Apple Inc v. Resonant Systems Inc

1. Case Identification

• Case #: IPR2024-00806
• Patent #: 9,941,830
• Filed: April 12, 2024
• Petitioner(s): Apple Inc.
• Patent Owner(s): Resonant Systems, Inc.
• Challenged Claims: 1-8, 14-17, 19-20

2. Patent Overview

• Title: Linear Vibration Modules and Linear-Resonant Vibration Modules
• Brief Description: The ’830 patent relates to vibration modules for incorporation into various electromechanical devices. The modules are designed to produce vibrations of selected amplitudes and frequencies through the linear oscillation of an internal component.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Gregorio - Claims 1-7 are obvious over Gregorio.

• Prior Art Relied Upon: Gregorio (Patent 7,843,277).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Gregorio, which discloses a system for generating haptic feedback in handheld devices using a Linear Resonant Actuator (LRA), teaches all limitations of independent claim 1. Gregorio’s system includes a housing, a moveable magnet/mass component, an actuator drive circuit as a power supply, user-input features like a touch-sensitive surface, an electric coil as a driving component, and a processor-based control component that adjusts oscillation frequency and amplitude based on stored values to maximize haptic feedback.
  • Motivation to Combine (for §103 grounds): Not applicable as this is a single-reference ground. Petitioner contended that Gregorio alone renders the claims obvious.
  • Expectation of Success (for §103 grounds): Not applicable.
  • Key Aspects: This ground establishes the foundational argument that a single prior art reference discloses a complete haptic feedback system containing all core elements of the challenged claims.

Ground 1B: Obviousness over Gregorio and Wakuda - Claims 8, 14, and 19 are obvious over Gregorio in view of Wakuda.

• Prior Art Relied Upon: Gregorio (Patent 7,843,277) and Wakuda (Patent 7,005,811).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Wakuda, which discloses a compact vibration generator, provides specific structural implementations for the LRA described more generally in Gregorio. Wakuda teaches a cylindrical-shaped casing (tube) capped at both ends, mechanical springs as movable-component-repelling components, and a movable magnet that slides within the tube, satisfying the limitations of claim 8. For claim 14, Wakuda teaches using magnetic materials for the casing and yoke members to create a defined magnetic flux path, reducing reluctance.
  • Motivation to Combine (for §103 grounds): A POSITA, seeking to implement the high-level LRA concept in Gregorio, would combine its control system with the detailed, compact, and compatible actuator structure from Wakuda to create a functional device for portable electronics. Both references target similar applications (handheld devices).
  • Expectation of Success (for §103 grounds): Success would be expected due to the architectural similarity of the actuators and the predictable result of combining a known control method with a known mechanical structure.

Ground 2A: Obviousness over Gregorio, Ramsay, Rossi, and Aldrich (under Means-Plus-Function Construction) - Claims 1-7, 15, 17, and 20 are obvious over the combination.

• Prior Art Relied Upon: Gregorio (Patent 7,843,277), Ramsay (Application # 2008/0294984), Rossi (Patent 4,879,641), and Aldrich (NASA Tech Briefs, Apr. 2008).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addresses the means-plus-function interpretation of "control component" and "driving component." Petitioner argued the combination of Gregorio and Ramsay (for user-customizable haptic effects) provides the basic system. Rossi is added to teach a specific, well-known H-bridge switching circuit as the structure for the "driving component" to control current direction. Aldrich is added to teach a "hill-climbing" feedback control algorithm as the structure for the "control component," which continuously monitors sensor output to maintain oscillation at a resonant frequency without the intermittent "monitoring period" taught by Gregorio.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Gregorio-Ramsay with Rossi for a simple, reliable circuit to implement the push/pull driving action. Aldrich would be combined to replace Gregorio's inefficient monitoring method with a superior, continuous feedback algorithm to improve performance and user experience, a known technique for a known problem.
  • Expectation of Success (for §103 grounds): Success was expected because combining the references involves implementing a standard circuit (Rossi) and a known software algorithm (Aldrich) into a compatible system (Gregorio-Ramsay) to achieve predictable improvements.
• Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Gregorio with Tierling to teach complex, multi-frequency vibration modes, and combining Gregorio with Ramsay to teach user-customizable haptic parameters under a plain-and-ordinary meaning construction.

4. Key Claim Construction Positions

• "control component" and "driving component": The central claim construction dispute concerns whether these terms should be interpreted under their plain-and-ordinary meaning or as means-plus-function terms under §112(f). Petitioner argued that the claims are unpatentable under either interpretation. For the means-plus-function approach (Grounds 2A-2C), Petitioner identified specific corresponding structures from the prior art, such as Rossi’s H-bridge circuit for the "driving component" and Aldrich’s hill-climbing algorithm implemented on a processor for the "control component."

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) and §325(d) is unwarranted.
• General Plastic/Fintiv Factors: Petitioner distinguished this petition from prior petitions filed by Samsung (IPR2023-00993) and Sony (IPR2024-00570) against the same patent. Petitioner argued it is a separate, unrelated party using entirely different prior art and claim construction arguments, thus presenting no unfair follow-on tactics. It also noted that a motion to stay is pending in the parallel district court litigation, favoring institution.
• Advanced Bionics Factors: Petitioner asserted that none of the relied-upon prior art references were considered during the original prosecution of the ’830 patent, and the art is not cumulative of what the examiner reviewed.

6. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 1-8, 14-17, and 19-20 of Patent 9,941,830 as unpatentable.