Meta Platforms Inc v. Resonant Systems Inc

1. Case Identification

• Case #: IPR2025-00823
• Patent #: 8,860,337
• Filed: April 23, 2025
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Resonant Systems, Inc.
• Challenged Claims: 2 and 3 (with analysis of disclaimed claims 1 and 4 to conform with a related IPR)

2. Patent Overview

• Title: Linear Vibration Modules and Linear-Resonant Vibration Modules
• Brief Description: The ’337 patent discloses vibration modules for incorporation into various electromechanical devices. The modules are designed to produce vibrations of selected amplitudes and frequencies via the linear oscillation of an internal weight or component.

3. Grounds for Unpatentability

Ground 1: Obviousness over Wakuda/Ramsay - Claims 1-4 are obvious over Wakuda in view of Ramsay.

• Prior Art Relied Upon: Wakuda (Patent 7,005,811) and Ramsay (Application # 2008/0294984).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wakuda taught a complete linear vibration generator system, including a casing, a movable body, a coil, and a control means capable of generating vibrations at a natural frequency and a lower envelope frequency. Ramsay was cited for teaching software and a graphical user interface (GUI) that enabled an end-user to customize haptic effects by specifying parameters like vibration frequency and amplitude.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Ramsay’s user-customization features with Wakuda’s haptic device to overcome the known limitation that haptic feedback modification was typically restricted to professional designers. This combination would provide users with greater flexibility and offer a "fuller haptic experience" by allowing the mixing of different haptic tracks.
  • Expectation of Success: A POSITA would have a reasonable expectation of success as both references describe techniques for controlling a linear actuator. The proposed modification primarily involved implementing Ramsay’s known software solutions into Wakuda’s hardware, a task well within the skill of a POSITA.

Ground 2: Obviousness over Wakuda/Ramsay/Rossi/Aldrich - Claims 1-4 are obvious over Wakuda and Ramsay in view of Rossi and Aldrich.

• Prior Art Relied Upon: Wakuda (Patent 7,005,811), 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 built on the Wakuda/Ramsay combination by adding specific implementation details. Petitioner asserted Rossi taught a well-known H-bridge switching circuit for reversing current flow, disclosing the specific circuitry to implement the oscillation described functionally in Wakuda. Aldrich was cited for its "hill-climbing" feedback control algorithm, which provides a specific method for tracking and maintaining oscillation at a resonant frequency—a goal of Wakuda for which it lacked implementation details.
  • Motivation to Combine: A POSITA would incorporate Rossi's H-bridge circuit into the Wakuda/Ramsay system as a simple, cost-effective, and conventional way to achieve the required current switching. A POSITA would also incorporate Aldrich’s algorithm to improve the system's ability to track the resonant frequency, thereby fulfilling Wakuda’s stated objective more effectively and reliably.
  • Expectation of Success: The combination involved applying a standard circuit design (Rossi) and a known software algorithm (Aldrich) to the base system, which were argued to be routine modifications for a POSITA with a high likelihood of success.

Ground 3A: Obviousness over Gregorio/Ramsay/Wakuda - Claims 1, 2, and 4 are obvious over Gregorio and Ramsay in view of Wakuda.

• Prior Art Relied Upon: Gregorio (Patent 7,843,277), Ramsay (Application # 2008/0294984), and Wakuda (Patent 7,005,811).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Gregorio taught a base haptic feedback system with a linear resonant actuator (LRA) that determines its own resonant frequency. The combination with Ramsay added user-customization features, similar to Ground 1. Wakuda was added to provide specific, concrete implementation details for the LRA components (e.g., casing, coil, movable body), which Gregorio described only at a high level.
  • Motivation to Combine: A POSITA seeking to build the LRA described in Gregorio would have been motivated to look to references like Wakuda for detailed design guidance. The motivation for adding Ramsay’s teachings remained consistent: providing user-configurability for a richer and more customizable haptic experience.
  • Expectation of Success: Success was argued to be predictable because the references describe compatible technologies for handheld haptic devices. Modifying Gregorio's system with Wakuda's more detailed actuator design was presented as an application of a known technique to a known system to achieve predictable results.
• Additional Grounds: Petitioner asserted additional obviousness challenges based on Gregorio/Ramsay combined with Tierling (Ground 3B), and both base combinations further combined with Rossi and Aldrich (Grounds 4A and 4B), relying on similar motivations to add user-defined complex vibration modes and specific control circuitry.

4. Key Claim Construction Positions

• Petitioner argued that the terms "control component" and "driving component" are subject to inconsistent interpretations by the Patent Owner in co-pending litigation.
• To address this ambiguity, the petition presented its unpatentability arguments under two alternative constructions: (1) a plain-and-ordinary meaning, and (2) a means-plus-function interpretation under 35 U.S.C. §112(f). Petitioner contended the challenged claims were obvious under either construction.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under the Fintiv factors was inappropriate and that the factors weighed in favor of institution.
• It asserted that the co-pending district court case was in its infancy with no trial date set and, crucially, that Petitioner stipulated it would not advance the same invalidity grounds in district court, thereby eliminating any significant overlap between the proceedings.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 2 and 3 of the ’337 patent as unpatentable.