Haptic, Inc. v. Apple, Inc.

Background

Haptic alleged that it owns 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 on a mounting surface, a server identifies a corresponding gesture pattern, and a terminal device performs an associated command. Haptic alleged that its Knocki product uses this type of tap-based control system.

Haptic accused Apple’s Back Tap feature of directly and indirectly infringing at least claims 1, 2, 4, 5, and 9 of the patent. Back Tap allows an iPhone user to tap the back of the handset to perform functions on the iPhone and control external devices. Haptic alleged that double-taps and triple-taps on the back of an iPhone are contact interactions that impact the claimed mounting surface, and that the iPhone’s accelerometer detects those interactions.

Apple moved to dismiss under Federal Rule of Civil Procedure 12(b)(6). That rule permits dismissal when a complaint does not provide enough factual allegations to support a legally recognized claim.

Direct Infringement

Apple argued that Haptic had not plausibly alleged the patent limitation requiring an “impact on said mounting surface.” Apple contended that the claimed mounting surface was inside the iPhone and could be reached only by opening the device and removing its back cover and battery. Apple also urged the court to interpret “impact on” as requiring a direct impact on the mounting surface.

The court declined to resolve that claim-meaning dispute at the motion-to-dismiss stage, before claim construction. At the pleading stage, the court gives patent claims their broadest reasonable construction for purposes of evaluating the complaint. The court concluded that Haptic’s allegations were not necessarily inconsistent with infringement under Apple’s preferred interpretation and denied Apple’s motion to dismiss the direct-infringement claim.

Contributory Infringement

Contributory infringement is a form of indirect patent infringement involving the sale or offer to sell a component that is especially made or adapted for infringing use, with knowledge of the patent and infringement, and without a substantial noninfringing use. Apple argued that Haptic had not adequately alleged an infringing material component, that the component lacked a substantial noninfringing use, or that Apple knew Back Tap users were infringing.

Haptic identified Back Tap’s interfacing elements in Apple’s HomeKit technology as the relevant material components. Haptic alleged that Back Tap can control third-party external devices and Apple HomeKit-compatible devices through Apple’s Shortcuts feature and Home application. The court found that these allegations sufficiently identified an infringing material component.

Haptic also alleged that Apple had contacted Haptic in 2016 to discuss partnership opportunities, learn more about Knocki, discuss Haptic’s pending patent application, and consider integrating the Knocki interface with Apple’s ecosystem. Haptic further alleged that Apple later integrated Haptic’s technology into Apple products when it launched Back Tap. The court held that these allegations supported reasonable inferences that Apple knew of the patent, made Back Tap to infringe it, knew of the alleged infringement, and that Back Tap lacked a substantial noninfringing use. The court therefore denied Apple’s motion to dismiss the contributory-infringement claim.

Disposition

The court denied Apple’s motion to dismiss. It also vacated the scheduled hearing because oral argument was unnecessary and stated that the order disposed of Docket Nos. 13 and 70. The order addressed whether Haptic had plausibly pleaded its claims; it did not decide whether Apple ultimately infringed the patent.