PTAB

IPR2016-00207

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
  • Brief Description: The ’843 patent describes a data entry device that uses optical detection of surface distortion. The challenged claims are directed to methods and devices that combine touch screens with tactile force feedback.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gemmell and Kasday - Claims 11 and 20 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 disclosed a computer system with a touch-sensitive screen that provides varied tactile feedback (vibration) depending on the location of the touch. However, Gemmell did not explicitly teach detecting touch via "deflection, deformation, or distortion" as required by the construed claims. Kasday was asserted to supply this limitation by teaching a touch sensor that optically detects the deformation or distortion of a flexible membrane. For dependent claim 20, Petitioner contended that Gemmell’s vibrating mechanism (a speaker coil attached to a corner of the screen) inherently actuates the screen in a direction generally perpendicular to its surface.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Gemmell and Kasday as they are analogous art directed to touch input devices. Gemmell suggests any known touch-sensitive screen could be used, and Kasday taught a specific, known implementation using optical deformation detection. A POSITA would be motivated to implement Gemmell's feedback system with Kasday's sensor to achieve a complete, functional device. Additional motivation was cited to incorporate Kasday’s multi-touch capabilities to enhance Gemmell's system with well-known features like virtual keyboards, which improve usability and reliability.
    • Expectation of Success: Combining a known feedback system (Gemmell) with a known touch detection system (Kasday) was argued to involve predictable design choices with a high expectation of success.

Ground 2: Obviousness over Wang and Kasday - Claim 11 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 this combination was similar to the first ground, with Wang serving as the primary reference. Wang was said to disclose a system with a touch-sensitive pad that provides vibratory and audio feedback to a user's finger, with the feedback corresponding to the location of the touch on a two-dimensional surface. As with Gemmell, Wang did not explicitly teach detecting touch via surface distortion. Kasday was again relied upon to teach an optical system for detecting touch by sensing the deformation of a surface membrane.
    • Motivation to Combine: Petitioner asserted that Wang and Kasday are both directed to touch-sensitive screens and are thus analogous. A POSITA would have been motivated to implement the system in Wang using Kasday's well-known optical touch-sensing mechanism. Further, a POSITA would have sought to combine Kasday's multi-touch functionality with Wang's device to provide the benefits of multi-touch gestures and to enable more reliable virtual keyboard input, a known area for improvement in touch interfaces at the time.
    • Expectation of Success: The combination was presented as the integration of known technologies to achieve a predictable improvement in functionality and user interface design.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claim 20 based on Gemmell, Kasday, and Hoevel (EP 0 556 999 A1), and separately on Wang, Kasday, and Hoevel. In these grounds, Hoevel was added to explicitly teach vibrating a touch surface in a "generally perpendicular" direction, as Hoevel discloses actuators and spring mountings designed to produce perpendicular motion for more effective tactile feedback.

4. Key Claim Construction Positions

  • Petitioner relied on preliminary constructions from a parallel district court litigation, which were central to its invalidity arguments.
  • "touch surface": Construed as a "surface that deflects, deforms, or distorts when touched." This construction was critical because the primary references (Gemmell and Wang) did not explicitly disclose this method of touch detection, making the secondary reference (Kasday), which teaches optical detection of surface deformation, essential to the obviousness combinations.
  • "generally perpendicular" (claim 20): Given its plain and ordinary meaning. Petitioner argued this was met by Gemmell’s actuator design but introduced Hoevel in alternative grounds to provide an explicit teaching of perpendicularly-acting force elements for tactile feedback.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 11 and 20 of the ’843 patent as unpatentable under 35 U.S.C. §103.