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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`IMMERSION CORPORATION,
`Patent Owner.
`____________
`
`Case IPR2016-01372 (Patent 8,659,571 B2)
`Case IPR2016-01381 (Patent 8,773,356 B2)
`____________
`
`Record of Oral Hearing
`Held: October 5, 2017
`____________
`
`
`
`
`Before MICHAEL R. ZECHER, BRYAN F. MOORE, NEIL T. POWELL,
`and MINN CHUNG, Administrative Patent Judges.
`
`
`
`
`
`
`Case IPR2016-01372 (Patent 8,659,571 B2)
`Case IPR2016-01381 (Patent 8,773,356 B2)
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`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`ROBERT C. WILLIAMS, ESQUIRE
`BRIAN K. ERICKSON, ESQUIRE
`JAMES HEINTZ, ESQUIRE
`DLA Piper
`401 B Street
`
`Suite 1700
`San Diego, California 92101-4297
`
`
`
`ON BEHALF OF PATENT OWNER:
`
`
`BABAK REDJAIAN, ESQUIRE
`MICHAEL R. FLEMING, ESQUIRE
`RICHARD M. BIRNHOLZ, ESQUIRE
`Irell & Manella, LLP
`4622 N. Dittmar Road
`Arlington, Virginia 22207
`
`
`
`The above-entitled matter came on for hearing on Thursday, October
`
`5, 2017, commencing at 1:00 p.m., at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`Case IPR2016-01381 (Patent 8,773,356 B2)
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`P R O C E E D I N G S
`- - - - -
`JUDGE POWELL: Good afternoon. We are here today for oral
`argument in IPR2016-01372 and IPR2016-01381. IPR2016-01372 involves
`U.S. patent number 8,659,571 B2. IPR-01381 involves U.S. patent number
`8,773,356 B2.
`The institution decision for the 1372 case was issued by Judges
`Zecher, Moore and Chung. The institution decision for the 1381 case was
`issued by Judges Zecher, Powell and Chung. In order to conduct the oral
`argument for the cases efficiently, all four judges join us today. But we note
`that we plan to have the final decision for each case issued by the same panel
`that issued the institution decision. So the final decision for the 1372 case
`will be issued by Judges Zecher, Moore and Chung, and the 1381 case will
`be Judges Zecher, Powell and Chung.
`In the hearing room with us today I have Judges Zecher and
`Moore. And Judge Chung joins us remotely from California.
`With that, can petitioner -- can counsel state their names for the
`record, starting with petitioner.
`MR. ERICKSON: Good afternoon, Your Honor. Brian Erickson
`with the law firm of DLA Piper representing petitioner. I'm backup counsel
`in the 01381 IPR. With me today are Jim Heintz, also from DLA, who is
`lead counsel in both IPRs, and Rob Williams, who is backup counsel in the
`01372 IPR. Also with us today is Kim Moore from Apple, petitioner.
`JUDGE POWELL: Thank you. And patent owner.
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`MR. FLEMING: Yes, Your Honor. I'm Mike Fleming with the
`law firm of Irell & Manella. And we represent the patent owner, Immersion
`Corporation. With me is Richard Birnholz, with Irell & Manella, and also
`Babak Redjaian, also with Irell & Manella. And also I have Kathryn Marsh,
`in-house counsel with Immersion Corporation.
`JUDGE POWELL: Very good. Thank you. So before we start
`with the arguments, I wanted to note that we received the parties' filings
`objecting that certain papers and demonstratives contained improper new
`arguments and/or evidence. As we prepare the final decisions for these
`cases, we will carefully consider those objections and vigilantly evaluate the
`contentions for improper new arguments. For today, though, each party may
`refer to anything that's in its briefing papers and anything in the
`demonstratives. As I said, we'll sort it out in the process of issuing finals.
`Now, as far as presenting and hearing the arguments, we've got
`two options. One option is we could have the petitioner present on both
`cases its case in chief followed by the patent owner presenting its case on
`both cases and then the petitioner rebutting on both cases kind of
`collectively.
`The second option is that we could do the 1372 case first, both
`sides, and then subsequently do the 1381 case, both sides. Hopefully that's
`clear.
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`And with that, does petitioner have a preference between those
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`two?
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`MR. ERICKSON: Your Honor, we had prepared under the
`assumption we would be going with the first option, but we're certainly
`happy to go with whatever the Board prefers.
