor coil drive signal (from tapped connection) and
`
`
`
`Accused Products
`
`Claim 3
`
`46
`
`

`

`47
`
`
`
`kHz) to drive the moveable component to oscillate.
`controller(s); in this case, a pulse width modulated positive signal (modulation frequency 857
`Oscilloscope trace showing, in green (CH4), the drive voltage applied by the iPhone 14 haptic
`
`
`
`Accused Products
`
`Claim 3
`
`47
`
`

`

`48
`
`
`
`the linear resonant vibration module) to achieve substantially the same result (e.g., causing the
`substantially the same way (e.g., making adjustments based on information from sensors within
`of the control component according to the received output signals from the sensors) in
`performs substantially the same function (e.g., adjusting one or more operational control outputs
`to signals or values derived from the received output signals from one or more sensors, which
`component in each Accused Product may adjust one or more operational control outputs according
`differences between the accused functionality and the claimed invention. For example, the control
`Accused Products, it is present under the doctrine of equivalents. There are no substantial
`To the extent Defendant contends and/or shows that this limitation is not literally present in the
`
`moveable component.
`motion of the iPhone 14 resulting (pursuant to Newton’s third law) from the oscillation of the
`component in a first and second direction. Channels 1 and 2 (yellow and purple) show the actual
`iPhone 14 haptic controller(s), with positive and negative voltages to drive the moveable
`Oscilloscope trace showing, in green (CH4), the PWM-modulated drive voltage applied by the
`
`
`
`
`
`Accused Products
`
`Claim 3
`
`48
`
`

`

`49
`
`
`
`
`
`See, e.g.:
`
`
`
`public APIs, as well as any proprietary Apple APIs and interfaces. See supra claim element [1f].
`more operational control parameters “intensity” and “sharpness” that may be selected in various
`least amplitude and frequency of a signal from a Hall effect sensor, which correspond to one or
`and belief, the operational control outputs are adjusted in a way to produce desired outputs of at
`frequency, and/or phase of the drive voltage applied by the control component. On information
`For example, each Accused Product adjusts the operational control outputs such as amplitude,
`
`
`
`operational control parameters.
`module produces desired outputs from the one or more sensors corresponding to one or more
`received output signals from the sensors in order that subsequent operation of the vibration
`adjusts the one or more operational control outputs of the control component according to the
`Each Accused Product comprises the vibration module of claim 1 wherein the control component
`
`Accused Products
`
`control parameters.
`one or more operational
`more sensors corresponding to
`desired outputs from the one or
`vibration module produces
`subsequent operation of the
`the sensors in order that
`received output signals from
`component according to the
`outputs of the control
`more operational control
`component adjusts the one or
`claim 1 wherein the control
`[4] The vibration module of
`
`Claim 4
`
`Claim 4
`
`values).
`moveable component to oscillate at a frequency and an amplitude specified by one or more stored
`
`Accused Products
`
`Claim 3
`
`49
`
`

`

`50
`
`
`
`filter).
`frequency of 230 Hz and motor drive amplitude of 3.2 V (peak-to-peak, through RC low-pass
`Oscilloscope trace showing the result of CHHapticEvent with intensity = 0.5, sharpness = 1, with
`
`
`
`Accused Products
`
`Claim 4
`
`50
`
`

`

`51
`
`
`
`as previous trace) is also significantly higher at intensity = 1 than 0.5.
`filter). Note that the externally measured vibration amplitude (yellow and purple traces, same scale
`frequency of 230 Hz and motor drive amplitude of 9.6V (peak-to-peak, through RC low-pass
`Oscilloscope trace showing the result of CHHapticEvent with intensity = 1, sharpness = 1, with
`
`
`
`Accused Products
`
`Claim 4
`
`51
`
`

`

`52
`
`
`
`parameters).
`desired outputs from the one or more sensors corresponding to one or more operational control
`operational control outputs in order that subsequent operation of the vibration module produces
`the linear resonant vibration module) to achieve substantially the same result (e.g., adjusting
`substantially the same way (e.g., making adjustments based on information from sensors within
`of the control component according to the received output signals from the sensors) in
`performs substantially the same function (e.g., adjusts the one or more operational control outputs
`to signals or values derived from the received output signals from one or more sensors, which
`component in each Accused Product may adjust one or more operational control outputs according
`differences between the accused functionality and the claimed invention. For example, the control
`Accused Products, it is present under the doctrine of equivalents. There are no substantial
`To the extent Defendant contends and/or shows that this limitation is not literally present in the
`
`filter).
`frequency of 80 Hz and motor drive amplitude of 10.8 V (peak-to-peak, through RC low-pass
`Oscilloscope trace showing the result of CHHapticEvent with intensity = 1, sharpness = 0, with
`
`
`
`
`
`Accused Products
`
`Claim 4
`
`52
`
`

