PTAB

IPR2016-00205

Samsung Electronics America Inc v. Tactile Feedback Technology LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Touch Screen Technology with Tactile Feedback
  • Brief Description: The ’440 patent is directed to data entry devices and methods involving touch screens with tactile force feedback. The invention is based primarily on the optical detection of surface distortion to determine touch input.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gemmell and Kasday - Claims 5, 7, 8, 11, 26, 27, 29, and 31 are 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, which teaches a computer system with a touch input device providing varied tactile feedback, discloses nearly all elements of the challenged claims. Gemmell describes vibrating a touch-sensitive plate with varying frequency and amplitude in response to user selections. However, Petitioner contended Gemmell does not explicitly teach optical detection of deflection, deformation, or distortion. This limitation, required by the proposed claim constructions, is supplied by Kasday, which teaches a touch screen using optical sensing of a deflected membrane to determine touch location. For claims requiring multiple touch inputs (e.g., claim 26), Kasday's disclosure of detecting simultaneous touches for functions like a virtual shift key or rotating graphics was also relied upon.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Kasday's optical detection method with Gemmell's system because they are analogous arts directed to touch input devices. Gemmell suggests any known touch input implementation could be used, and Kasday’s optical method represented one of a finite number of known, predictable implementations. A POSITA would also have been motivated to incorporate Kasday's multi-touch capability into Gemmell to provide well-known benefits, such as virtual keyboards, thereby improving the device's functionality.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these known elements for their established purposes, predictably resulting in a functional tactile feedback system with optical touch detection.

Ground 2: Obviousness over Gemmell and Kasday in Further View of Hoevel - Claims 5, 7, 8, 11, 26, 27, 29, and 31 are obvious over Gemmell and Kasday in further view of Hoevel.

  • Prior Art Relied Upon: Gemmell (WO 92/00559), Kasday (Patent 4,484,179), and Hoevel (EP 0 556 999 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative, arguing that if Gemmell were found not to teach vibrating the touch surface in a "generally perpendicular" direction, Hoevel explicitly does. The core teachings of Gemmell (tactile feedback system) and Kasday (optical and multi-touch sensing) remain the same as in Ground 1. Hoevel is introduced for its disclosure of a tactile feedback actuator (a T-shaped armature and electromagnet) that moves perpendicularly to impact and vibrate the data capture surface, as shown by an arrow labeled "activated motion."
    • Motivation to Combine: A POSITA seeking to improve the tactile feedback system of Gemmell/Kasday would have been motivated to incorporate Hoevel's perpendicular vibration mechanism. Perpendicular vibrations are more readily and effectively felt by a user's finger than in-plane vibrations. Maximizing the palpability of the feedback would have been a simple and obvious design choice for improving the user experience.
    • Expectation of Success: Implementing a perpendicular actuator as taught by Hoevel into the Gemmell/Kasday system would predictably result in a more effective and noticeable tactile feedback sensation for the user.

Ground 3: Obviousness over Wang and Kasday in Further View of Hoevel - Claims 5, 7, 8, 11, 26, 27, 29, and 31 are obvious over Wang and Kasday in further view of Hoevel.

  • Prior Art Relied Upon: Wang (Patent 5,461,711), Kasday (Patent 4,484,179), and Hoevel (EP 0 556 999 A1).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground substituted Wang for Gemmell as the primary reference. Wang teaches a system with a touch-sensitive pad that provides vibrational feedback corresponding to the user's finger position, particularly for navigating time-based information like audio recordings. Petitioner argued Wang teaches a method for providing tactile feedback in response to user input. As in the other grounds, Kasday was used to supply the teachings of optical sensing of surface deformation and multi-touch input, while Hoevel was used to provide the explicit teaching of perpendicular vibration for the feedback mechanism.
    • Motivation to Combine: The motivations were similar to the prior grounds. A POSITA would combine Kasday's optical sensing mechanism with Wang as one of a finite number of known ways to implement a touch input device. Kasday's multi-touch features would be incorporated to enhance Wang's functionality with predictable results. Finally, Hoevel's perpendicular vibration mechanism would be integrated to improve the effectiveness and palpability of Wang's disclosed tactile feedback, a known and desirable improvement.
    • Expectation of Success: Combining these known elements from analogous arts for their recognized purposes would have been a predictable path for a POSITA, with a high expectation of creating an enhanced and fully functional multi-touch haptic feedback device.

4. Key Claim Construction Positions

  • "touch surface": Petitioner proposed the construction "surface that deflects, deforms, or distorts when touched." This construction was central to the invalidity arguments, as it directly linked the claim language to the optical deformation-sensing technology disclosed in Kasday.
  • "sensor circuit" / "touch sensor": Consistent with the above, Petitioner proposed "sensor that optically detects deflection, deformation, or distortion." This construction specified the type of sensor required, further strengthening the reliance on Kasday as necessary prior art.
  • "force feedback": Petitioner proposed "force detectable by a user’s sense of touch." This broad construction was argued to be easily met by the vibratory mechanisms in Gemmell and Wang.
  • Petitioner noted that these proposed constructions reflected preliminary rulings from a parallel district court litigation involving the ’440 patent.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 5, 7, 8, 11, 26, 27, 29, and 31 of the ’440 patent as unpatentable.