`JUDGE POWELL: Does patent owner have a preference?
`MR. FLEMING: We do, Your Honor. We would prefer to have
`each one separately because they are separate and different issues for each
`patent.
`
`JUDGE POWELL: Okay. If you are sure that's okay with
`petitioner, we'll go that way with it.
`With that, then, the petitioner will start, and petitioner has
`30 minutes -- we are going the give you 30 minutes of argument time for the
`1372 case. And you may reserve as much as you would like for rebuttal.
`MR. WILLIAMS: Your Honors, Rob Williams with DLA Piper
`on behalf of petitioner. I have hard copies of the demonstratives for the
`1372 case if Your Honors would like. And may we approach?
`JUDGE POWELL: Sure. Would you like to reserve time for
`rebuttal?
`MR. WILLIAMS: Yes, Your Honor. I believe I'll go roughly
`15 minutes, give or take, on opening and reserve the remainder for rebuttal.
`JUDGE POWELL: Okay.
`MR. WILLIAMS: Good afternoon. As I mentioned, Rob
`Williams with DLA Piper representing petitioner, Apple, in IPR2016-01372.
`This IPR relates to the '571 patent. If we go to slide 2, please, the title of
`slide 2 lists the claims instituted in this IPR. The body of the slide lists or
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`includes claim 1, which is representative of the independent claims in the
`'571 patent.
`Now, the '571 patent generally relates to a method for generating a
`dynamic haptic effect as recited in claim 1. The method includes receiving
`first and second gesture signals, generating a dynamic interaction parameter
`based on those signals, and then applying a drive signal to generate a haptic
`effect according to the dynamic interaction parameter.
`If we go to slide 3, please, slide 3 lists the constructions, the
`relevant claim constructions adopted by the Board in its institution decision.
`And I'll note that the patent owner's primary dispute in this IPR relates to the
`term "gesture signal" which the Board construed as a signal indicating a
`movement of the body that conveys meaning or user intent.
`JUDGE CHUNG: Counsel, this is Judge Chung from the Silicon
`Valley office. I just wanted to confirm that petitioner agrees with these
`constructions that we have preliminarily adopted in our institution.
`MR. WILLIAMS: Yes, Your Honor. Petitioner has applied in its
`reply papers the construction as adopted by the Board. In its reply paper
`petitioner has not challenged that construction in this proceeding.
`JUDGE CHUNG: Thank you.
`MR. WILLIAMS: Turning to slide 4, there's one grounded issue
`in this IPR, and that's that the instituted claims are all obvious in view of the
`Burrough reference. The Burrough reference teaches a method of providing
`haptic feedback on a multi-touch input device such as a touchscreen.
`Slide 5, please, in one embodiment depicted in a series of figures,
`Figures 12, Burrough discloses a zoom or a pinch-to-zoom interaction with a
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`touchscreen. Specifically, as you can see in Figure 12B on the left, the user
`has placed two fingers on the touchscreen on a displayed object, on this case
`a map of North America; and in Figure 12C, the user has moved the two
`fingers apart to zoom in on a portion of the map, in this case, California.
`Turning to slide 6, Burrough further discloses generating a
`dynamic haptic effect which varies based upon the user's interaction with the
`device. In particular, Burrough teaches that there is a haptic effect at each
`finger denoted by a haptic response, H(d), whose magnitude varies as the
`function of the distance between the user's fingers. And you can see at the
`bottom of each of the figures there are two graphs.
`One in each figure is circled in red. The magnitude of the haptic
`effect H(d) varies as a function of the distance such that when the distance is
`small, the magnitude of that haptic response H(d) is similarly small. As
`distance increases, the haptic effect correspondingly increases.
`Slide 7, please, as I mentioned, patent owner's primary dispute in
`this IPR relates to the first and second gesture signal limitations. And patent
`owner's arguments really turn on the construction of gesture signal which, as
`I mentioned, were construed in its institution decision. I'll note at the outset
`that either under the Board's actual construction or under patent owner's
`interpretation, Burrough still discloses gesture signals. We'll get into that in
`a moment.