`

`53
`
`
`
`
`
`See, e.g.:
`
`
`
`element [1f].
`component will be adjusted in order to produce the selected resonant frequency. See supra claim
`pre-determined resonant frequency of the vibration module, the power supplied to the driving
`APIs and interfaces. When the “sharpness” parameter is chosen to be substantially similar to a
`“sharpness” parameter may be selected in various public APIs, as well as any proprietary Apple
`oscillate as an operational control output. The desired oscillation frequency corresponding to a
`For example, each Accused Product includes a frequency for driving the moveable component to
`
`
`
`any proprietary Apple APIs and interfaces. See supra claim element [1f].
`corresponding to an “intensity” parameter that may be selected in various public APIs, as well as
`For example, each Accused Product includes a strength of vibration operational control parameter,
`
`movable component at a resonant frequency for the vibration module.
`dynamically adjusting the power supplied to the driving component to produce oscillation of the
`which the control component drives the moveable component to oscillate, the control component
`moveable component; and wherein the one or more operational control outputs is a frequency at
`operational control parameters is a strength of vibration produced by the oscillation of the
`Each Accused Product comprises the vibration module of claim 4 wherein the one or more
`
`
`
`Accused Products
`
`vibration module.
`resonant frequency for the
`movable component at a
`produce oscillation of the
`the driving component to
`adjusting the power supplied to
`component dynamically
`oscillate, the control
`moveable component to
`component drives the
`at which the control
`control outputs is a frequency
`one or more operational
`component; and wherein the
`oscillation of the moveable
`vibration produced by the
`parameters is a strength of
`more operational control
`claim 4 wherein the one or
`[5] The vibration module of
`
`Claim 5
`
`Claim 5
`
`53
`
`

`

`54
`
`
`
`patterns resulting from various control inputs
`https://developer.apple.com/documentation/corehaptics/chhapticevent, describing vibration
`Documentation of CHHapticEvent object,
`
`
`
`Accused Products
`
`Claim 5
`
`54
`
`

`

`55
`
`
`
`https://developer.apple.com/documentation/corehaptics/chhapticevent/parameterid;
`Documentation of haptic event parameters,
`
`
`
`Accused Products
`
`Claim 5
`
`55
`
`

`

`56
`
`
`
`more complex operational modes also exist as shown by the existence of complex and time-
`single haptic event with constant intensity and sharpness. Other operational modes, including
`any proprietary Apple APIs and interfaces. The default operational mode may correspond to a
`corresponding to an “intensity” parameter that may be selected in various public APIs, as well as
`For example, each Accused Product includes a strength of vibration operational control parameter,
`
`mode.
`of vibration produced by the oscillation of the moveable component and a current operational
`In each Accused Product, the one or more operational control parameters include both a strength
`
`
`
`Each Accused Product comprises the vibration module of claim 4.
`
`Accused Products
`
`operational mode; and
`component and a current
`oscillation of the moveable
`vibration produced by the
`include both a strength of
`operational control parameters
`[6a] wherein the one or more
`claim 4
`[6pre] The vibration module of
`
`Claim 6
`
`Claim 6
`
`9219fdebdcaa.
`https://medium.com/lofelt/10-things-you-should-know-about-designing-for-apple-core-haptics-
`
`
`
`Accused Products
`
`Claim 5
`
`56
`
`

`

`57
`
`
`
`element [1f] and infra claim 15.
`dependent vibrational behaviors not supported by the default operational mode. See supra claim
`
`Accused Products
`
`Claim 6
`
`
`
`See also, e.g.:
`
`
`
`57
`
`

`

`58
`
`
`
`patterns resulting from various control inputs
`https://developer.apple.com/documentation/corehaptics/chhapticevent, describing vibration
`Documentation of CHHapticEvent object,
`
`
`
`Accused Products
`
`Claim 6
`
`58
`
`

`

`59
`
`
`
`https://developer.apple.com/documentation/corehaptics/chhapticevent/parameterid;
`Documentation of haptic event parameters,
`
`
`
`Accused Products
`
`Claim 6
`
`59
`
`

`

`60
`
`
`
`oscillate as an operational control output. See supra claim element [1f].
`For example, each Accused Product includes a frequency for driving the moveable component to
`
`
`
`output used to produce a desired vibration strength.
`coils, this indicates current supplied by the power supply to the driving component is a control
`each Accused Product. Since the magnetic field is proportional to current in the electromagnetic
`magnet in the moveable component by the magnetic field produced by electromagnetic coils in
`For example, the strength of vibration is determined from the force exerted on the permanent
`
`which the control component drives the moveable component to oscillate.
`determines a current supplied by the power supply to the driving component and a frequency at
`In each Accused Product, the one or more operational control outputs is a control output that
`
`9219fdebdcaa.
`https://medium.com/lofelt/10-things-you-should-know-about-designing-for-apple-core-haptics-
`
`
`
`
`
`
`
`component to oscillate.
`drives the moveable
`which the control component
`component and a frequency at
`power supply to the driving
`a current supplied by the
`control output that determines
`operational control outputs is a
`[6b] wherein the one or more
`
`Accused Products
`
`Claim 6
`
`60
`
`

