Haptic, Inc. v. Apple, Inc.

Background

Haptic sued Apple for direct and indirect infringement of U.S. Patent No. 9,996,738, titled “System and Method for Controlling a Terminal Device.” The patent describes a system in which a sensor detects gestures or physical impacts associated with a mounting surface and generates commands for a terminal device. The parties asked the court to resolve disputes about seven claim terms after a December 6, 2024 hearing.

The court adopted a definition of a person of ordinary skill in the art that required an undergraduate degree in electrical engineering, computer science, computer engineering, or a related field, plus at least two years of practical experience with computer programming or engineering, including signal processing or interface technologies.

Claim Constructions

1. “Said contact interaction being comprised of an impact on said mounting surface”

The court construed “impact” to include both a direct and an indirect impact. The claim did not say that the impact had to be direct, and the patent’s preferred examples included impacts transmitted through a wall or table. The court also found that Haptic’s prosecution-history statements distinguished physical from nonphysical interactions but did not clearly disclaim indirect impacts.

2. “Terminal device”

The court construed this term to mean “the device being controlled.” It rejected Apple’s proposed construction, “a remote device.” The patent’s claims and specification repeatedly described the terminal device as the device controlled by the system, and the court concluded that “independent from” did not necessarily mean physically remote.

3. “Processing module”

The court held that this term has its plain and ordinary meaning and needed no construction. It rejected Apple’s argument that the term was a function-based limitation governed by 35 U.S.C. § 112(f), a provision that can require a claim to be tied to disclosed structure when it describes a function rather than structure. The court found that the patent described the processing module’s connections, location, inputs, outputs, and operations sufficiently for a skilled person to understand it as a structural component. The court also stated that Apple had waived any alternative construction.

4. “Additional receiving module”

The court held that this term does not invoke § 112(f), is governed by its plain meaning, and needed no construction. The patent described the receiving module as a component of the terminal device that receives the command from the server.

5. “Routing module”

The court held that § 112(f) does not apply and that the term’s plain meaning governs. It concluded that a skilled person would understand “routing module” as referring to a router, rather than merely any device capable of performing a routing function.

6. “Output module”

The court held that this term is not a function-based limitation under § 112(f) and needed no construction. The patent described the output module as a server component connected to the processing module that transmits a command to the receiving module of the terminal device.

7. “Engagement means”

The parties agreed that this term is governed by § 112(f), so the court identified the claimed functions and the corresponding structures disclosed in the patent. The functions are engagement, attaching or holding the housing to the mounting surface, transmitting data signals to the sensor, and connecting the sensor to the housing’s attachment means to set the sensor’s rigid position relative to the mounting surface.

The corresponding structures include adhesive, mechanical fasteners, or threaded screws, together with transmission portion 28. The transmission portion must be made of a material with flexibility different from the mounting surface, must reduce damping, and may include one or more of: (1) frames and brackets 38, (2) an injection-molded frame comprising a rigid material, or (3) a spring-loaded portion. The court also included equivalent structures.

The court adopted Haptic’s proposed function because the claim required signals to be generated through the transmission portion, but did not require that the signals be transmitted from the attachment means to the sensor. It rejected Apple’s attempt to add that limitation. The court further held that reducing damping was part of the required structure’s function, including for the injection-molded-frame embodiment.

Result and Next Step

The court entered the listed constructions, including “no construction necessary” for four module terms. The order disposed of Docket Nos. 101, 119, and 121. It also set a further case-management conference for February 20, 2025, with an updated joint statement due one week beforehand. The opinion does not decide infringement or the ultimate validity of the patent.