`Slide 8, please. First I would like to talk a little bit about patent
`owner's interpretation of gesture signal. While patent owner purports to
`apply the Board's construction from its institution decision, its interpretation
`is actually inconsistent with the plain language of the construction and even
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`the patent specification. Specifically, patent owner and its expert argue that
`a gesture signal needs to do two things. First, it needs to indicate a
`movement of the body, and second, it also needs to convey meaning or user
`intent.
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`If you turn to slide 9, please, that's not what the Board's
`construction actually requires. And I have included an excerpt from the
`institution decision at 9 that summarizes the Board's conclusion. In the
`institution decision, the Board concluded that a gesture signal is simply a
`signal indicating a gesture and noted that the patent, the '571 patent,
`expressly defines what a gesture is. We can see that at the bottom of the
`slide. The patent finds a gesture as a movement of the body that conveys
`meaning or user intent. Accordingly, the institution decision concluded that
`a gesture signal is simply a signal indicating a movement of the body that
`conveys meaning or user intent.
`On slide 10, I have included a graphical representation of the
`Board's conclusion. The Board determined that a gesture signal is simply a
`signal indicating a gesture. The patent defines what a gesture is. Plugging
`that definition into the Board's conclusion, the Board's construction is a
`signal indicating a movement of the body that conveys meaning or user
`intent.
`
`Now, from a grammatical perspective, grammatically the clause
`that conveys meaning user intent modifies the immediately preceding clause,
`a movement of the body. So from just the perspective of pure grammar,
`what the Board's construction indicates is that the movement of the body is
`what conveys meaning or user intent. Not the signal.
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`But to the extent there's any ambiguity here, the Board's reasoning
`in arriving at this construction resolves that ambiguity. And specifically the
`phrase that conveys meaning or user intent comes from the patent's
`definition of what a gesture is. And the gesture is a movement of the body
`that conveys meaning or intent. The gesture signal is simply a signal
`indicating that gesture.
`If we turn to slide 11, please, patent owner's interpretation is
`inconsistent with both the plain language of the Board's construction and the
`reasoning in arriving at this conclusion. What patent owner argues is that
`the signal needs to convey meaning or user intent and not the movement of
`the body. In effect, patent owner is trying to rewrite the Board's
`construction to a signal indicating a movement of the body and that conveys
`meaning or user intent. But that's not what the Board construed this term to
`mean.
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`If we could skip to slide 13, please, I'll note that patent owner's
`interpretation also is inconsistent with the '571 patent specification as it
`would exclude the Figure 9 embodiment. Specifically, the Figure 9
`embodiment discloses a swipe gesture on a touchscreen where a user may
`swipe a finger across the screen in order to scroll between displayed
`photographs.
`Slide 14, please, the patent specification, the '571 patent
`specification describes how this swipe gesture is implemented. Specifically
`during the swipe gesture, the touchscreen generates multiple inputs. The
`patent explains that each of multiple inputs may occur at a different time and
`may indicate a different two-dimensional position of the finger on the
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`touchscreen. In other words, each of the inputs is a single indication of the
`location of the finger at a particular point in time.
`Now, under the Board's construction, each of these inputs is a
`gesture signal. In fact, I'll note that in the institution decision at 9, the Board
`specifically cited to this embodiment in support of its construction.
`Go back to slide 12, please, under patent owner's interpretation, the
`touchscreen signals in figure 9 would presumably not be gesture signals.
`Here in this patent owner response at 9, patent owner argues at least in the
`context of Burrough, analogous touchscreen signals S are a single indication
`that a finger has contacted the screen at a particular location. And according
`to the patent owner, well, those types of signals don't indicate an intent.
`Patent owner further argues that in Burrough you would need
`multiple of these signals in order to draw the conclusion that a user is
`attempting to zoom in or zoom out. But the same would be true of the
`signals in Figure 9. As I mentioned, the signals in Figure 9 are simply single
`indications of where the finger is at a particular point in time. And you
`would need multiple of those in order to draw conclusions about the user's
`intent: Is the user trying to swipe right? Is the user trying to swipe left?
`From a single point, one might not be able to figure out what that intent is.
`So under patent owner's interpretation of gesture signal, at least as they are
`applying it to the Burrough reference, it would exclude the embodiment of
`Figure 9 improperly.
