DCT

8:25-cv-02354

Haptix Solutions LLC v. MSI Computer Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-02354, C.D. Cal., 10/17/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant MSI Computer Corp. maintains offices in the district and conducts substantial business there, including the sale of the accused products.
  • Core Dispute: Plaintiff alleges that Defendant’s "MSI Pen 2" electronic stylus infringes a patent related to systems and methods for providing haptic feedback.
  • Technical Context: The technology concerns haptic feedback in electronic styluses, which aims to simulate the tactile sensation of writing on physical surfaces, thereby enhancing the user experience on digital tablets and computers.
  • Key Procedural History: Plaintiff Haptix Solutions LLC is the exclusive licensee of the patent-in-suit, which was originally assigned to the Electronics and Telecommunications Research Institute (ETRI). The complaint alleges that Plaintiff provided Defendant MSI with written notice of infringement on March 7, 2025, approximately seven months prior to filing the lawsuit, a fact which forms the basis for the willfulness allegation.

Case Timeline

Date Event
2007-11-26 ’686 Patent Priority Date
2012-08-28 ’686 Patent Issue Date
2023-01-06 News articles discuss Accused Product
2025-03-07 Plaintiff sends pre-suit notice letter to MSI
2025-03-10 MSI receives pre-suit notice letter
2025-10-17 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,253,686 - "Pointing Apparatus Capable of Providing Haptic Feedback, and Haptic Interaction System and Method Using the Same"

The Invention Explained

  • Problem Addressed: The patent addresses the limitation of conventional electronic styluses that fail to provide tactile feedback, making the experience of writing or drawing on a touchscreen feel unnatural compared to using a traditional pen on paper ('686 Patent, col. 1:49-54). Existing approaches allegedly required intrusive modifications to the touchscreen device itself ('686 Patent, col. 1:52-54).
  • The Patented Solution: The invention is a self-contained pointing apparatus (stylus) that incorporates its own power source, a wireless communication unit, a controller, and a "haptic stimulator" (e.g., a vibrator) ('686 Patent, Abstract). The stylus receives "haptic output information" wirelessly from a user terminal (e.g., a tablet) and the internal controller generates a signal to reproduce a corresponding haptic pattern, such as a vibration ('686 Patent, col. 2:7-15). This system architecture, illustrated in the patent's Figure 1 and reproduced in the complaint, allows the stylus to provide feedback independently, without requiring a specialized touchscreen (Compl. ¶15; ’686 Patent, FIG. 1).
  • Technical Importance: This approach decouples the haptic feedback generation from the display hardware, enabling advanced tactile features on a wider range of standard touchscreen devices.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 ('686 Patent, col. 15:5-24; Compl. ¶¶18, 27).
  • The essential elements of independent claim 1 are:
    • A pointing apparatus comprising a wireless communication unit, a controller, and a haptic stimulator.
    • The wireless communication unit receives an event with haptic output information.
    • The controller generates a control signal to reproduce a haptic pattern.
    • The haptic stimulator reproduces the pattern and must be either a "rotary vibrator" or a "linear vibrator" with specific functional characteristics.
    • The controller "increases an input cycle of the control signal in proportion to the moving speed of a pointer."
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The "MSI Pen 2" and any other electronic styluses sold by MSI with "substantially the same construction and haptic features" (Compl. ¶20).

Functionality and Market Context

  • The complaint describes the MSI Pen 2 as a stylus that provides "[h]aptic feedback which features a tiny motor built into the stylus body that provides a slight resistance when the pen is in contact with screen giving the user a realistic writing experience" (Compl. ¶22).
  • The product allegedly connects to devices via Bluetooth and supports the "Microsoft MPP2.6-haptic feedback" protocol (Compl. ¶¶23-24). Marketing materials cited in the complaint claim the feedback creates the "sensation of writing on texture" (Compl. ¶24).

