EXHIBIT A9 PAGE 1 OF 30
`SMITH INTERFACE TECHNOLOGIES, LLC’S
`PATENT L.R. 3.1 PRELIMINARY INFRINGEMENT CONTENTIONS
`
`EXHIBIT A9 - U.S. Patent No. 10,936,114 (iPhone)
`Claims 1, 27, 30, and 32
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`Smith Interface Technologies, LLC (“Smith Interface”) accuses Apple of infringing claims 1, 27, 30, and 32 of U.S. Patent No. 10,936,114
`(hereinafter “the 114 Patent”). Pursuant to Patent L.R. 3.1(c), Smith Interface provides the following claim chart.
`
`This claim chart identifies specifically where each element of each Asserted Claim is found within each Accused Instrumentality and
`provides Apple’s notice of identified instrumentalities (including “the Accused System”) that incorporate or reflect the recited claim elements.
`This claim chart is not intended to be an expert report on infringement or provide detailed analysis of the claim terms or infringement. This claim
`chart includes information related to an assertion of infringement with respect to the *114 Patent Accused Products identified, including diagrams,
`web page screenshots, and other documentary evidence by way of example and not by way of limitation.
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`The Asserted Claims include elements that are implemented, at least in part, by instrumentalities described in confidential information not
`accessible to Plaintiff. In some instances, the precise processes and algorithms used are, at least in part, not publicly available. An analysis of
`Apple’s (or other third parties’) technical documentation and/or software source code may be necessary to more fully identify all infringing
`features and functionality. Accordingly, Smith Interface reserves the right to supplement these contentions once such information is made available
`to Smith Interface. Furthermore, Smith Interface reserves the right to revise these contentions, as appropriate, upon issuance of the Court’s Claim
`Construction Order.
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`The claim chart refers to the Accused System and the aforementioned products are included in (or can operate in conjunction with) the
`Accused System, as noted in the claim chart. To the extent the below claim chart relies on evidence for the Accused System, Smith Interface
`asserts that, on information and belief, any similarly-functioning system also infringe the charted claim. Smith Interface reserves the right to
`amend these infringement contentions with other products made, used, sold, imported, or offered for sale by Apple. Smith Interface also reserves
`the right to amend these infringement contentions by citing other claims of the *114 Patent, not listed in the claim chart, that are infringed by the
`Accused System. Smith Interface further reserves the right to amend these infringement contentions by adding, subtracting, or otherwise modifying
`content in the “Accused System” section.
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`To the extent there are any differences between the accused instrumentalities and the following claim elements, any such differences are
`insubstantial and are alleged to infringe under the doctrine of equivalents.
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`APPLE 1024
`Apple v. Smith Interface
`1 IPR2024-01091
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`EXHIBIT A9
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`PAGE 2 OF 30
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`Claim
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`Claim Elements
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`Exemplary Accused System (Apple iPhone 14 Pro, iOS 16)
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`11
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`(a) An apparatus,
`comprising:
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`at least one non-transitory
`memory storing instructions
`and a plurality of
`applications;
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`a touch screen; and
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`one or more processors in
`communication with the at
`least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute the
`instructions to:
`
`Apple iPhone 14 Pro smartphones comprise at least one non-transitory memory (e.g., 128MB, 256MB,
`512MB, or 1TB, etc.) storing instructions and a plurality of applications, a touch screen (e.g., Super
`Retina XDR display, etc.); and one or more processors (e.g., A16 Bionic chip, etc.) in communication
`with the at least one non-transitory memory and the touch screen.
`
`See the evidence above and below, for example:
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`! Each element of the independent claims incorporates all elements of the independent claim. For example, any evidence provided in claim 1
`element (a) incorporates all claim elements 1(b)-(f).