`If we could jump ahead to slide 15, please, so as I mentioned
`earlier, Burrough discloses first and second gesture signals either under the
`Board's actual construction or under patent owner's interpretation. But let's
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`start with the Board's actual construction. There's no dispute that the
`pinch-to-zoom interaction on a touchscreen is a gesture. It's a movement of
`the body of the user's finger. It conveys intent. The intent is to zoom in or
`zoom out. Patent owner doesn't dispute that.
`If we could turn to slide 16, please, Burrough also discloses that
`touchscreen sensors generate gesture signals such as the signals S.
`Specifically, Burrough teaches that when a user touches on the touchscreen,
`the touch sensor or sensing device 124 generates touch signal S1 and any
`other signal consistent with a multi-touch event.
`Slide 17, please, both parties' experts agree that the touch sensor in
`Burrough generates signals for each finger at each instant in time. The
`experts referred to the signals, for example, when a user first touches the
`screen in Figure 12B as signals S1 and S2. And in Figure 12C when the
`user has moved two fingers apart, the experts refer to the those signals as S3
`and S4.
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`Now, each of these signals is a gesture signal under the Board's
`construction because these signals indicate the zoom gesture. In other
`words, a movement of the body, the user fingers, that conveys the intent of
`the user to zoom in or zoom out.
`If we can turn to slide 18, please, now, patent owner argues that the
`signals S1, S2, S3 and S4, those can't be gesture signals, at least under their
`interpretation of gesture signal, because the signals themselves do not
`convey intent. According to patent owner, you need multiple of these
`signals in order to convey the intent to zoom in or zoom out.
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`But patent owner made this same argument in its preliminary
`response and the Board already addressed it and rejected it in the institution
`decision specifically noting that under the Board's construction, the Board's
`construction does not exclude conveying meaning user intent in conjunction
`with other gesture signals. In other words, you can look at a number of
`signals collectively in order to draw conclusions about what the intent is.
`And of course, that's consistent with the Figure 9 embodiment we just talked
`about in which a user is performing a swipe gesture that generates multiple
`signals over time, which when viewed collectively, reveals the user's intent
`or conveys the user's intent to swipe.
`If we go to slide 19, please, as I mentioned, Burrough discloses
`first and second gesture signals under the Board's actual construction, but it
`also discloses first and second gesture signals under patent owner's
`interpretation. The zoom gesture in Burrough is a complex gesture which
`may be comprised of multiple simple gestures. For example, simple
`gestures might include things like finger down gestures or finger move
`gestures. For example, at paragraph 81, Burrough teaches that the set down
`of the fingers will associate or lock the fingers to the particular GUI object
`being displayed. In other words, bringing the fingers into contact with the
`screen, as we see in Figure 12B, is interpreted by Burrough as a simple
`gesture which locks the particular displayed object to be zoomed.
`In other words, bringing fingers into contact with the screen
`conveys an intent while perhaps not the intent to zoom. Nonetheless, it
`conveys the intent of the user to contact the screen at a particular location.
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`Similarly, the movement of the fingers conveys an intent to zoom in or zoom
`out on the displayed object.
`If we go to slide 20, please, and I'll note that the '571 patent
`expressly contemplates that complex gestures may be comprised of simple
`gestures. In fact, one of the very examples described in the '571 patent is
`what is referred to as a finger on gesture in which bringing a finger into
`contact with the touchscreen, according to the '571 patent, constitutes a
`simple gesture called finger on.
`So even under patent owner's interpretation, the set down of
`fingers would convey meaning or intent. Perhaps not the intent to zoom, but
`the intent to lock on to a particular object. Similarly, the movement of the
`fingers conveys an intent. In this case, the intent to zoom in or zoom out,
`depending on whether the fingers are moving together or apart.
`JUDGE CHUNG: Counsel, so patent owner argues that not every
`touch on a touchscreen can be to indicate gesture because you may have
`accidental and unintentional touching. So how do you get to the conclusion
`that the touches that's described in Burrough, the zoom gesture, those
`touches relate to gesture? They are not merely -- just looking at the signals
`coming from touches, how do you get from those signals to a gesture?
`MR. WILLIAMS: Well, Your Honor, I think what we would need
`to do is look at the context in which those touches occur. In the context of
`the specific embodiment disclosed in Burrough, the set down of the fingers
`is described in the reference itself as locking to a particular displayed object.
