PTAB

IPR2016-00305

Aristocrat Technologies Inc v. Igt

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Gaming Device with Multi-Purpose Reels
  • Brief Description: The ’675 patent relates to gaming devices, such as video slot machines, that use a video display to show multiple video reels. The core inventive concept involves displaying an "exhibition" on one or more of the video reels to inform a player of a specific game outcome, such as a winning combination or the initiation of a bonus game.

3. Grounds for Unpatentability

Ground I: Obviousness over Manship - Claims 1-10 and 12-17 are obvious over Manship.

  • Prior Art Relied Upon: Manship (Patent 5,697,843).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Manship, which teaches a video slot machine, discloses every element of the challenged claims. Manship describes a 3x3 array of video reels on a display screen controlled by a processor. Upon a triggering event (a "crossed bells" combination), Manship’s game enters a "Swinging Bells" bonus mode where the bells are enlarged and color-enhanced. During the bonus game, winning bell symbols animate by swinging back and forth. Petitioner asserted these animations (enlarging, color-enhancing, swinging) meet the ’675 patent's broad definition of an "exhibition" that informs the player they have reached a game outcome (i.e., a bonus opportunity or a bonus payout).
    • Motivation to Combine (for §103 grounds): N/A (single reference ground).
    • Expectation of Success (for §103 grounds): N/A (single reference ground).
    • Key Aspects: Petitioner contended that because each reel in Manship is adjacent to another, and the "exhibition" can appear on any of the nine reels, the locational requirements of the claims (e.g., at the position of a reel adjacent to another reel) are inherently met.

Ground II: Obviousness over Manship and Barrie - Claims 11 and 13 are obvious over Manship in view of Barrie.

  • Prior Art Relied Upon: Manship (Patent 5,697,843) and Barrie (Patent 5,833,537).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Manship by adding Barrie to address specific dependent claim limitations. For claim 11 (an exhibition across a plurality of reels between two other reels), Barrie was cited for teaching that electronic slot machines can have more or fewer reels than a standard configuration. For claim 13 (an exhibition including a textual message), Barrie was cited for disclosing an animation on a reel that includes the text "5x" to indicate a payline multiplier.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Manship with Barrie to vary gameplay and alter payout characteristics to make the game more appealing. Barrie teaches that changing the number of reels is a known way to alter game characteristics. A POSITA would also be motivated to add Barrie’s textual multiplier feature to Manship to implement persistent features that encourage continued play.
    • Expectation of Success (for §103 grounds): Combining these known gaming features involved predictable results with a high expectation of success.

Ground IV: Obviousness over Cannon - Claims 1, 10-12 are obvious over Cannon.

  • Prior Art Relied Upon: Cannon (Patent 5,766,074).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented Cannon as an alternative primary reference to Manship. Cannon discloses a video slot machine with five vertical spinning reels. Petitioner argued that Cannon’s method of updating the display after a spin constitutes the claimed "exhibition." Specifically, Cannon teaches highlighting winning symbols with brighter colors while drawing non-winning symbols in a faded manner or removing them entirely. Petitioner asserted this visual change, controlled by a processor and displayed on the reels, informs the player of a winning outcome and thus meets the core limitations of claim 1.
    • Motivation to Combine (for §103 grounds): N/A (single reference ground).
    • Expectation of Success (for §103 grounds): N/A (single reference ground).

Ground V: Obviousness over Cannon and Watts - Claims 2-9 and 14-16 are obvious over Cannon in view of Watts.

  • Prior Art Relied Upon: Cannon (Patent 5,766,074) and Watts (Patent 5,775,692).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds the teachings of Watts to Cannon to address claim limitations related to bonus games and bonus spins. Watts explicitly discloses a bonus spin feature for a slot machine, where certain symbol combinations enable the reels to be spun again as part of the same game. This provides the "opportunity to play a bonus game" (claim 2), "award of bonus credits" (claim 3), and various bonus spin limitations (claims 4-9 and 14-16) that are not expressly detailed in Cannon.
    • Motivation to Combine (for §103 grounds): A POSITA implementing the exhibition features of Cannon would have been motivated to add the well-known and attractive feature of bonus spins to increase player engagement and the size of potential prizes. Watts is directed specifically to such bonus features and would have been a natural reference for a POSITA to consult to implement them in the Cannon system.
    • Expectation of Success (for §103 grounds): Combining a known bonus spin feature (Watts) with a base game (Cannon) was a routine design choice in the art that would have yielded predictable results.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Manship with Thomas (shaking reels); combining Cannon with Bennett (animated wild card symbol awarding bonus credits); and various three-reference combinations (Cannon/Watts/Bennett and Cannon/Watts/Thomas) to address remaining claims with similar design modification theories.

4. Key Claim Construction Positions

  • "exhibition": Petitioner argued that the Board should adopt the patent’s express definition provided in the specification. This definition is exceptionally broad, encompassing "(a) reels which are animated; and/or (b) an audio, visual or audiovisual representation of a person, place or thing in motion or at rest..." This broad construction was central to Petitioner's arguments, allowing common visual effects like animating symbols (Manship) or highlighting winning combinations (Cannon) to qualify as the claimed "exhibition."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 and 33-34 of the ’675 patent as unpatentable.