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`EXHIBIT A9
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`PAGE 3 OF 30
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`https://www.apple.com/iphone-14-pro/specs/
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`A16 Bionic chip
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`vith 2 performance and 4 efficiency cores
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`16-core Neural Engine
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`(b) display, via the touch
`screen, an object and at
`least a portion of an
`interface;
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`Apple iPhone 14 Pro smartphones are designed to display, via the touch screen (e.g., Super Retina
`XDR display, etc.), an object (e.g., one or more controls of Control Center, etc.) and at least a portion
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`of an interface (e.g., Control Center interface,
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`etc.);
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`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 4 OF 30
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`(c) detect a gesture on the Apple iPhone 14 Pro smartphones are designed to detect a gesture on the touch screen (e.g., Super
`touch screen on the object; | Retina XDR display, etc.) on the object (e.g., one or more controls of Control Center, etc.);
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`EXHIBIT A9
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`PAGE 5 OF 30
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`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 6 OF 30
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`(d) when a magnitude of a | Apple iPhone 14 Pro smartphones are designed to, when a magnitude of a duration of the gesture being
`duration of the gesture detected on the touch screen (e.g., Super Retina XDR display, etc.) on the object (e.g., one or more
`being detected on the touch | controls of Control Center, etc.) is less than a first magnitude threshold, perform an operation,
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`screen on the object is less
`than a first magnitude See the evidence above and below, for example:
`threshold, perform an
`operation;
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`EXHIBIT A9
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`PAGE 7 OF 30
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`(e) when the magnitude of
`the duration of the gesture
`being detected on the touch
`screen on the object is
`
`Apple iPhone 14 Pro smartphones are designed to, when the magnitude of the duration of the gesture
`being detected on the touch screen (e.g., Super Retina XDR display, etc.) on the object (e.g., one or
`more controls of Control Center, etc.) is greater than the first magnitude threshold, perform a scaling
`in connection with at least the object, where the scaling includes a reduction in a size such that the size
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`EXHIBIT A9
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`PAGE 8 OF 30
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`greater than the first
`magnitude threshold,
`perform a scaling in
`connection with at least the
`object, where the scaling
`includes a reduction in a
`size such that the size is
`inversely related to the
`magnitude of the duration
`of the gesture being
`detected on the touch screen
`on the object; and
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`is inversely related to the magnitude of the duration of the gesture being detected on the touch screen
`on the object;
`
`See the evidence above and below, for example:
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`(f) when the magnitude of
`the duration of the gesture
`being detected on the touch
`screen on the object is
`greater than a second
`magnitude threshold,
`perform another operation.
`
`Apple iPhone 14 Pro smartphones are designed to, when the magnitude of the duration of the gesture
`being detected on the touch screen (e.g., Super Retina XDR display, etc.) on the object (e.g., one or
`more controls of Control Center, etc.) is greater than a second magnitude threshold, perform another
`operation.
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`See the evidence above and below, for example:
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`EXHIBIT A9
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`PAGE 9 OF 30
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`Airplane Mode Cellular Data
`off On
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`Bluetooth
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`27
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`(a) An apparatus,
`comprising:
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`Apple iPhone 14 Pro smartphones comprise at least one non-transitory memory (e.g., 128MB, 256MB,
`512MB, or 1TB, etc.) storing instructions and a plurality of applications; a touch screen (e.g., Super
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`EXHIBIT A9 PAGE 10 OF 30
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`Retina XDR display, etc.); and one or more processors (e.g., A16 Bionic chip, etc.) in communication
`at least one non-transitory | with the at least one non-transitory memory and the touch screen, wherein the one or more processors
`memory storing instructions | execute the instructions to cause the apparatus to:
`
`and a plurality of
`applications; See the evidence above and below, for example:
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`a touch screen; and
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`one or more processors in
`communication with the at
`least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute the
`instructions to cause the
`apparatus to:
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`EXHIBIT A9 PAGE 11 OF 30
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`2 performance and 4 efficiency cores
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`https://www.apple.com/iphone-14-pro/specs/
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`(b) display an object on at | Apple iPhone 14 Pro smartphones are designed to display an object (e.g., one or more controls of
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`least a portion of an Control Center, etc.) on at least a portion of an interface (e.g., Control Center interface, etc.),
`interface;
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`See the evidence above and below, for example:
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`11
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`EXHIBIT A9 PAGE 12 OF 30
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`(c) detect a gesture via the | Apple iPhone 14 Pro smartphones are designed fo detect a gesture on the touch screen (e.g., Super
`touch screen on the object; | Retina XDR display, etc.) on the object (e.g., one or more controls of Control Center, etc.),
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`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 13 OF 30
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`(d) perform a first function | Apple iPhone 14 Pro smartphones are designed to perform a first function in a first touch state;
`in a first touch state;
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`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 14 OF 30
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`(e) perform a second Apple iPhone 14 Pro smartphones are designed to perform a second function in a second touch state;
`function in a second touch | and
`state; and
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`EXHIBIT A9 PAGE 15 OF 30
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`See the evidence above and below, for example:
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`L ((T))
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`Airplane Mode Cellular Data
`off On
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`3
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`Bluetooth
`on
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`Personal Hotspot
`off
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`(f) during detection of at Apple iPhone 14 Pro smartphones are designed such that during detection of at least a portion of the
`least a portion of the gesture | gesture and based on a change in a duration of the gesture being detected via the touch screen (e.g.,
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`EXHIBIT A9
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`PAGE 16 OF 30
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`and based on a change in a
`duration of the gesture
`being detected via the touch
`screen on the object,
`perform a scale operation in
`connection with the at least
`portion of the interface,
`where the scale operation
`includes a reduction in a
`size that is inversely related
`to the duration of the
`gesture being detected via
`the touch screen on the
`object.
