Resonant Systems Inc v. Meta Platforms Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Resonant Systems, Inc., d/b/a RevelHMI (Washington)
  • Defendant: Meta Platforms, Inc. (Delaware)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 7:25-cv-00035, W.D. Tex., 01/31/2025
• Venue Allegations: Venue is asserted based on Defendant Meta having a regular and established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Meta Quest 3 virtual reality products infringe a patent related to linear vibration modules for haptic feedback.
• Technical Context: The technology concerns haptic actuators that generate vibrations, a key component for creating immersive tactile feedback in consumer electronics like virtual reality controllers.
• Key Procedural History: This complaint represents the initial filing in this litigation. The asserted patent is a continuation-in-part of a 2010 application, which claims priority to a 2009 provisional application. The complaint does not mention any prior litigation or post-grant proceedings involving the patent.

Case Timeline

Date	Event
2009-05-18	’337 Patent Priority Date
2014-10-14	’337 Patent Issue Date
2025-01-31	Complaint Filing Date

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’s background section identifies multiple deficiencies in prior art vibration systems, which commonly used intentionally unbalanced rotating motors (’337 Patent, col. 1:22-30). These systems are described as inefficient, producing destructive internal forces that lead to rapid deterioration, generating primarily elliptical (not purely linear) vibrations, and being restricted to a very limited range of operational frequencies and amplitudes (’337 Patent, col. 2:11-54).
• The Patented Solution: The invention proposes a linear vibration module where a moveable component (a weight or magnet) oscillates linearly within a housing, driven by electromagnets whose polarity is rapidly alternated (’337 Patent, Abstract). This direct linear actuation, controlled by a processor and specialized circuitry like an H-bridge switch, allows for more efficient, directional, and precisely controlled vibrations across a wide range of frequencies and amplitudes, overcoming the limitations of rotational motors (’337 Patent, col. 4:13-43; Fig. 6).
• Technical Importance: The technology purports to offer a more robust and versatile method for generating haptic feedback, enabling designers to create more complex and nuanced tactile effects than were possible with conventional unbalanced motors (’337 Patent, col. 8:36-53).

Key Claims at a Glance

• The complaint asserts independent claim 2 (’337 Patent, Compl. ¶10).
• The essential elements of independent claim 2 are:
  • A housing;
  • A moveable component;
  • A power supply;
  • User-input features;
  • A driving component that drives the moveable component in two opposite directions within the housing;
  • 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 notes the infringement of "one or more claims," reserving the right to assert additional claims (’337 Patent, Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Meta Quest 3" as the representative Accused Product (Compl. ¶9).

Functionality and Market Context

• The complaint alleges that the Meta Quest 3 is a product that Meta makes, uses, sells, or imports (Compl. ¶9). It does not provide specific details regarding the technical operation of the haptic feedback system within the Accused Product or any allegations regarding its market position beyond its identification as a Meta product.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products "satisfy all claim limitations of one or more claims of the ’337 Patent" and states that a claim chart for exemplary independent claim 2 is attached as Exhibit 2 (Compl. ¶10). However, this exhibit was not included with the complaint document. As a result, the infringement theory is limited to the conclusory allegation of infringement without specific element-by-element mapping. A claim chart table cannot be constructed from the provided documents.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the complaint’s limited detail, the central disputes will likely emerge during discovery and claim construction.
  • Scope Questions: A primary question will concern the scope of the final limitation of claim 2: what constitutes "simultaneous oscillation... at two or more frequencies to generate complex vibration modes." The interpretation of this phrase, particularly "complex vibration modes," will be critical to the infringement analysis.
  • Technical Questions: A key evidentiary question will be whether the Plaintiff can produce evidence that the Meta Quest 3 haptic system actually operates in the manner required by claim 2. Specifically, discovery will need to establish whether the Quest 3 controller is capable of, and in fact does, drive its haptic actuator with a signal composed of two or more simultaneous frequencies to create specific "complex" effects, as opposed to simply varying the amplitude or frequency of a single oscillation over time.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis of likely claim construction disputes. However, based on the claim language and the patent's specification, certain terms are likely to be central.

• Term: "complex vibration modes"

• Context and Importance: This term appears in the final, and arguably most limiting, element of independent claim 2. The definition of what makes a vibration mode "complex" will be determinative of the scope of infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that the plain meaning of the claim language itself—"drives simultaneous oscillation... at two or more frequencies"—defines what is meant by a "complex vibration mode," without further limitation.
  • Evidence for a Narrower Interpretation: Practitioners may focus on dependent claim 3, which recites that "complex vibration modes include: a primary oscillation frequency modulated by a modulating oscillation frequency; a beat frequency; and an aperiodic oscillation waveform" (’337 Patent, col. 16:18-24). A party could argue this dependent claim defines and limits the scope of "complex vibration modes" in the independent claim. The specification also provides explicit examples and figures for these specific modes, such as the "beat-wave form" shown in Figure 23 (’337 Patent, col. 13:28-32).

• Term: "control component"

• Context and Importance: This term is central to the operation of the claimed invention. Its construction will determine what type of processing architecture meets the limitation—for example, whether a general-purpose CPU running software suffices, or if a more specialized hardware configuration is implied.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification discloses that the control component can be a "CPU microprocessor" that executes a "control program" and may be coupled to memory, suggesting a general-purpose, software-driven architecture (’337 Patent, col. 5:11-17; Fig. 6).
  • Evidence for a Narrower Interpretation: A party could argue that the detailed flow charts in Figures 7A-7C, which describe specific logic for monitoring sensor feedback and adjusting frequency to seek resonance, inform the meaning of the "control component" and require it to perform these specific functions (’337 Patent, col. 5:43-6:65).

VI. Other Allegations

• Indirect Infringement: The complaint makes a passing reference to "inducing others to do the same" in its jurisdictional allegations (Compl. ¶5). However, it does not plead a separate count for indirect infringement or provide specific factual allegations to support the required elements of knowledge and intent.
• Willful Infringement: The complaint does not explicitly allege willful infringement. It does, however, include a prayer for a finding that this is an "exceptional case" under 35 U.S.C. § 285, which is the statutory basis for awarding attorneys' fees and often relies on a finding of willful infringement or other litigation misconduct (Compl., Prayer for Relief ¶e). The complaint does not allege any facts related to pre-suit knowledge by the Defendant.

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

1. An Evidentiary Question of Operation: The central issue will be factual: can Plaintiff prove, through reverse engineering or internal documents, that the Meta Quest 3 haptic system actually functions as claimed? The case may turn on whether the accused device generates vibrations by driving its actuator with a signal comprising "two or more" distinct, simultaneous frequencies, as required by the patent, or if it achieves varied haptic effects through other means.

2. A Definitional Question of Scope: The dispute will likely focus on the proper construction of the term "complex vibration modes." The key question for the court will be whether this term is limited to the specific modulated and beat-frequency waveforms detailed in the patent's specification and dependent claims, or if it has a broader meaning that could cover any haptic effect generated from more than one simultaneous frequency.

3. A Question of Pleading Sufficiency: Given the complaint’s lack of specific factual allegations mapping claim elements to the accused product's functionality, Defendant may raise questions about whether the complaint meets the plausibility pleading standards established by Twombly and Iqbal, particularly for a technology where the specific method of operation is not externally apparent.