DCT

7:23-cv-00077

Resonant Systems v. Apple Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:23-cv-00077, W.D. Tex., Filing Date of Second Amended Complaint: 06/26/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains regular and established places of business in the district, including multiple office and retail locations in Austin, El Paso, and San Antonio.
  • Core Dispute: Plaintiff alleges that Defendant’s iPhone products infringe four U.S. patents related to linear-resonant vibration modules used for haptic feedback.
  • Technical Context: The technology concerns haptic feedback systems in consumer electronics, which generate tactile sensations to enhance user interaction and provide notifications.
  • Key Procedural History: The complaint is a Second Amended Complaint. It alleges that Defendant had knowledge of the infringement allegations at least since receiving service of the lawsuit no later than June 7, 2023, and received infringement contentions on October 5, 2023. These dates are cited as the basis for Plaintiff's post-suit willful infringement claim.

Case Timeline

Date Event
2009-05-18 Earliest Priority Date (’767, ’337, ’830 Patents)
2012-01-10 ’767 Patent Issued
2014-10-14 ’337 Patent Issued
2015-02-13 Earliest Priority Date (’882 Patent)
2015-09-25 iPhone 6s Launch Date (Earliest Accused Product)
2018-04-10 ’830 Patent Issued
2021-10-19 ’882 Patent Issued
2023-06-07 Lawsuit Service Date (per complaint)
2023-10-05 Infringement Contentions Service Date (per complaint)
2024-05-28 Defendant's Interrogatory Answer Date (per complaint)
2024-06-26 Second Amended Complaint Filing Date

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

U.S. Patent No. 8,093,767 - "Linear-resonant vibration module" (issued Jan. 10, 2012)

The Invention Explained

  • Problem Addressed: The patent describes conventional vibration-generating units, such as intentionally unbalanced electric motors, as inefficient, destructive to the device, and limited to a narrow range of frequencies and amplitudes (ʼ767 Patent, col. 2:9-50).
  • The Patented Solution: The invention proposes a linear-resonant vibration module (LRVM) where a moveable component (e.g., a magnet) oscillates linearly within a housing. This motion is driven by an electromagnetic coil and controlled by a microprocessor. Magnets at the ends of the housing act like springs, repelling the moveable component to facilitate the reversal of direction, thereby creating a more efficient and controllable directional vibration (’767 Patent, col. 3:20-67; Figs. 4A-4G).
  • Technical Importance: This approach provided a method for generating more precise, efficient, and varied haptic feedback compared to the simple, often inefficient, rotational motors common at the time (’767 Patent, col. 4:1-17).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶11).
  • Essential elements of claim 1 include:
    • a housing;
    • a moveable component;
    • a power supply;
    • a driving component that drives the moveable component in two opposite directions;
    • a control component including a microprocessor, a control program, and a switch;
    • the control component receiving output signals from sensors within the module; and
    • the control component adjusting one or more operational control outputs according to the received sensor signals.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,860,337 - "Linear vibration modules and linear-resonant vibration modules" (issued Oct. 14, 2014)

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problems as the ’767 Patent, related to the limitations of unbalanced electric motors used for haptic feedback (’337 Patent, col. 2:11-67).
  • The Patented Solution: This invention expands on the LRVM concept by disclosing more advanced control methods and physical configurations. It describes driving the module at two or more frequencies simultaneously to generate "complex vibration modes" and "beat-wave" forms, allowing for more nuanced tactile effects (’337 Patent, col. 13:1-24; Figs. 22A-23). The patent also introduces the use of paramagnetic flux paths to concentrate the magnetic field, thereby improving the module's efficiency (’337 Patent, col. 14:1-15; Fig. 24B).
  • Technical Importance: The technology discloses methods for creating more sophisticated haptic effects beyond simple, single-frequency vibrations, and for improving the electromechanical efficiency of the actuator itself.

Key Claims at a Glance

  • The complaint asserts independent claim 2 (Compl. ¶17).
  • Essential elements of claim 2 include:
    • a housing, moveable component, power supply, user-input features, and a driving component;
    • a control component that controls the power supply to cause the moveable component to oscillate at a frequency and amplitude specified by user input;
    • wherein the control component drives simultaneous oscillation of the moveable component at two or more frequencies to generate complex vibration modes.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,941,830 - "Linear vibration modules and linear-resonant vibration modules" (issued April 10, 2018)

  • Technology Synopsis: This patent continues the same line of invention, describing linear vibration modules. It details control methods and physical configurations, including the use of elastomeric bristles for transferring vibration and paramagnetic flux paths for efficiency (’830 Patent, col. 10:1-10; col. 14:1-15). The patent further focuses on generating complex, user-specified vibration modes based on frequency and amplitude inputs (’830 Patent, col. 16:1-17).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶23).
  • Accused Features: The haptic feedback systems in the accused iPhone models (Compl. ¶22).

U.S. Patent No. 11,152,882 - "Oscillating-resonant-module controller" (issued October 19, 2021)

  • Technology Synopsis: This patent focuses on the controller for an "oscillating resonant module" (ORM). It describes a system with sensors that provide feedback, allowing a control component to precisely manage the oscillation to produce a desired vibration response, often by matching the device's resonant frequency (’882 Patent, Abstract; col. 3:4-15). It further discloses using pulse-width modulation and other advanced control signals to more accurately achieve desired vibration waveforms (’882 Patent, col. 24:39-51; col. 26:15-24).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶29).
  • Accused Features: The haptic feedback systems and their controllers in the accused iPhone models (Compl. ¶28).