IV. Analysis of Infringement Allegations

The complaint references an attached claim chart (Exhibit B) that was not provided with the filing; therefore, the infringement theory is summarized below based on the complaint's narrative allegations (Compl. ¶20).

The complaint alleges that the MSI Pen 2 practices the elements of at least Claim 1 of the ’686 Patent. The device’s Bluetooth functionality is alleged to meet the "wireless communication unit" limitation (Compl. ¶24). Its internal electronics and "tiny motor" are alleged to function as the claimed "controller" and "haptic stimulator" that work together to provide haptic feedback and create a "realistic writing experience" (Compl. ¶22). The complaint includes a side-by-side visual comparison of the accused 'MSI Pen 2' and the patent’s FIG. 2 to allege structural similarity (Compl. ¶21). However, the complaint does not provide specific technical facts explaining how the MSI Pen 2's internal components satisfy the final, and highly specific, limitation of Claim 1: that the controller "increases an input cycle of the control signal in proportion to the moving speed of a pointer." The allegations rely instead on general marketing descriptions of the user experience, such as creating the "sensation of writing on texture" (Compl. ¶24).

Identified Points of Contention

  • Scope Questions: A potential dispute may arise over whether the "tiny motor" in the MSI Pen 2 meets the specific definitions of either a "rotary vibrator" or a "linear vibrator" as required by the claim and described in the patent's specification.
  • Technical Questions: A central question will be whether the complaint's reliance on marketing language can substitute for direct evidence on a key technical limitation. What evidence does the complaint provide that the accused product's controller performs the specific function of increasing a control signal's "input cycle" in proportion to the pointer's moving speed, as the claim requires?

V. Key Claim Terms for Construction

The Term

"increases an input cycle of the control signal in proportion to the moving speed of a pointer"

Context and Importance

This functional limitation is the most specific and technically complex element of the asserted independent claim. Proving that the accused device performs this exact function will be critical to Plaintiff's infringement case. Practitioners may focus on this term because infringement will likely depend on whether the general "realistic writing experience" provided by the MSI Pen 2 is achieved through the specific proportional control logic claimed by the patent.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent states that the relationship may be determined "to be within a predetermined level, or may be determined to be in a continuous functional relationship," which may support an argument that a strict mathematical proportionality is not required ('686 Patent, col. 7:46-49).
  • Evidence for a Narrower Interpretation: The specification provides a specific example illustrated in FIG. 5B, where vibration frequency corresponds to discrete speed levels (e.g., "vibration is generated once per a second when the speed of the pointer is at a level 1, and the vibration is generated five times per a second when the speed of the pointer is at a level 5") ('686 Patent, col. 7:34-39). This could be used to argue that the claim requires a direct, measurable correlation between speed and the signal's cycle or frequency.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement based on MSI providing promotional materials, user guides, and technical support that instruct customers on how to use the infringing haptic features (Compl. ¶30). It also alleges inducement of third-party manufacturers and contributory infringement, asserting the MSI Pen 2 is a material component of the invention not suitable for substantial non-infringing use (Compl. ¶¶29, 31).

Willful Infringement

Willfulness is alleged based on pre-suit knowledge. The complaint states that Plaintiff sent a detailed notice letter to MSI on March 7, 2025, which was received on March 10, 2025, and that MSI continued its allegedly infringing conduct despite this notice (Compl. ¶33).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A key evidentiary question will be one of technical proof: Can Plaintiff demonstrate that the accused MSI Pen 2 implements the specific control logic required by Claim 1—namely, that the "input cycle of the control signal" increases "in proportion to the moving speed of a pointer"? The case may depend on whether evidence beyond high-level marketing claims can establish that the accused device operates in the precise manner claimed.
  • A core issue will be one of claim scope: Does the accused product's "tiny motor" fall within the definition of the claimed "haptic stimulator," which the patent limits to specific "rotary" or "linear" vibrator embodiments? The resolution will likely turn on a technical comparison of the accused device's internal mechanism against the structures described in the patent's specification.