Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 1 of 16
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`HAPTIC, INC.,
`
`Plaintiff,
`
`v.
`
`APPLE, INC.,
`
`Defendant.
`
`Civil Action No. 1:23-cv-1351
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`JURY TRIAL REQUESTED
`
`COMPLAINT FOR PATENT INFRINGEMENT AND JURY DEMAND
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`Plaintiff Haptic, Inc., (“Haptic” or “Plaintiff”) hereby files its Complaint for Patent
`
`Infringement and Jury Demand against Defendant Apple, Inc., (“Apple” or “Defendant”). Haptic
`
`alleges infringement of United States Patent No. 9,996,738 (the “’738 Patent” or “Asserted Patent”) and
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`states as follows:
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`THE PARTIES
`
`1.
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`Plaintiff Haptic, Inc., formerly known as Swan Solutions, Inc., is a Delaware
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`company with its principal place of business at 6016 Chictora Cove, Austin, TX 78759.
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`2.
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`Haptic is the sole and exclusive owner of all rights, title, and interest to and in the
`
`’738 Patent and holds the exclusive right to take all actions necessary to enforce its rights to the ʼ738
`
`Patent, including the right to recover all damages for past, present, and future infringement of the
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`ʼ738 Patent and to seek injunctive relief as appropriate under the law.
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`3.
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`Defendant Apple, Inc. is a California corporation and has a physical place of
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`business at 5501 West Parmer Lane, Austin, Texas 78727. Apple can be served through its registered
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`agent, CT Corporation System, located at 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`1
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`APPLE 1108
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 2 of 16
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`4.
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`Apple is registered to do business in Texas and has regular and established places of
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`business in the Western District of Texas.
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`
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`JURISDICTION AND VENUE
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`5.
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`This Court has exclusive subject matter jurisdiction over this case pursuant to 28
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`U.S.C. §§ 1331 and 1338(a) on the grounds that this action arises under the Patent Laws of the United
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`States, 35 U.S.C. § 1 et seq., including, without limitation, 35 U.S.C. §§ 271, 281, 284, and 285.
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`6.
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`This Court has specific personal jurisdiction over Apple because Apple conducts
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`business in the State of Texas and in this District. Plaintiff’s causes of action arise from Apple’s
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`contacts with and activities in the State of Texas and in this District. Upon information and belief,
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`Apple has committed acts of infringement within the State of Texas and within this District by
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`directly and/or indirectly making, using, selling, offering to sell, or importing products that infringe
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`one or more claims of the ʼ738 Patent.
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`7.
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`Venue is proper in this District under 28 U.S.C. §§ 1391(b), (c), and 1400(d) because
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`(1) Apple has done and continues to do business in this District, (2) Apple has a regular and
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`established place of business in this District, and (3) Apple has committed and continues to commit
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`acts of patent infringement in this District by making, using, selling, offering to sell, or importing
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`products that infringe one or more claims of the ʼ738 Patent.
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`8.
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`Apple is registered to do business in Texas and maintains regular and established
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`places of business in this District, including at least at 3121 Palm Way, Austin, Texas; 2901 S. Capital
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`of Texas Hwy., Austin, Texas; 12535 Riata Vista Circle, Austin, Texas; and 5501 West Parmer Lane,
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`Austin, Texas. Apple carries out its business from these physical locations. Upon information and
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`belief, work done at these Apple locations in Texas includes work related to Apple’s iPhone.
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`9.
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`Apple has placed or contributed to placing infringing products into the stream of
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`commerce via established distribution channels knowing or understanding that such products would
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 3 of 16
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`be sold and used in the United States, including in the Western District of Texas. On information and
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`belief, Apple has derived substantial revenues from infringing acts in the Western District of Texas,
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`including from the sale and use of infringing products.
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`10.
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`On information and belief, Apple manufactures some of its products in this District
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`and has done so since at least 2013.
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`11.
`
`On information and belief, several Apple employees who met with Haptic in 2016
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`and who have knowledge of Apple’s infringement of the ’738 Patent, including at least Apple
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`Systems Engineer Adam Norwood, reside in Austin.
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`12.
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`Apple has committed acts of infringement in this District and does business in this
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`District, including making sales and/or providing service and support for customers and/or end-users
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`in this District. Apple purposefully and voluntarily sold one or more infringing products with the
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`expectation they would be purchased in this District. These infringing products have been and
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`continue to be purchased in this District. Thus, Apple has committed acts of infringement within the
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`United States, the State of Texas, and this District.