III. The Accused Instrumentality

Product Identification

The accused products are numerous iPhone models, including the iPhone 6s, 6s Plus, 7, 7 Plus, 8, 8 Plus, X, XR, XS, XS Max, 11, 11 Pro, 11 Pro Max, SE (second and third generations), 12, 12 mini, 12 Pro, 12 Pro Max, 13, 13 mini, 13 Pro, 13 Pro Max, 14, 14 Plus, 14 Pro, and 14 Pro Max (Compl. ¶10, 16, 22, 28).

Functionality and Market Context

The accused functionality is the haptic feedback system within the iPhones, widely known as the "Taptic Engine." This system employs a linear actuator to generate precise vibrations that provide tactile feedback for a wide range of user interactions, such as confirming button presses, simulating physical clicks, and delivering nuanced notification alerts (Compl. ¶10-11). This feature is an integral part of the iOS user experience. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references separate claim chart exhibits that were not provided for this analysis. The infringement theory is therefore summarized in prose.

  • ’767 Patent Infringement Allegations: The complaint alleges that the accused iPhones contain a haptic feedback module that satisfies all limitations of claim 1 (Compl. ¶11). The narrative infringement theory suggests that the iPhones’ haptic system includes a housing, a moveable mass, a power supply, an electromagnetic driving component, and a microprocessor-based controller. Crucially, the theory asserts that this system uses sensors to provide feedback to the controller, which in turn adjusts its control outputs to manage the vibration, thereby forming a closed-loop control system as claimed.
  • ’337 Patent Infringement Allegations: The complaint alleges that the accused iPhones’ haptic system meets all limitations of claim 2 (Compl. ¶17). The core of this allegation is that the iPhone controller "drives simultaneous oscillation of the moveable component at two or more frequencies to generate complex vibration modes." This suggests that the sophisticated and varied haptic effects produced by the iPhones are achieved through the specific multi-frequency driving method recited in the claim.
  • Identified Points of Contention:
    • Scope Questions: A central question for the ’767 Patent may be whether the accused system’s "sensors" and controller perform the claimed function of "adjusting... operational control outputs... according to the received output signals." The dispute could turn on whether the accused devices use a real-time feedback loop to optimize vibration (as the patent specification suggests) or operate an open-loop system that executes pre-programmed patterns without real-time adjustment based on sensor feedback.
    • Technical Questions: For the ’337 Patent, the primary technical question is evidentiary: what is the precise operational mechanism of the accused haptic engine? The analysis will likely focus on whether the complex haptic effects are generated by driving the actuator with a signal composed of two or more simultaneous frequencies, as claimed, or if they are achieved through alternative methods, such as rapidly sequencing single-frequency waveforms.

V. Key Claim Terms for Construction

  • For the ’767 Patent, Claim 1:
    • The Term: "adjusting one or more operational control outputs... according to the received output signals"
    • Context and Importance: This term defines the claimed feedback mechanism. The infringement analysis for claim 1 will hinge on whether Apple’s system performs this specific type of sensor-driven, real-time adjustment.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is general and does not specify the purpose of the adjustment (e.g., resonance seeking). This may support a construction covering any change to the control signal that is responsive to a sensor input.
      • Evidence for a Narrower Interpretation: The specification provides a detailed example of the controller using sensor input (vibrational strength "lv11") to adjust frequency ("freq") in order to find the resonant peak (’767 Patent, Fig. 7B, steps 738-752). This embodiment may be used to argue for a narrower construction requiring the adjustment to be part of a feedback loop for optimizing vibration characteristics.
  • For the ’337 Patent, Claim 2:
    • The Term: "drives simultaneous oscillation of the moveable component at two or more frequencies"
    • Context and Importance: This limitation is the key point of novelty asserted for claim 2. The case may turn on whether the control signals used in the accused devices can be characterized as driving "simultaneous" oscillation at multiple frequencies.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term "simultaneous" could be construed broadly to mean any composite driving signal whose waveform is the mathematical superposition of two or more frequencies, which could cover a wide range of complex electronic signals.
      • Evidence for a Narrower Interpretation: The specification describes using this technique to create specific "complex vibrational modes," including "low-frequency pulses of high-frequency vibration" and "beat-wave" forms (’337 Patent, col. 13:1-24; Fig. 23). This context may support a narrower interpretation requiring a specific type of multi-frequency signal generation intended to produce such distinct, complex modes.

VI. Other Allegations

  • Willful Infringement: The complaint alleges post-suit willful infringement based on Defendant's knowledge of the asserted patents since at least the service of the lawsuit on June 7, 2023, and service of infringement contentions on October 5, 2023 (Compl. ¶32). The complaint further alleges that Defendant's interrogatory response of May 28, 2024, did not indicate an intention to cease infringement or design around the patents, suggesting a continued disregard for Plaintiff's patent rights (Compl. ¶33).

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

  • A key evidentiary question will be one of technical operation: Does the accused iPhone Taptic Engine function in the specific manner recited by the claims? Discovery will likely focus on reverse-engineering the control signals and feedback mechanisms to determine whether the system uses real-time, sensor-based adjustment (’767 Patent) and drives the actuator with simultaneous, multi-frequency signals to create complex effects (’337 Patent).
  • A core legal issue will be one of claim scope: How broadly will the court construe dispositive terms such as "adjusting... according to... signals" and "simultaneous oscillation"? The outcome of claim construction will likely determine whether Apple’s method for generating sophisticated haptics, even if technically different from the patent’s specific embodiments, falls within the bounds of the asserted claims.