`And that's the displayed object that's going to be zoomed. So if you have
`three or four objects on the screen, you want to zoom in on one of them,
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`well, Burrough teaches that the set down of the fingers indicates the intent of
`which you want to zoom in to or out of.
`Now, an accidental touching, perhaps in a different context or even
`a particular different interaction which is unrelated to the pinch-to-zoom
`gesture may not be a signal that conveys intent. I'll give you an example.
`Let's imagine, for example, that in the context of the Burrough embodiment
`which recognizes a pinch-to-zoom interaction, a user instead tried to draw a
`circle on the screen. Now, the user may intend to draw a circle or a letter or
`any other -- the user may have such intent in mind of what they would like
`to do on the device, but that doesn't meet the profile of a gesture that can be
`conveyed to the device, well, while that would not be an example of a
`gesture signal. It doesn't convey meaning or user intent to the device. So
`that, to me, is the distinction.
`JUDGE POWELL: You have used a little over 17 minutes. You
`are welcome to keep going, but I just thought I would remind you.
`MR. WILLIAMS: Thank you, Your Honor. At this point I'll
`reserve the rest of my time for rebuttal. I'll note that I have a number of
`slides on the other issues that patent owner has raised in its papers, but in the
`interest of time, I'll save that for rebuttal.
`JUDGE POWELL: Okay.
`MR. FLEMING: Good afternoon, Your Honors. May I have slide
`2, please. I would like to cover these topics, claim construction, also our
`argument that Burrough's S signals are not gesture signals in the zoom
`embodiment. Also, I would like to cover that Burrough's zoom does not
`teach a first gesture signal and a second gesture signal. And finally, for
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`claim 2, I want to point out that Burrough's zoom does not teach gesture
`signals that include magnitude and direction.
`May I have slide 4, please. Let's turn to claim construction. Can I
`have slide 5, please. Indeed the claim does require a first gesture and a
`second gesture. May I have slide 6, please. Indeed the Board did construe
`the claim to say that a gesture indicates the movement of a body that
`conveys meaning or user intent. And as we had pointed out, we believe that
`the Board is construing the claim in terms of that the gesture signal must do
`both, indicate the movement of the body and convey user intent.
`The '571 patent, the computer system creates a gesture signal that
`indeed does both. And if I could have slide 7, please, this is consistent with
`the specification. First off, the spec does define a gesture. But second, the
`spec makes clear that the gesture signals are different than the device sensor
`signals that just indicate the movement of the body. So the gesture signal is
`more than just a device sensor signal.
`Can I have the '571 --
`JUDGE CHUNG: Counsel, this is Judge Chung from Silicon
`Valley. So patent owner agrees that the specification of the '571 patent
`defines the term "gesture" as any movement of the body that conveys
`meaning or intent?
`MR. FLEMING: Yes, Your Honor.
`JUDGE CHUNG: And in terms of the construction, the same
`question I asked petitioner, that do you agree with our preliminary
`construction in our decision on institution defining a gesture signal as a
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`signal indicating a movement of the body that conveys meaning or user
`intent?
`
`MR. FLEMING: Your Honor, we agree with it in the sense that it
`requires a signal that does both, both indication of the movement of the body
`and also that the signal conveys user intent or meaning.
`And Your Honor, may I please point to the specification to make
`my point here that when you read it in light of the specification, the
`reasonable interpretation would be that it requires both. So if I could have
`the '571 abstract up, please, in the second sentence, the patent makes clear
`that there is a distinction between gesture signals and sensor signals. So the
`gesture signal is more than just a device sensor signal. Also, if you notice,
`the sensor signals can have indications of movement of the body.
`So may I go to column 13, 38 through 41, please. Here the
`specification explains that, in fact, you combine gestures with gesture
`signals to create a haptic effect. So there must be a difference between the
`two.
`
`Also, these device sensor signals can be the movement of the body.
`For example, heart rate, human activity such as walking or running. Here,
`let me show you columns 11 and 12 up on the screen. If we can zoom in to
`column 11, 7 through 17, there you see that the device sensors may be a
`whole host of sensors that are providing indications of movement of the
`body. Now, for instance, you have blood pressure and heart rate. If we
`could also go to the Table 1, there you see there's a whole host of device
`sensors that are providing all sorts of movements of the body.