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`13.
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`Additionally, Haptic is headquartered and physically based in Austin. Haptic also
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`inventories and ships its products from Austin.
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`
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`PATENT-IN-SUIT
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`14.
`
`On June 12, 2018, the United States Patent and Trademark Office issued the ʼ738
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`Patent titled “System and method for controlling a terminal device.” A true and correct copy of the
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`ʼ738 Patent is attached hereto as Exhibit 1. The ’738 Patent claims priority to U.S. Provisional Patent
`
`Application No. 62/115,769, filed on February 13, 2015. The ’738 Patent is valid and enforceable.
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`15.
`
`The ʼ738 Patent generally covers a tap-based control system that converts a surface
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`into a controller for a terminal device. The control system includes a housing, a sensor, a mounting
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`surface, a sensor, and a terminal device.
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`3
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`16.
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`Claim 1 of the ’738 Patent reads:
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`A control system comprising:
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`a housing having an engagement means for a mounting surface;
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` a
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` sensor contained within said housing, said sensor forming an interactive zone
`defined by a range of said sensor, said sensor being comprised of an accelerometer,
`said interactive zone being aligned with said mounting surface and overlaying said
`mounting surface outside a perimeter of said housing, said sensor being in a fixed
`position relative to said engagement means, wherein a contact interaction associated
`with said mounting surface within said interactive zone is detected by said sensor as
`data signals, said contact interaction being comprised of an impact on said mounting
`surface, said data signals being comprised of vibration data of said contact interaction;
`
` a
`
` server in communication with said sensor, said server being comprised of a routing
`module, a processing module being connected to said routing module, and an output
`module connected to said processing module, said routing module receiving said data
`signals from said sensor, said processing module determining a data pattern
`corresponding to said data signals of said contact interaction and matching said data
`pattern with a gesture profile, said gesture profile being associated with a command;
`and
`
` a
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` terminal device being comprised of a receiving module and means for initiating
`activity of said terminal device corresponding to said command, said terminal device
`being in communication with said server, said output module transmitting said
`command to said receiving module,
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`wherein said engagement means of said housing comprises:
`
`
`
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`an attachment means between said housing to said mounting surface; and
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`a transmission portion connecting said sensor to said attachment means of said
`housing and being comprised of a material with flexibility different than said
`mounting surface so as to set a rigid position of said sensor relative to said
`mounting surface, said contact interaction generating said data signals of said
`sensor through said transmission portion.
`
`Claim 2 of the ’738 Patent reads:
`
`17.
`
`The control system, according to claim 1, wherein said interactive zone of said sensor aligns
`with said mounting surface, said interactive zone being coplanar with said mounting
`surface.
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`18.
`
`Claim 4 of the ’738 Patent reads:
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`4
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 5 of 16
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`The control system, according to claim 1, wherein said contact interaction is comprised of an
`impact on said mounting surface, said data signals having a respective defined peak
`corresponding to each impact, a defined time period after a last defined peak, said data pattern
`being comprised of each defined peak and said defined time period after said last defined
`peak.
`
`19.
`
`Claim 5 of the ’738 Patent reads:
`
`The control system, according to claim 1, wherein said contact interaction is comprised of a
`plurality of impacts on said mounting surface, said data signals having a respective defined
`peak corresponding to each impact, a measured time period between each defined peak, and
`a defined time period after a last defined peak, said data pattern being comprised of each
`defined peak, each measured time period, and said defined time period after said last defined
`peak.
`
`20.
`
`Claim 9 of the ’738 Patent reads:
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`The control system, according to claim 1, further comprising:
`
`an additional terminal device being comprised of an additional receiving module and
`additional means for initiating activity of said additional terminal device corresponding to an
`additional command, said additional terminal device being in communication with said
`server, said output module transmitting said additional command to said additional receiving
`module.
`
`21.
`
`22.
`
`The ’738 Patent’s named inventors are Yaniv Boshernitzan and Ohad Nezer.
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`On February 12, 2016, the inventors conveyed to Swan Solutions, Inc. all rights,
`
`title, and interest in and to the invention of the ’738 Patent in a written assignment recorded in the
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`United States Patent and Trademark Office. On June 10, 2019, Swan Solutions, Inc. changed its name
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`to Haptic, Inc.
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`23.
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`24.
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`Haptic, Inc. is the exclusive owner of all rights, title, and interest in the ’738 Patent.
