Samsung Electronics America Inc v. Tactile Feedback Technology LLC

1. Case Identification

• Case #: IPR2016-00202
• Patent #: 8,068,100
• Filed: November 17, 2015
• Petitioner(s): Samsung Electronics America, Inc.
• Patent Owner(s): Tactile Feedback Technology, LLC
• Challenged Claims: 31

2. Patent Overview

• Title: Touch Screen Technology
• Brief Description: The ’100 patent discloses a data entry device that uses optical detection of surface distortion to sense touch inputs. The claimed invention combines a touch screen with tactile force feedback that varies based on the user's input.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gemmell and Kasday - Claim 31 is obvious over Gemmell in view of Kasday.

• Prior Art Relied Upon: Gemmell (WO 92/00559) and Kasday (Patent 4,484,179).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Gemmell disclosed all elements of claim 31 except for the specific method of sensing touch via deflection, deformation, or distortion, and the capability to sense multiple simultaneous touches. Gemmell taught a computer system with a touch input device that provides varying tactile feedback (e.g., vibration) based on the location and nature of the touch. Petitioner asserted that Kasday supplied the missing elements by teaching a touch screen that uses optical sensing to detect the deflection and deformation of a surface and is explicitly capable of sensing multiple, simultaneous touches for functions like rotating a shape or using a shift key.
  • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would be motivated to combine these references because they are analogous art, both directed to touch input devices. Gemmell was described as teaching a general system and suggesting that any known touch input implementation could be used. Kasday provided a known, specific implementation for a touch screen. A POSITA would have found it obvious to use Kasday's optical, multi-touch sensing mechanism to implement Gemmell's system to gain the known benefits of multi-touch input, such as enabling virtual keyboards, enhancing reliability, and allowing for a greater number of input gestures.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining the known touch-sensing technology of Kasday with the feedback system of Gemmell was a predictable integration of known components to achieve a predictable result.

Ground 2: Obviousness over Wang and Kasday - Claim 31 is obvious over Wang in view of Kasday.

• Prior Art Relied Upon: Wang (Patent 5,461,711) and Kasday (Patent 4,484,179).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wang, like Gemmell in the first ground, disclosed most elements of claim 31 but lacked the specific teaching of sensing touch via surface deflection, deformation, or distortion. Wang taught a touch-sensitive interface pad that provides vibration feedback to a user's finger and could sense "multiple finger positions." Petitioner again relied on Kasday to teach the optical detection of surface deformation and its robust multi-touch capabilities.
  • Motivation to Combine: The motivation to combine Wang and Kasday mirrored the reasoning in Ground 1. Petitioner argued that Wang was not limited to a specific touch-sensing mechanism, making Kasday's optical deformation sensor an obvious and available implementation choice. A POSITA would combine the references to add the known benefits of Kasday's multi-touch technology—such as improved virtual keyboard functionality and increased reliability for safety-critical inputs—to the tactile feedback system of Wang. Petitioner further asserted that because Wang's touch pad and Kasday's touch screen were both flat, touch-sensitive input devices, a POSITA would have recognized them as interchangeable.
  • Expectation of Success: Success was predictable as it involved substituting one known type of touch sensor (Kasday's) into a system (Wang's) that was agnostic to the specific sensor implementation, thereby combining known elements for their established purposes.

4. Key Claim Construction Positions

• "touch surface": Petitioner adopted the district court's preliminary construction of "surface that deflects, deforms, or distorts when touched." This construction was central to the invalidity arguments, as it necessitated a reference like Kasday that explicitly taught detecting physical changes in the touch surface, a feature Petitioner argued was absent from the primary references Gemmell and Wang.
• "force feedback" / "force feedback signal": Petitioner adopted the construction "force detectable by a user's sense of touch." This broad construction allowed Petitioner to map the vibration feedback disclosed in both Gemmell and Wang directly onto this claim limitation.
• "force element": Petitioner adopted the agreed-upon construction "component that generates a force feedback signal to a user." This allowed Petitioner to identify components like the speaker coils and activators in Gemmell and Wang as meeting this limitation.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claim 31 of the ’100 patent as unpatentable.