`
`Super Retina XDR display, etc.) on the object (e.g., one or more controls of Control Center, etc.),
`perform a scale operation in connection with the at least portion of the interface, where the scale
`operation includes a reduction in a size that is inversely related to the duration of the gesture being
`detected via the touch screen on the object.
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`See the evidence above and below, for example:
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`(a) An apparatus,
`comprising:
`
`at least one non-transitory
`memory storing instructions
`and a plurality of
`applications;
`
`a touch screen;
`
`a vibrator; and
`
`Apple iPhone 14 Pro smartphones comprise at least one non-transitory memory (e.g., 128MB, 256MB,
`512MB, or 1TB, etc.) storing instructions and a plurality of applications; a touch screen (e.g., Super
`Retina XDR display, etc.); a vibrator; and one or more processors (e.g., A16 Bionic chip, etc.) in
`communication with the at least one non-transitory memory, the touch screen, and the vibrator,
`wherein the one or more processors execute the instructions to cause the apparatus to:
`
`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 17 OF 30
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`one or more processors in
`communication with the at
`least one non-transitory
`memory, the touch screen,
`and the vibrator, wherein
`the one or more processors
`execute the instructions to
`cause the apparatus to:
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`EXHIBIT A9 PAGE 18 OF 30
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`clency C
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`6-core Neural Engine
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`https://www.apple.com/iphone-14-pro/specs/
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`Models with haptic feedback
`e iPhone 14
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`¢ iPhone 14 Plus
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`e iPhone 14 Pro
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`¢ iPhone 14 Pro Max
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`https://support.apple.com/guide/iphone/change-sounds-and-vibrations-iphQ07c¢867128/io0s
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`(b) display a first object and | Apple iPhone 14 Pro smartphones are designed to display a first object (e.g., one or more controls of
`at least one other object; Control Center, etc.) and at least one other object;
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`See the evidence above and below, for example:
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`EXHIBIT A9
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`PAGE 19 OF 30
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`' 4
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`(c) detect a gesture on the
`touch screen on the first
`object;
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`Apple iPhone 14 Pro smartphones are designed to detect a gesture on the touch screen (e.g., Super
`Retina XDR display, etc.) on the first object (e.g., one or more controls of Control Center, etc.);
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`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 20 OF 30
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`Under My Thu...
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`(d) during detection of at Apple iPhone 14 Pro smartphones are designed such that during detection of at least a portion of the
`least a portion of the gesture | gesture before a completion thereof is detected, perform a scale operation, based on a change in a
`before a completion thereof | duration of the gesture being detected on the touch screen (e.g., Super Retina XDR display, etc.) on the
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`EXHIBIT A9
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`PAGE 21 OF 30
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`is detected, perform a scale
`operation, based on a
`change in a duration of the
`gesture being detected on
`the touch screen on the first
`object, on at least the at
`least one other object,
`where the scale operation
`includes a reduction in a
`size that is inversely related
`to the duration of the
`gesture being detected on
`the touch screen on the first
`object; and
`
`first object (e.g., one or more controls of Control Center, etc.), on at least the at least one other object,
`where the scale operation includes a reduction in a size that is inversely related to the duration of the
`gesture being detected on the touch screen on the first object.
`
`See the evidence above and below, for example:
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`(e) after at least a portion of
`the scale operation, vibrate
`the apparatus and perform
`an action.
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`Apple iPhone 14 Pro smartphones are designed such that afier at least a portion of the scale operation,
`vibrate the apparatus and perform an action.