`
`Apple is not licensed under the ’738 Patent, either expressly or implicitly, nor does
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`Apple enjoy or benefit from any rights in or to the ’738 Patent whatsoever.
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 6 of 16
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`FACTUAL ALLEGATIONS
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`Haptic’s Innovative Technologies
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`Haptic is an operating business that offers Knocki, a small wireless device that
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`1.
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`25.
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`activates surfaces into touch control interfaces for terminal devices. Haptic has over ten-thousand
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`active users.
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`26.
`
`Yaniv Boshernitzan is the founder and CEO of Haptic. He is an experienced product
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`designer and inventor with 20 years of experience as an entrepreneur and product development
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`executive.
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`27.
`
`Haptic has several employees and has invested millions of dollars in product
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`development and other research and development efforts. Haptic’s flagship product, Knocki, helped
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`Haptic become the most-backed Texas technology company in Kickstarter history, raising $1.3
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`million in just 30 days to help the company bring its product to market and begin testing its Haptic
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`platform.
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`28.
`
`The specific mode of interaction of Knocki are “tap gestures,” which are predefined
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`tap patterns that can be applied to an activated surface. Each tap pattern can be mapped to trigger
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`specific functions. Knocki can be programmed with up to 10 unique tap gestures, such as a double-
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`taps, triple-taps, or two double-taps.
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`29.
`
`Knocki can be configured to control a variety of devices and programs. Knocki can
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`use Wi-Fi to connect to an automation server in the cloud, so that when a command is transmitted by
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`knocking a surface, the server identifies the corresponding action and sends it to the appropriate
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`device, software, or service. Internet-connected devices, devices with open-platform software, or
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`third-party Application Programming Interfaces can be controlled through Knocki. Knocki can also
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`connect to devices that are not internet-connected via a local area network. Knocki can also connect
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`to a variety of free online automation “recipe” tools to create unlimited new functions. In addition to
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 7 of 16
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`controlling other devices, Knocki can use gestures to control itself. Gestures can put the Knocki
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`device into different modes or even reset the device.
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`30.
`
`Knocki works anywhere it can access a Wi-Fi connection. Knocki works throughout
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`most homes and offices and even in garages or out-houses within the range of Wi-Fi. Knocki instantly
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`turns ordinary surfaces into powerful touch control interfaces for various actions. For example, Knocki
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`may be attached to a table and set to different knock patterns to turn off lights, unlock doors, send
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`messages, adjust the temperature, and many other actions.
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`31.
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`Knocki works on any solid surface, including those made of glass, plastic, wood,
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`and other materials. It may be placed on a wall, table, door, or even under or within a surface to add
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`interactivity and automate an endless array of actions.
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`32.
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`Haptic introduced Knocki to the public via a Kickstarter campaign in 2016. Since
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`then, Haptic has sold and shipped Knocki devices to customers in over 90 countries. Haptic continues
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`to manufacture the device and to sell it to customers worldwide directly through its website,
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`knocki.com, and through distributors. Knocki has garnered accolades from many distinguished
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`sources, including Popular Science, Business Insider, and Wired. Today, Haptic holds at least 7
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`United States utility and design patents on Knocki and related technology.
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`
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`2.
`
`33.
`
`Haptic’s Interactions with Apple
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`Amid the publicity from Knocki’s record-breaking Kickstarter campaign, Apple
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`reached out to and requested a meeting with Haptic to explore partnership opportunities and learn
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`more about Knocki. On May 23, 2016, in an email to Haptic’s CEO, an Apple representative wrote:
`
`We’d love to discuss your product and how it confluences with many of Apple’s
`smarthome aspirations. Without making any definitive promises too early, there
`may be some partnerships and resources to examine when your product goes to
`market. We’d like to schedule some time to speak with you on both your short and
`long-term objectives, general business structure and hopefully through this
`process get more insight on how Apple can be a partner to you both immediately
`and in the future. When can we chat?
`
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 8 of 16
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`34.
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`On December 6, 2016, Haptic had an in-person meeting with at least six Apple
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`representatives. That meeting was requested by Apple and hosted by Apple at an Apple office in
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`Houston, Texas:
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`
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`35.
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`During that meeting, Apple representatives asked many questions about Haptic and
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`
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`its technology. Apple explained to Haptic that it would use the technical information Haptic provided
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`to explore opportunities for collaboration, including accessibility applications within Apple products
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`and inclusion of Haptic’s Knocki product in Apple stores. At that meeting, Haptic told the Apple
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`representatives that the key technology in the Knocki product was patent pending. Apple requested
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`a sample of the Knocki product, and Haptic informed Apple that a pre-release Knocki could be
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`provided under a nondisclosure agreement.
