Resonant Systems Inc v. Sony Group Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Resonant Systems, Inc., d/b/a RevelHMI (Washington)
  • Defendant: Sony Group Corporation and Sony Interactive Entertainment, Inc. (Japan)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 2:22-cv-00424, E.D. Tex., 10/26/2022
• Venue Allegations: Venue is alleged to be proper because Defendants are foreign corporations, which may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s PlayStation 5 DualSense Wireless Controller infringes patents related to linear vibration motors for advanced haptic feedback.
• Technical Context: The technology concerns systems for generating more efficient, precise, and complex vibrational effects in electronic devices than traditional rotating-mass motors.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patents through "pre-filing communications." The asserted patents are part of a cascading family of continuing applications. Subsequent to the filing of the complaint, the assignee filed a disclaimer for claims 15 and 16 of the '081 patent, which relate to generating complex vibration modes, potentially narrowing the enforceable scope of that patent.

Case Timeline

Date	Event
2009-05-18	Earliest Priority Date for ’337, ’081, and ’830 Patents
2014-10-14	U.S. Patent No. 8,860,337 Issued
2016-06-14	U.S. Patent No. 9,369,081 Issued
2018-04-18	U.S. Patent No. 9,941,830 Issued
2022-10-26	Complaint Filed

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

U.S. Patent No. 8,860,337 - Linear vibration modules and linear-resonant vibration modules, Issued October 14, 2014

The Invention Explained

• Problem Addressed: The patent describes conventional vibration motors, which use an asymmetrically mounted weight on a rotating shaft, as inefficient, prone to rapid wear, and limited to producing elliptical (not linear) vibrations within a narrow frequency range (’337 Patent, col. 1:49 - col. 2:65).
• The Patented Solution: The invention proposes a linear vibration module where a moveable mass oscillates back and forth, driven by electromagnets. The polarity of the electromagnets is rapidly alternated by a control system, which can use feedback to maintain the oscillation at or near the system's resonant frequency for maximum efficiency and force (’337 Patent, Abstract; col. 5:1-9). The overall system, including a CPU, user controls, and sensors, is depicted in the patent's Figure 6 (’337 Patent, Fig. 6).
• Technical Importance: This linear, resonant approach was designed to produce a wider range of more precisely controlled and power-efficient haptic effects than the simple rumble of prior art motors (’337 Patent, col. 8:52-62).

Key Claims at a Glance

• The complaint asserts independent claim 2 (Compl. ¶10).
• The essential elements of independent claim 2 are:
  • A housing, a moveable component, a power supply, and user-input features.
  • A driving component that drives the moveable component in two opposite directions.
  • A control component that controls power to the driving component to cause oscillation at a user-specified frequency and amplitude.
  • Wherein the control component "drives simultaneous oscillation of the moveable component at two or more frequencies to generate complex vibration modes."
• The complaint alleges infringement of "one or more claims" of the patent (Compl. ¶10).

U.S. Patent No. 9,369,081 - Linear vibration modules and linear-resonant vibration modules, Issued June 14, 2016

The Invention Explained

• Problem Addressed: As a continuation of the same patent family, the ’081 Patent addresses the same technical problems as the ’337 Patent: the inefficiency, destructive forces, and limited operational range of vibration systems based on unbalanced rotating motors (’081 Patent, col. 2:2-51).
• The Patented Solution: The invention describes a linear vibration module controlled by a microprocessor. The control component is configured to receive input from user controls and cause a moveable component to oscillate at a frequency and amplitude "specified by user input" (’081 Patent, col. 16:40-46). This creates a direct link between user action and the specific character of the resulting vibration, allowing for a broad, user-controllable haptic space (’081 Patent, col. 4:30-36).
• Technical Importance: The invention enables independent control over both amplitude and frequency, allowing developers to create much more nuanced and varied tactile feedback than was previously achievable with fixed-mode vibration motors (’081 Patent, col. 8:50-65).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶16).
• The essential elements of independent claim 1 are:
  • A housing, a moveable component, a power supply, and user-input features.
  • A driving component that drives the moveable component in two opposite directions.
  • A control component that controls power to the driving component "to cause the moveable component to oscillate at a frequency and an amplitude specified by user input received from the user-input features."
• The complaint alleges infringement of "one or more claims" of the patent (Compl. ¶16).

Multi-Patent Capsule: U.S. Patent No. 9,941,830

• Patent Identification: U.S. Patent No. 9,941,830, Linear vibration modules and linear-resonant vibration modules, Issued April 18, 2018 (Compl. ¶21).
• Technology Synopsis: This patent continues the family's focus on linear vibration modules. It describes a system where a control component uses "one or more stored values" to specify the oscillation's frequency and amplitude (’830 Patent, col. 16:6-10). It further claims systems that drive "simultaneous oscillation of the moveable component at two or more frequencies to generate complex vibration modes" (’830 Patent, col. 18:32-35).
• Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶22).
• Accused Features: The complaint alleges that the "linear vibration motor technology" within the Sony PlayStation 5 DualSense Wireless Controller infringes this patent (Compl. ¶22).