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`See the evidence above and below, for example:
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`EXHIBIT A9
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`PAGE 22 OF 30
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`[ ((T )
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`Airplane Mode Cellular Data
`off Or
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`3
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`Bluetooth
`On
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`Personal Hotspot
`Off
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`EXHIBIT A9
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`PAGE 23 OF 30
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`Models with haptic feedback
`¢ iPhone 14
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`¢ iPhone 14 Plus
`e iPhone 14 Pro
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`¢ iPhone 14 Pro Max
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`https://support.apple.com/guide/iphone/change-sounds-and-vibrations-iph07¢867f28/ios
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`32
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`(a) An apparatus,
`comprising:
`
`at least one non-transitory
`memory storing instructions
`and a plurality of
`applications;
`
`a touch screen; and
`
`one or more processors in
`communication with the at
`least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute the
`instructions to:
`
`Apple iPhone 14 Pro smartphones comprise at least one non-transitory memory (e.g., 128MB, 256MB,
`S12MB, or 1TB, etc.) storing instructions and a plurality of applications; a touch screen (e.g., Super
`Retina XDR display, etc.); and one or more processors (e.g., A16 Bionic chip, etc.) in communication
`with the at least one non-transitory memory and the touch screen.
`
`See the evidence above and below, for example:
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`EXHIBIT A9 PAGE 24 OF 30
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`EXHIBIT A9
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`PAGE 25 OF 30
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`https://www.apple.com/iphone-14-pro/specs/
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`6-core Neura
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`vith 2 performance and 4 efficiency cores
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`Engine
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`(b) display, via the touch
`screen, a first object and at
`least one other object;
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`object;
`
`See the evidence above and below, for example:
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`Apple iPhone 14 Pro smartphones are designed to display, via the touch screen (e.g., Super Retina XDR
`display, etc.), a first object (e.g., one or more controls of Control Center, etc.) and at least one other
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`EXHIBIT A9
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`PAGE 26 OF 30
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`(c) detect at least one
`component of a gesture on
`the touch screen on the first
`object;
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`Apple iPhone 14 Pro smartphones are designed to detect at least one component of a gesture on the
`touch screen (e.g., Super Retina XDR display, etc.) on the first object (e.g., one or more controls of
`Control Center, etc.),
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`EXHIBIT A9
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`PAGE 27 OF 30
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`See the evidence above and below, for example:
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`Under My Thu...
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`“ p »
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`cee= goa=
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`(d) when a first component
`of the gesture is detected
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`Apple iPhone 14 Pro smartphones are designed to when a first component of the gesture is detected
`where a magnitude of a duration of the gesture being detected on the touch screen (e.g., Super Retina
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`EXHIBIT A9 PAGE 28 OF 30
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`where a magnitude of a XDR display, etc.) on the first object (e.g., one or more controls of Control Center, etc.) is less than a
`duration of the gesture first magnitude threshold, perform a function upon a cessation of the gesture being detected;
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`being detected on the touch | See the evidence above and below, for example:
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`screen on the first object is
`less than a first magnitude
`threshold, perform a
`function upon a cessation of
`the gesture being detected;
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`EXHIBIT A9
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`PAGE 29 OF 30
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`(e) when a second
`component of the gesture is
`detected where the
`magnitude of the duration of
`the gesture being detected
`on the touch screen on the
`first object is greater than
`the first magnitude
`threshold, perform a scale
`operation for the at least one
`other object, where the scale
`operation includes a
`reduction in a size so as to
`be inversely related to the
`magnitude of the duration of
`the gesture being detected
`on the touch screen on the
`first object; and
`
`Apple iPhone 14 Pro smartphones are designed to when a second component of the gesture is detected
`where the magnitude of the duration of the gesture being detected on the touch screen (e.g., Super
`Retina XDR display, etc.) on the first object (e.g., one or more controls of Control Center, etc.) is
`greater than the first magnitude threshold, perform a scale operation for the at least one other object,
`where the scale operation includes a reduction in a size so as to be inversely related to the magnitude
`of the duration of the gesture being detected on the touch screen on the first object;
`
`See the evidence above and below, for example:
`
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`() when a third component
`of the gesture is detected
`where the magnitude of the
`duration of the gesture
`being detected on the touch
`screen on the first object is
`greater than a second
`magnitude threshold,
`perform another function.
`
`Apple iPhone 14 Pro smartphones are designed to when a third component of the gesture is detected
`where the magnitude of the duration of the gesture being detected on the touch screen (e.g., Super
`Retina XDR display, etc.) on the first object (e.g., one or more controls of Control Center, etc.) is
`greater than a second magnitude threshold, perform another function.
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`See the evidence above and below, for example:
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`EXHIBIT A9
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`PAGE 30 OF 30
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`»-
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`Airplane Mode
`off
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`(@)
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`AirDrop
`Receiving Off
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`((T))
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`Cellular Data
`on
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`3
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`Bluetooth
`on
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`Personal Hotspot
`Off
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