EXHIBIT B7 PAGE 1 OF 23
`SMITH INTERFACE TECHNOLOGIES, LLC’S
`PATENT L.R. 3.1 PRELIMINARY INFRINGEMENT CONTENTIONS
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`EXHIBIT B7 - U.S. Patent No. 10,936,114 (iPad)
`Claims 1, 27, and 32
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`Smith Interface Technologies, LLC (“Smith Interface”) accuses Apple of infringing claims 1, 27, 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.
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`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 1025
`Apple v. Smith Interface
`1 IPR2024-01091
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`EXHIBIT B7 PAGE 2 OF 23
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`Claim Claim Elements Exemplary Accused System (Apple iPad Pro, iPadOS 16)
`1! | (a) An apparatus, Apple iPad Pro tablets comprise at least one non-transitory memory (e.g., 128MB, 256MB, 512MB,
`comprising: 1TB, or 2TB, etc.) storing instructions and a plurality of applications; a touch screen (e.g., Liquid
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`Retina display, etc.), and one or more processors (e.g., Apple M2 chip, etc.) in communication with the
`at least one non-transitory | at least one non-transitory memory and the touch screen.
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`memory storing instructions
`and a plurality of See the evidence above and below, for example:
`applications;
`iPad Pro
`a touch screen; and
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`one or more processors in
`communication with the at iPad Pro 11-inch
`least one non-transitory
`memory and the touch
`screen, wherein the one or
`more processors execute the | Finish
`instructions to:
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`Capacity’ 128GB
`256GB
`512GB
`178
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`Silver, Space Gray 2TB
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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 B7
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`PAGE 3 OF 23
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`Display
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`Chip
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`11"
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`Liquid Retina display
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`. -/
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`Liquid Retina display
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`11-inch (diagonal) LED backlit
`Multi-Touch display with IPS
`technology
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`Apple M2 chip
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`8-core CPU with 4 performance cores and 4
`efficiency cores
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`10-core GPU
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`16-core Neural Engine
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`100GB/s memory bandwidth
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`8GB RAM on models with 128GB, 256GB, or
`512GB storage
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`16GB RAM on models with 1TB or 2TB
`storage
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`https://www.apple.com/ipad-pro/specs/
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`EXHIBIT B7 PAGE 4 OF 23
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`(b) display, via the touch Apple iPad Pro tablets are designed to display, via the touch screen (e.g., Super Retina XDR display,
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`screen, an object and at etc.), an object (e.g., one or more controls of Control Center, etc.) and at least a portion of an interface
`least a portion of an (e.g., Control Center interface, etc.);
`interface;
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`See the evidence above and below, for example:
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`EXHIBIT B7 PAGE 5 OF 23
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`(c) detect a gesture on the Apple iPad Pro tablets are designed to detect a gesture on the touch screen (e.g., Super Retina XDR
`touch screen on the object; | 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 B7 PAGE 6 OF 23
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`(d) when a magnitude of a | Apple iPad Pro tablets are designed to, when a magnitude of a duration of the gesture being detected on
`duration of the gesture the touch screen (e.g., Super Retina XDR display, etc.) on the object (e.g., one or more controls of
`being detected on the touch | 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:
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`PAGE 7 OF 23
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`threshold, perform an
`operation;
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`(e) when the magnitude of
`the duration of the gesture
`being detected on the touch
`screen on the object is
`greater than the first
`magnitude threshold,
`perform a scaling in
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`Apple iPad Pro tablets 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 is
`inversely related to the magnitude of the duration of the gesture being detected on the touch screen on
`the object;
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`EXHIBIT B7 PAGE 8 OF 23
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`connection with at least the | See the evidence above and below, for example:
`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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`® = 98% mm
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`(f) when the magnitude of | Apple iPad Pro tablets are designed to, when the magnitude of the duration of the gesture being
`the 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 greater than a second magnitude threshold, perform another
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`screen on the object is operation.
`greater than a second
`magnitude threshold, See the evidence above and below, for example:
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`perform another operation.
