PTAB

IPR2015-00396

Sony Computer Entertainment America LLC v. Aplix IP Holdings Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: User Interface for Hand-Held Electronic Device
  • Brief Description: The ’313 patent describes a user interface and input mechanisms for handheld electronic devices. The invention arranges input assemblies on front and back surfaces to leverage the natural opposition of a user's thumb and fingers, purportedly to increase data input efficiency.

3. Grounds for Unpatentability

Ground 1: Obviousness over Griffin/Rekimoto - Claims 1, 3, 8-10, and 12 are obvious over Griffin in view of Rekimoto.

  • Prior Art Relied Upon: Griffin (Application # 2003/0020692) and Rekimoto (Patent 7,088,342).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Griffin taught a handheld electronic device with front-surface inputs (a keyboard and thumbwheel) optimized for thumb use and back-surface inputs (special function keys like "Shift" and "Alt") for finger use. Crucially, Griffin disclosed that manipulating the back-surface keys changes the input function of the front-surface keys (e.g., producing an uppercase letter). Petitioner argued that Rekimoto supplemented Griffin by teaching a handheld device with a touch sensor on its back surface. This touch sensor featured "operation buttons," which were delineated active areas visually represented on the device's front display to help the user locate them. The combination of Griffin's front/back input modification system with Rekimoto's back-surface touch sensor with delineated areas allegedly rendered the limitations of claim 1 obvious. For dependent claims, Rekimoto’s disclosure of an actuator providing vibrational feedback was argued to teach the "vibratory units" of claims 8-9.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to improve Griffin’s device by replacing its discrete back-surface buttons with the more advanced back-surface touch sensor taught by Rekimoto. This combination would provide a more versatile and user-friendly interface, a known goal in handheld device design.
    • Expectation of Success: Petitioner contended that combining a back-surface touch sensor with a front-surface keyboard was a known design choice for improving handheld devices. A POSITA would have had a reasonable expectation of success in integrating these known elements to achieve the predictable result of an improved user interface.

Ground 2: Obviousness over Pallakoff/Ishihara - Claims 1, 3, 5, 10, and 12 are obvious over Pallakoff in view of Ishihara.

  • Prior Art Relied Upon: Pallakoff (Application # 2002/0163504) and Ishihara (Japanese Unexamined Patent No. 2002-77357).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Pallakoff disclosed a handheld device with "face keys" on the front and "modifier buttons" on the sides or back, an arrangement that explicitly utilized the "opposed thumb and finger ergonomics inherent in the hand." Manipulation of Pallakoff’s modifier buttons was shown to change the input function of the front keys. While Pallakoff taught the ergonomic arrangement, it was silent regarding a sensor pad for the back-surface inputs. Petitioner asserted that Ishihara remedied this by teaching a handheld device with a back-surface "touch panel switch" (a touch sensor) divided into a plurality of areas. These areas were delineated both tactilely (via convex surfaces) and visually (depicted on the front display), corresponding to the functionality of Claim 1’s "delineated active areas."
    • Motivation to Combine: A POSITA would have been motivated to incorporate the back-surface touch panel from Ishihara into the device of Pallakoff. This would improve Pallakoff's device by implementing its modifier buttons using the more flexible and modern delineated active areas taught by Ishihara, which was an obvious design improvement for similar devices.
    • Expectation of Success: Implementing back-surface touch inputs to improve handheld device ergonomics was a well-understood technique. A POSITA would have expected this combination to predictably result in a more efficient and user-friendly device.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges, primarily by adding tertiary references to the Griffin/Rekimoto and Pallakoff/Ishihara combinations. These grounds argued that adding features like an input controller (Liebenow), a D-pad with haptic feedback (Martin), a palpable detent like a resilient dome cap (Armstrong), game applications (Willner), or a gyroscope/accelerometer (Hedberg) were all obvious modifications to the base combinations.

4. Key Claim Construction Positions

Petitioner argued for the broadest reasonable interpretation of key claim terms, highlighting two as central to its invalidity arguments.

  • "delineated active areas": Petitioner asserted this term should be construed to include areas on a sensor pad that are differentiated from each other either physically or tactilely to assist a user in locating them. This construction was based on the specification's disclosure of areas that are physically shaped or that use shape-changing media to provide tactile feedback.
  • "substantially optimize a biomechanical effect of the human user's hand": Petitioner argued this phrase should encompass any input element arrangement designed to take advantage of the hand's biomechanics, specifically including the opposed tapping of the thumb and fingers. Petitioner contended that the Patent Owner attempted to narrow this term during prosecution to exclude tapping motions in favor of sliding motions to distinguish prior art. Petitioner argued this was inconsistent with the ’313 patent’s specification, which explicitly describes tapping as an efficient input method.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1 and 3-14 of the ’313 patent as unpatentable.