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`36.
`
`Shortly after the December 6, 2016 meeting in Houston, an Apple representative
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`introduced Haptic by email to several Apple teams for the purpose of continuing discussions about
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`accessibility applications, putting Haptic’s product in Apple’s stores, and other partnership
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 9 of 16
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`opportunities. In 2017, Haptic and Apple entered a nondisclosure agreement. Over the next few
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`months, Haptic and Apple representatives continued discussing Knocki, which Haptic had provided
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`to Apple in pre-release form.
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`37.
`
`During an August 2017 call, Apple representatives asked Haptic many questions
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`about the technology architecture of the pre-release Knocki. In particular, Apple asked questions
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`about Haptic’s patented hardware architecture and the user interface of Haptic’s mobile application.
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`Apple also disclosed to Haptic that Apple was interested in how Haptic’s tap technology might
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`integrate more natively with Apple’s accessibility initiatives.
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`38.
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`Based on Apple’s disclosure of this interest, Haptic suggested the idea of Haptic and
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`Apple working together to seamlessly integrate the Knocki interface with Apple’s own ecosystem as
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`an accessible Siri alternative to control Apple’s own HomeKit-compatible Apple devices, such as
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`Apple TVs, MacBook Laptops, Home Pods, and Apple Watches. Haptic also suggested exploring
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`incorporation of its patent-pending technology directly into Apple devices and discussed with Apple
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`the mobile application that Haptic had designed for Knocki, demonstrating how tap gestures could
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`be mapped to functions, and how various third-party devices could be selected and grouped together
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`into a multi-function task-list that a tap pattern, such as a triple-tap, could control.
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`39.
`
`Haptic told Apple that Haptic’s Knocki device contained a specific processor model
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`(Texas Instruments CC3200) that Texas Instruments had previously road-mapped to integrate with
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`Apple devices via Apple’s HomeKit. Haptic cited its own use of that processor model to show Apple
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`that Haptic had already taken steps to seamlessly integrate Haptic’s technology with Apple’s
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`technology. Shortly after that meeting, Apple stopped communicating with Knocki. Also, shortly
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`after that meeting, the CC3200 Apple HomeKit roadmap was terminated.
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`40.
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`Apple was fully aware of Haptic’s pending patent application at least as of 2016.
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`Haptic’s patent application was granted in June 2018. Based on Haptic’s meetings with Apple in
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`2016 and 2017, Apple knew about Haptic’s patent and Knocki technology, and was interested in
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`accessibility applications similar to Haptic’s technology. After Apple ended all communications with
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`Haptic, Apple integrated Haptic’s technology into Apple’s own products when Apple launched the
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`Back Tap feature in September 2020.
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`
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`3.
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`41.
`
`Apple Launches its Back Tap Feature
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`On September 14, 2020, Apple launched Back Tap as a new iPhone feature with the
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`release of iOS 14. Apple prominently featured Back Tap when it was introduced. In Apple’s official
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`announcement for iOS 14, Back Tap appeared in the number one spot at the top of the list of Apple’s
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`new accessibility features, outranking seven other new accessibility features. Apple continues to
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`promote the Back Tap feature and has included it in every new iOS version since iOS 14.
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`42.
`
`Apple did not only include Back Tap in its new models of iPhones. Apple also rolled-
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`out Back Tap to over one billion previous-model iPhones via iOS updates.
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`43.
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`In addition to Apple’s own promotion of Back Tap, news articles, magazines, and
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`tech blogs have praised the Back Tap feature (Popular Science, Forbes, Business Insider, USA
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`Today, Mashable, MacWorld, NY Post, etc.). For example, Mashable stated that “iOS brings many
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`new features but back tap may be the most useful new feature,” and MacWorld touts Back Tap as
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`“the best iPhone feature you’re not using.”
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`
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`THE ACCUSED PRODUCTS
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`44.
`
`The Accused Products consist of Apple’s Back Tap feature and every model of
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`iPhone that Apple has introduced since the iPhone 8 series, including at least the iPhone 8, 8 Plus,
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`X, XS, XS Max, XR, 11, 11 Pro, 11 Pro Max, SE, SE2, SE3, 12, 12 Mini, 12 Pro, 12 Pro Max, 13,
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`13 Mini, 13 Pro, 13 Pro Max, 14, 14 Plus, 14 Pro, 14 Pro Max, 15, 15 Plus, 15 Pro, and 15 Pro Max
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`models.