`

`61
`
`
`
`14, with moveable component in place at left. The moveable component travels up and down from
`Photograph showing one driving coil (at right) within disassembled Taptic Engine from the iPhone
`
`See, e.g.:
`
`
`
`driving component.
`fields substantially parallel to the directions in which the moveable component is driven by the
`For example, each Accused Product comprises two electromagnetic coils that generate magnetic
`
`
`
`directions in which the moveable component is driven by the driving component.
`comprises one or more electromagnetic coils that generate magnetic fields parallel to the
`Each Accused Product comprises the vibration module of claim 1 wherein the driving component
`
`Accused Products
`
`driving component.
`component is driven by the
`which the moveable
`parallel to the directions in
`generate magnetic fields
`more electromagnetic coils that
`component comprises one or
`claim 1 wherein the driving
`[7] The vibration module of
`
`Claim 7
`
`Claim 7
`
`61
`
`

`

`62
`
`
`
`moveable mass.
`magnetic field direction substantially parallel to the left and right directions of motion of the
`from this perspective (red arrows) against mechanical springs. The drive coils produce a
`bottom) surrounding the moveable component. The moveable component travels left and right
`Photograph of internals of Taptic Engine from the iPhone 14, showing drive coils (top and
`
`coils.
`this perspective, which is the same direction as magnetic field lines originating from the driving
`
`Accused Products
`
`Claim 7
`
`62
`
`

`

`63
`
`repelling components selected from one of mechanical springs and magnets.
`In each Accused Product, the housing is a tube, capped at both ends by movable-component-
`
`Each Accused Product comprises the vibration module of claim 1.
`
`Accused Products
`
`
`
`tube, capped at both ends by
`[8a] wherein the housing is a
`claim 1
`[8pre] The vibration module of
`
`Claim 8
`
`Claim 8
`
`magnetic field lines originating from the drive coils.
`moveable component travels left and right from this perspective, which is the same direction as
`visible coils would be positioned above and below the movable component when assembled. The
`Photograph of drive coils within disassembled Taptic Engine from Apple Watch Ultra. The two
`
`Accused Products
`
`Claim 7
`
`63
`
`

`

`64
`
`
`
`travels up and down from this perspective against two mechanical springs on the top and bottom.
`14, with moveable component in place at left inside a rectangular tube. The moveable component
`Photograph showing one driving coil (at right) within disassembled Taptic Engine from the iPhone
`
`Mechanical springs
`
`See, e.g.:
`
`
`
`mechanical springs.
`For example, in each Accused Product, the housing is a rectangular tube capped at both ends by
`
`
`
`Accused Products
`
`magnets;
`of mechanical springs and
`components selected from one
`movable-component- repelling
`
`Claim 8
`
`64
`
`

`

`65
`
`
`
`In each Accused Product, the moveable component is a magnet shaped to slide within the tube.
`travels left and right from this perspective against two mechanical springs on the left and right.
`moveable component in place at the top inside a rectangular tube. The moveable component
`Photograph of drive coils within disassembled Taptic Engine from Apple Watch Ultra, with the
`
`See, e.g.:
`
`
`
`to slide within the tube; and
`component is a magnet shaped
`[8b] wherein the movable
`
`Mechanical springs
`
`Accused Products
`
`Claim 8
`
`65
`
`

`

`66
`
`
`
`within a rectangular tube.
`Photograph of a disassembled Taptic Engine from the iPhone 14 showing a magnet shaped to slide
`
`Magnet
`
`Accused Products
`
`Mechanical springs
`
`Claim 8
`
`66
`
`

`

`67
`
`
`
`In each Accused Product, the driving component is an electromagnetic coil.
`slide within a rectangular tube.
`Photograph of a disassembled Taptic Engine from Apple Watch Ultra showing a magnet shaped to
`
`electromagnetic coil.
`component is an
`[8c] wherein the driving
`
`Magnet
`
`Mechanical springs
`
`Accused Products
`
`Claim 8
`
`67
`
`

`

`68
`
`
`
`Photograph of a disassembled Taptic Engine from the iPhone 14 showing an electromagnetic coil.
`
`coil
`Electromagnetic
`
`Magnet
`
`Mechanical springs
`
`See, e.g.:
`
`Accused Products
`
`Claim 8
`
`68
`
`

`

`69
`
`determined from energy-dispersive X-ray spectroscopy (EDS). The housing primarily consists of
`For example, the elemental composition of the housing of the Taptic Engine in the iPhone 14 was
`
`or more magnetic circuits within the vibration module.
`comprising a paramagnetic material that is shaped and positioned to reduce the reluctance of one
`Each Accused Product comprises the vibration module of claim 1 further including flux paths
`
`
`
`Accused Products
`
`coil.
`Photograph of a disassembled Taptic Engine from Apple Watch Ultra showing an electromagnetic
`
`
`
`reduce the reluctance of one or
`shaped and positioned to
`paramagnetic material that is
`paths comprising a