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`Also, if we could go to column 12, 23 through 25, and we zoom in
`to that, you see that the sensors also provide that the user is engaged in
`physical activity such as walking or running. So when you take it in the
`context of the specification, there must be something different about a sensor
`that provides just simply the movement of the body and a gesture that
`provides the movement of the body that also conveys intent.
`JUDGE CHUNG: Counsel, doesn't your argument really go to
`what the movement of the body indicates rather than what signal indicates?
`You know, as long as the movement of the body indicates the intent or
`meaning, wouldn't that satisfy the definition of the gesture?
`MR. FLEMING: No, Your Honor. The gesture signal must
`convey a meaning or intent to be a gesture as well as the movement of the
`body. Whereas, as I just pointed out, there is many points of which you
`have sensors that are providing movement of the body but are not going to
`be a gesture signal. So as a result, what you need is a signal that indicates
`it's going to be a gesture signal by saying you are conveying meaning or
`intent of what the user wants to do with the interaction with the computer.
`JUDGE MOORE: Counsel, petitioner, in its presentation, argued
`that the embodiment of Figure 9A, B and C would be excluded based on
`your reading of the construction. Can you speak to that issue.
`MR. FLEMING: Yes, Your Honor. May I have slide 11, please. I
`want to point out that Apple has misconstrued what we had said in our
`patent owner's response. In fact, the entire quote shows that, in fact, what
`we are saying is the expert is saying that we are having to have both
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`meaning and -- convey a meaning and intent as well as moving the body.
`And they are pointing to the scrolling.
`That's misplaced because indeed, when you are scrolling between
`those photos, what you are having is you are having a movement of the
`body, of the finger touching the screen, but you are also conveying intent
`that you are moving from one photo to the next. So that conveying an intent
`shows that you want to select the next photo. So that computer system then
`does recognize that and provides -- conveys the intent to move to the next
`photo.
`
`JUDGE MOORE: So in that scenario, what would be the two -- as
`required by the claims, two signals?
`MR. FLEMING: Your Honor, that embodiment there we are
`talking about -- I'm sorry, you are asking what is the two -- the first and
`second haptic signals?
`JUDGE MOORE: Right, as required by the claim. No, the first
`gesture signal and the second gesture signal in that gesture you were just
`describing.
`MR. FLEMING: So Your Honor, what is covered there is that you
`have an indication of the touching of the screen but also knowing that you
`are touching that first photo. That's the first gesture signal. And then you
`are moving it to the second photo, which then is showing that you have
`moved across to the next photo. And you are having a second gesture which
`is saying, okay, now you are touching the screen and you are conveying to
`us that you want that photo to be displayed.
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`JUDGE CHUNG: Counsel, so you were saying that the gesture
`that's described in Figures 9A to C is a swipe gesture, as explained. And
`you just explained that the first gesture is touching the photograph and
`second gesture is moving the finger across; is that right?
`MR. FLEMING: That's correct.
`JUDGE CHUNG: So that's what you identify as two distinct
`separate gestures that conveys -- each conveying intent or meaning?
`MR. FLEMING: Right.
`JUDGE CHUNG: So if a single gesture touching an object and
`swiping across screen provides -- satisfies the claim, I'm not seeing how
`that's different from zoom gesture that's described in Burrough.
`MR. FLEMING: Your Honor, in fact, let me just jump to
`Burrough, if you don't mind. I believe it's slide 14, please. If you look at
`Burrough, you have a touching on step 1102. At that point you do not
`convey intent to zoom.
`JUDGE CHUNG: But you may convey intent to select an object
`to be zoomed similar to the swipe gesture.
`MR. FLEMING: That is not what's disclosed in Burrough, in fact.
`What Burrough is disclosing is, okay, at that point you are detecting a touch
`of the two fingers. That's all you are detecting. And it's not until you get to
`step 1110 where the figures then have been determined that they are moving
`together or moving apart that you indeed have a gesture.
`So if I could go to slide 15, please, this is confirmed by the
`Burrough's hardware. Burrough, if you look at sensing device 124, that
`provides S1 data signals that are only indicating a touch, the location at a
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`point in time on the screen. And when the finger touches the sensing device
`124, it's active. Can I have slide 16, please. So then once the sensor 24
`generates the S signal, it indicates the user's finger location on the screen at
`that moment in time. If I could have slide 17, please. Then it's only until
`you hit processor 106 that the processor converts these S signals into a Tinfo
`s
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