III. The Accused Instrumentality

• Product Identification: Sony PlayStation 5 DualSense Wireless Controller (Compl. ¶¶10, 16, 22).
• Functionality and Market Context: The complaint identifies the accused product as containing "linear vibration motor technology" used to generate haptic feedback for the user (Compl. ¶¶10, 16, 22). The complaint does not provide further technical details on the operation of the controller's haptic system or its market context, instead referring to extrinsic claim chart exhibits that were not filed with the complaint. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for analysis of infringement. For each asserted patent, the complaint makes a conclusory statement that the Accused Products "satisfy all claim limitations" and refers to a corresponding claim chart exhibit (Compl. ¶¶10, 16, 22). As these exhibits were not provided with the pleading, there is no narrative or evidentiary basis within the complaint document itself to analyze the specific infringement theory.

• Identified Points of Contention:
  • Scope Questions: For the ’337 Patent, a central issue may be the interpretation of "drives simultaneous oscillation... at two or more frequencies to generate complex vibration modes." The dispute could turn on whether the accused controller's haptic engine achieves its effects by superimposing multiple distinct frequencies, or by rapidly modulating a single waveform in a way that Plaintiff argues is equivalent.
  • Technical Questions: For the ’081 Patent, a key question may be whether the controller's software layer interrupts the causal chain required by the claim. The claim requires oscillation "at a frequency and an amplitude specified by user input." A dispute may arise over whether a user's action (e.g., pulling a trigger) "specifies" the haptic response, or if the game's software, which interprets that action and selects a pre-programmed effect, is the true specifier of the frequency and amplitude.

V. Key Claim Terms for Construction

For the ’337 Patent:

• The Term: "complex vibration modes" (Claim 2)
• Context and Importance: This term is the central inventive concept distinguishing asserted claim 2. The outcome of the infringement analysis for the ’337 Patent will likely depend on whether the operation of the DualSense controller falls within the construed scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Dependent claim 3 provides a non-exhaustive list of what constitutes a complex vibration mode, including "a primary oscillation frequency modulated by a modulating oscillation frequency," a "beat frequency," and an "aperiodic oscillation waveform" (’337 Patent, col. 16:18-24). This suggests the term is not limited to a single technical implementation.
  • Evidence for a Narrower Interpretation: The definition is tied to its method of generation: "drives simultaneous oscillation of the moveable component at two or more frequencies" (’337 Patent, col. 16:15-17). A party could argue that a vibration profile not generated by the superposition of two or more distinct, simultaneous frequencies, regardless of its perceived complexity, falls outside the claim's scope.

For the ’081 Patent:

• The Term: "amplitude specified by user input" (Claim 1)
• Context and Importance: Practitioners may focus on this term because modern game controllers mediate user actions through complex software. The dispute will concern the required directness of the link between the user's physical action and the resulting vibration's amplitude.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses a system where "the vibration amplitude and vibration frequency can be independently controlled by a user through user-input features, including buttons, sliders, and other types of user-input features" (’081 Patent, col. 4:32-36). This could support a reading where any user action that results in a given amplitude satisfies the limitation.
  • Evidence for a Narrower Interpretation: The patent's control diagram (Fig. 6) shows "user controls" (606) providing input to a "CPU" (602), which in turn controls the haptics. A party might argue that the CPU and its programming, not the "user input" itself, are what ultimately "specify" the amplitude, requiring a more direct hardware-level mapping than what may occur in the accused controller.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Sony induces infringement by "actively encourage[ing] and instruct[ing] customers" to use the accused controllers in ways that directly infringe (Compl. ¶¶11, 17, 23). The basis for this appears to be the standard and intended operation of the gaming controller.
• Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint asserts Sony had knowledge "Through pre-filing communications from Plaintiff, and through at least the filing and service of this Complaint" (Compl. ¶¶11, 17, 23).

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

• A core issue will be one of technical operation: Does the accused DualSense controller generate haptic effects by driving its linear actuators with two or more simultaneous frequencies to create "complex vibration modes" as required by the patents, or does it employ a different, non-infringing method to create sophisticated tactile sensations?
• A key legal question will be one of causation and claim scope: For claims requiring vibration "specified by user input," does the layer of game software that interprets a player's actions and dictates a corresponding haptic effect break the causal chain required for infringement, or is the indirect link sufficient to meet the claim limitation?
• An immediate evidentiary question will arise from the pleading's structure: Given the complaint's reliance on un-provided exhibits for its infringement theories, early proceedings may focus on compelling Plaintiff to articulate the specific factual basis for its allegations that the accused controller's features map onto the patent claims.