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`10
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`45.
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`Every model of iPhone that Apple has introduced since the iPhone 8 series utilizes
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`Back Tap, a feature that allows a user to tap the back of the handset to perform functions on the
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`iPhone and control other external devices.
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`46.
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`On the iPhone, users can use Back Tap to set “double taps” and “triple taps” to
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`perform a variety of pre-configured functions. Users can also select more customized functionality
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`through Apple’s “Shortcuts” application—such as combining multiple steps across multiple apps to
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`create powerful task automations—and assign a shortcut to a Back Tap gesture profile.
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`47.
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`Back Tap activates the backside of the iPhone as a remote control tap interface,
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`allowing double-taps and triple-taps applied to the back of the phone to trigger a wide variety of
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`functions within the iPhone and to control external devices.
`
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`iPhone users can use Back Tap to control their phones and other devices with
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`48.
`
`different types of taps on the back of their phones. In addition to controlling the iPhone handset itself,
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`Back Tap also allows a user to create automations to control smart home features and other third-
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`party external devices. Back Tap also can control external Apple devices, including MacBook
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`computers, Apple TVs, Apple AirPods, Home Pods, and Apple Watches.
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`49.
`
`The functionality disclosed within the claims of the ’738 Patent represent the core
`
`value proposition of Haptic’s flagship product—Knocki. Knocki provides an easier way to control
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`devices by tap gestures anywhere on an ordinary surface. This is precisely the value proposition that
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`Apple is able to deliver through the infringing Back Tap feature.
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`50.
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`Apple has capitalized on Haptic’s patented technology and delivered it to millions
`
`of Apple customers without Haptic’s permission.
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`
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`51.
`
`52.
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`COUNT 1—DIRECT INFRINGEMENT OF THE ʼ738 PATENT
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`Haptic repeats and realleges all preceding paragraphs, as if fully set forth herein.
`
`As outlined in the non-limiting and exemplary claim charts attached as Exhibit 2,
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`Apple iPhones that use the Back Tap feature infringe every element of at least Claims 1, 2, 4, 5, and
`
`9 of the ʼ738 Patent. The attached claim charts are incorporated by reference in their entirety. Haptic
`
`reserves the right to modify these charts, including, for example, based on information about the
`
`Accused Products obtained in discovery.
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`53.
`
`Furthermore, the Back Tap feature enables control of the iPhone handset as well as
`
`devices external to the iPhone. Back Tap is also integrated with Apple’s “Shortcuts” application,
`
`which allows users to control Apple-produced and third-party external devices.
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`54.
`
`Apple’s Back Tap directly competes with Knocki and Haptic, which owns the ʼ738
`
`Patent that Apple infringes.
`
`55.
`
`Haptic has not licensed or otherwise authorized Apple to make, use, offer for sale,
`
`sell, or import any products that embody the inventions of the ʼ738 Patent.
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`56.
`
`Apple infringes at least claims 1, 2, 4, 5, and 9 of the ʼ738 Patent in violation of 35
`
`U.S.C. § 271 with respect to the Accused Products. Haptic contends each limitation is met literally,
`
`and, to the extent a limitation is not met literally, it is met under the doctrine of equivalents.
`
`57.
`
`Apple directly infringes at least claims 1, 2, 4, 5, and 9 of the ʼ738 Patent by making,
`
`using (e.g., performing/executing), selling, and/or offering to sell within the United States all iPhone
`
`models since the iPhone 8.
`
`58.
`
`As described in additional detail in the claim charts attached and incorporated herein
`
`by reference, the Accused Products detect a contact interaction, determine a data pattern of the
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`contact interaction (e.g., a double-tap or a triple-tap), and match it to a gesture profile. The gesture
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`profile is configured by the user through Apple’s graphical user interface, where a user can assign a
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`particular function to the double-tap or triple-tap. Apple’s devices utilize Apple software that allows
`
`users to see which devices it can control and configures which devices to control.
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`COUNT 2—CONTRIBUTORY INFRINGEMENT OF THE ’738 PATENT
`
`Haptic repeats and realleges all preceding paragraphs, as if fully set forth herein.
`
`59.
`
`60.
`
`Apple also contributes to infringement by others of one or more claims of the ʼ738
`
`Patent under 35 U.S.C. § 271(c), such as sellers, resellers, and end-user customers who directly
`
`infringe the ʼ738 Patent when they use Back Tap to control third-party external devices or to control
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`Apple’s own HomeKit-compatible Apple devices, such as Apple TVs, and MacBook Laptops,
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`AirPods, Home Pods, or Apple Watches.