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`EXHIBIT B7 PAGE 9 OF 23
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`27 | (a) An apparatus, Apple iPad Pro tablets comprise at least one non-transitory memory (e.g., 128MB, 256MB, 512MB,
`comprising: 1TB, or 2TB, etc.) storing instructions and a plurality of applications, a touch screen (e.g., Liquid
`Retina display, etc.), and one or more processors (e.g., Apple M2 chip, etc.) in communication with the
`at least one non-transitory | at least one non-transitory memory and the touch screen, wherein the one or more processors execute
`memory storing instructions | the instructions to cause the apparatus to:
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`and a plurality of
`applications; See the evidence above and below, for example:
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`PAGE 10 OF 23
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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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`iPad Pro
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`Finish
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`iPad Pro 11-inch
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`Capacity’
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`Silver, Space Gray
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`128GB
`256GB
`512GB
`1B
`2TB
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`10
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`PAGE 11 OF 23
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`Display
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`Chip
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`11"
`
`Liquid Retina display
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`- —J
`
`Liquid Retina display
`
`11-inch (diagonal) LED backlit
`Multi-Touch display with IPS
`technology
`
`Apple M2 chip
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`8-core CPU with 4 performance cores and 4
`efficiency cores
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`10-core GPU
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`16-core Neural Engine
`
`100GB/s memory bandwidth
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`8GB RAM on models with 128GB, 256GB, or
`512GB storage
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`16GB RAM on models with 1TB or 2TB
`storage
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`https://www.apple.com/ipad-pro/specs/
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`11
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`EXHIBIT B7 PAGE 12 OF 23
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`(b) display an object on at | Apple iPad Pro tablets are designed to display an object (e.g., one or more controls of Control Center,
`least a portion of an 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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`EXHIBIT B7 PAGE 13 OF 23
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`(c) detect a gesture via the | Apple iPad Pro tablets are designed to detect a gesture on the touch screen (e.g., Super Retina XDR
`touch screen on the object; | 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 B7 PAGE 14 OF 23
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`(d) perform a first function | Apple iPad Pro tablets 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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`(e) perform a second Apple iPad Pro tablets are designed to perform a second function in a second touch state; and
`function in a second touch
`state; and See the evidence above and below, for example:
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`PAGE 15 OF 23
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`(f) during detection of at
`least a portion of the gesture
`and based on a change in a
`duration of the gesture
`being detected via the touch
`screen on the object,
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`Apple iPad Pro tablets are designed such that during detection of at least a portion of the gesture and
`based on a change in a duration of the gesture being detected via the touch screen (e.g., 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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`PAGE 16 OF 23
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`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.
`
`See the evidence above and below, for example:
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`® = 98% mm
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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
`
`Apple iPad Pro tablets comprise at least one non-transitory memory (e.g., 128MB, 256MB, 512MB,
`1TB, or 2TB, etc.) storing instructions and a plurality of applications; a touch screen (e.g., Liquid
`Retina display, etc.); and one or more processors (e.g., Apple M2 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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`16
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`PAGE 17 OF 23
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`more processors execute the
`instructions to:
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`iPad Pro
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`iPad Pro 11-inch
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`Finish
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`Capacity’
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`Silver, Space Gray
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`128GB
`256GB
`512GB
`178
`2TB
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`17
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`EXHIBIT B7
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`PAGE 18 OF 23
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`Display
`
`Chip
`
`11"
`
`Liquid Retina display
`
`- —J
`
`Liquid Retina display
`
`11-inch (diagonal) LED backlit
`Multi-Touch display with IPS
`technology
`
`Apple M2 chip
`
`8-core CPU with 4 performance cores and 4
`efficiency cores
`
`10-core GPU
`
`16-core Neural Engine
`
`100GB/s memory bandwidth
`
`8GB RAM on models with 128GB, 256GB, or
`512GB storage
`
`16GB RAM on models with 1TB or 2TB
`storage
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`https://www.apple.com/ipad-pro/specs/
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`EXHIBIT B7 PAGE 19 OF 23
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`(b) display, via the touch
`screen, a first object and at
`least one other object;
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`Apple iPad Pro tablets 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 object;
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`See the evidence above and below, for example:
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`EXHIBIT B7 PAGE 20 OF 23
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`(c) detect at least one Apple iPad Pro tablets are designed to detect at least one component of a gesture on the touch screen
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`component of a gesture on | (e.g., Super Retina XDR display, etc.) on the first object (e.g., one or more controls of Control Center,
`the touch screen on the first | etc.);
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`object;
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`See the evidence above and below, for example:
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`EXHIBIT B7
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`PAGE 21 OF 23
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`(d) when a first component
`of the gesture is detected
`where a magnitude of a
`duration of the gesture
`being detected on the touch
`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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`Apple iPad Pro tablets 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 XDR
`display, etc.) on the first object (e.g., one or more controls of Control Center, etc.) is less than a first
`magnitude threshold, perform a function upon a cessation of the gesture being detected;
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`See the evidence above and below, for example:
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`PAGE 22 OF 23
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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 iPad Pro tablets 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;
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`See the evidence above and below, for example:
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`® = 98% =m
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`® = 98% mm
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`(f) 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 iPad Pro tablets 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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