`
`61.
`
`Apple is also liable as a contributory infringer of the ’738 Patent because it offers to
`
`sell and/or sold within the United States the material components of the Accused Products that
`
`practice the ’738 Patent. Additionally, Apple controls and monetizes the technical architecture for
`
`Apple’s “HomeKit,” which enables Back Tap to control other devices and allows Apple to set the
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`rules for how third-party devices can work with Back Tap.
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`COUNT 3—WILLFUL INFRINGEMENT OF THE ’738 PATENT
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`62.
`
`63.
`
`Haptic repeats and realleges all preceding paragraphs, as if fully set forth herein.
`
`Apple has had actual notice of Haptic’s patent application at least as early as
`
`December 2016. Apple received constructive notice of the ʼ738 Patent at least as early as June 2018
`
`(when the U.S. Patent and Trademark Office issued the ’738 Patent) and actual notice of the ʼ738
`
`Patent at least as early as the filing of this Complaint. Apple performed and continues to perform the
`
`acts that constitute direct and/or indirect infringement, with knowledge or willful blindness that the
`
`acts would constitute direct and/or indirect infringement of the ʼ738 Patent.
`
`64.
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`Haptic has been injured and seeks damages to adequately compensate it for Apple’s
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`infringement of the ʼ738 Patent. Such damages should be no less than a reasonable royalty under 35
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`U.S.C. § 284.
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`65.
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`Upon information and belief, Apple will continue to infringe the ʼ738 Patent unless
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`permanently enjoined by this Court. Pursuant to 35 U.S.C. § 283, Haptic is entitled to a permanent
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`injunction against further infringement of the ʼ738 Patent by Apple.
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`DEMAND FOR JURY TRIAL
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`66.
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`Plaintiff demands a jury trial of all issues so triable.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff prays for relief against Defendant as follows:
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`a. Entry of judgment declaring that Defendant infringes one or more claims of the ʼ738 Patent;
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`b. Entry of judgment declaring that Defendant’s infringement of the ʼ738 Patent is willful;
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`c. An order awarding damages sufficient to compensate Plaintiff for Defendant’s infringement
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`of the ʼ738 Patent, but in no event less than a reasonable royalty, including supplemental
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`damages post-verdict, together with pre-judgment and post-judgment interest and costs;
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 15 of 16
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`d. An injunction permanently enjoining Defendant, its employees, agents, officers, directors,
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`attorneys, successors, affiliates, subsidiaries, and assigns, and all of those in active concert
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`and participation with any of the foregoing persons or entities from infringing, contributing
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`to the infringement of, or inducing infringement of the ʼ738 Patent;
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`e. Enhanced damages pursuant to 35 U.S.C. § 284, and supplemental damages for any continuing
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`post-verdict infringement through entry of the final judgment with an accounting as needed;
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`f. Entry of judgment declaring that this case is exceptional and awarding Plaintiff its costs and
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`reasonable attorney fees pursuant to 35 U.S.C. § 285;
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`g. An accounting for acts of infringement;
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`h. A judgment and order requiring Defendant to pay Plaintiff pre-judgment and post-judgment
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`interest on the damages awarded;
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`i. A judgment and order awarding a compulsory ongoing royalty;
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`j. A judgment and order awarding Plaintiff costs associated with bringing this action;
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`k. Such other equitable relief which may be requested and to which the Plaintiff is entitled; and
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`l. Such other and further relief as the Court deems just and proper.
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`Date: November 6, 2023
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` Respectfully submitted,
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` SUSMAN GODFREY LLP
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` /s/ Brian D. Melton
`Brian D. Melton (Texas 24010620)
`Rocco Magni (Texas 24092745)
`Ace M. Factor (Texas 24118923)
`Thomas V. DelRosario (Texas 24110645)
`Shaleez E. Ozlat (Texas 24110186)
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Tel: (713) 651-9366
`Fax: (713) 654-6666
`bmelton@susmangodfrey.com
`rmagni@susmangodfrey.com
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`Case 1:23-cv-01351 Document 1 Filed 11/06/23 Page 16 of 16
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`afactor@susmangodfrey.com
`tdelrosario@susmangodfrey.com
`sozlat@susmangodfrey.com
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`Counsel for Plaintiff Haptic, Inc.
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